### U n i t e d S t a t e s O f f i c e o f W a t e r E P A 8 3 3

- R

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- 0 0 5 E n v i r o n m e n t a l P r o t e c t i o n W a s h i n g t o n , D C 2 0 4 6 0 A u g u s t 2 0 1 0 A g e n c y www.epa.gov/npdes F i n a l R e p o r t



# R e p o r t t o C o n g r e s s :

S t u d y o f D i s c h a r g e s I

n c i d e n t a l t o N o r m a l O p e r a t i

o n o f C o m m e r c i a l F i

s h i n g V e s s e l s a n d O t h e r N o n - R e c r e a t i

o n a l V e s s e l s L e s s t h a n 7 9 F e e t

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### ACKNOWLEDGMENTS



## The EPA Office of Wastewater Management (OWM) presents this draft Vessels Study Report to Congress conducted to meet th e obligations of EPA under Public Law (P.L.) 110-299 (July 31, 2008). EPA would like to thank the numerous trade associations and individual companies who contributed to this project. Thos e groups who provided assistance to EPA are listed in Chapter 2 of th is report. The project could not have been successful without the support by EPA Regi on 2, 3, and 5 laboratories, EPA Gulf Ecology Division and other EPA program offices. EPA would also like to thank the United States Coast Guard for providing both lo gistical support and review of many of the report’s elements. Finally, EPA would also like to acknowledge the contractor support for this project provided by individua ls from Great Lakes Environmental Center, Inc., Eastern Research Group, and Abt Associates.

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## The primary technical contacts for this document are:

Ryan Albert U.S. Environmental Protection Agency

Office of Water (Mail Code: 4203M) 1200 Pennsylvania Avenue, NW Washington, DC 20460 (202) 564-0763 (telephone) (202) 564-6392 (fax)

Robin Danesi U.S. Environmental Protection Agency

Office of Water (Mail Code: 4203M) 1200 Pennsylvania Avenue, NW Washington, DC 20460 (202) 564-1846 (telephone) (202) 564-6392 (fax)

The primary EPA congressional relations contact for this document is:

Greg Spraul U.S. Environmental Protection Agency Office of Congressional a nd Intergovernmental Rela tions (Mail Code: 1301A) 1200 Pennsylvania Avenue, NW Washington, DC 20460 (202) 564-0255 (telephone) (202) 564-1519 (fax)

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## TABLE OF CONTENTS

EXECUTI VE SUMMARY ........................................................................................................ xv CHAPTER 1 Introduction to the Report ................................................................................... 1 1.1. Congressional Study Charge................................................................................... 1 1.2. Organization of this report...................................................................................... 2 1.3. Classes or Types of Vessels.................................................................................... 2 1.3.1. Commercial Fishing Vessels................................................................................... 3 1.3.2. Tugs/Towing Vessels.............................................................................................. 8 1.3.3. Water Taxis/Small Ferries ...................................................................................... 9 1.3.4. Tour Boats............................................................................................................... 9 1.3.5. Recreational Vessels Used for Non-Recreational Purposes ................................. 10 1.4. Vessel Population.................................................................................................. 11 1.4.1. Vessel Characteristics Data................................................................................... 11 1.4.2. Overview of Vessel Universe ............................................................................... 12 1.5. Discharges from Vessels....................................................................................... 24 1.5.1. Bilgewater............................................................................................................. 25 1.5.2. Deck Washdown and Deck Runoff....................................................................... 25 1.5.3. Engine Effluent ..................................................................................................... 26 1.5.4. Firemain Systems.................................................................................................. 28 1.5.5. Fish Hold and Fish Hold Cleaning Efflue nt (Refrigerated Seawater Discharge or Fish Ice Slurry Discharge) .................................................................................... 29 1.5.6. Graywater.............................................................................................................. 31 1.5.7. Shaft Packing Gland Effluent ............................................................................... 31 1.5.8. Antifouling Hull Coatings..................................................................................... 32 1.6. Pollutants Potentially Found in Vessel Discharges .............................................. 32 1.6.1. Classical Pollutants ............................................................................................... 33 1.6.2. Nutrients................................................................................................................ 35 1.6.3. Pathogen Indicators............................................................................................... 36 1.6.4. Metals.................................................................................................................... 36 1.6.5. Volatile and Semivolatile Organic Compounds ................................................... 36 1.6.6. Nonylphenols ........................................................................................................ 37 1.7. Chapter Conclusions ............................................................................................. 37 CHAPTER 2 Study Design ........................................................................................................ 39 2.1 Data Sources ......................................................................................................... 39 2.1.1 Existing EPA Data Sources .................................................................................. 39 2.1.2 Industry Participation............................................................................................ 40 2.1.3 Vessel Sampling.................................................................................................... 42 2.1.4 Literature Review.................................................................................................. 42 2.1.5 Other Governmental Data Sources ....................................................................... 42 2.2 EPA Vessel Discharge Sampling Program........................................................... 43 2.2.1 Vessels Sampled and Locations............................................................................ 44 2.2.2 Sampled Discharges.............................................................................................. 49 2.2.3 Target Analytes..................................................................................................... 51 2.2.4 Sampling Methods ................................................................................................ 53 2.2.5 QA/QC .................................................................................................................. 58

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## 2.3 Data Considerations and study limitations ........................................................... 61 2.3.1 Voluntary Nature of the Sampling Program ......................................................... 61 2.3.2 Vessels/Discharges Not Sampled ......................................................................... 62 2.3.3 Pollutants Not Sampled......................................................................................... 63 2.3.4 Application to Other Vessels, Includi ng Larger Vessels Not Sampled for this Study ..................................................................................................................... 63 CHAPTER 3 Analysis of Disc harges and Potential Impact to Human Health and the Environment........................................................................................................ 67 3.1 Approach to Analyses........................................................................................... 67 3.1.1 Data Reduction and Presentation.......................................................................... 68 3.1.2 Summary Statistics and Box Plots ........................................................................ 69 3.1.3 Calculation of Potential Hazard Quotients ........................................................... 70 3.2 Characterization of Discharges............................................................................. 79 3.2.1 Bilgewater............................................................................................................. 79 3.2.2 Stern Tube Packing Gland Effluent .................................................................... 115 3.2.3 Deck Washdown ................................................................................................. 143 3.2.4 Fish Hold and Fish Hold Cleaning Effl uent (Refrigerated Seawater and Ice Slurry) ................................................................................................................. 188 3.2.5 Graywater............................................................................................................ 234 3.2.6 Engine Effluent ................................................................................................... 261 3.2.7 Firemain Discharges ........................................................................................... 338 3.2.8 Antifouling Hull Coatings................................................................................... 354 CHAPTER 4 Potential Large-Scal e Impacts of Study Vessels’ Incidental Discharges to Human Health and the Environment.............................................................. 368 4.1 Model Selection .................................................................................................. 370 4.2 Fraction of Freshwater Model............................................................................. 371 4.2.1 Step 1: Calculate Vessel Disc harge Analyte Loading Rates .............................. 372 4.2.2 Step 2: Calculate the Fraction of Freshwater in the Harbor................................ 373 4.2.3 Step 3: Calculate the Ha rbor Flushing Time....................................................... 373 4.2.4 Step 4: Calculate the Harbor Analyte Concentration.......................................... 374 4.3 Vessel Discharge Loading Rates ........................................................................ 374 4.3.1 Calculate the Average Analyte Concentrations .................................................. 374 4.3.2 Discharge Flow Rate Assumptions..................................................................... 375 4.3.3 Number of Vessels Present in the Harbor........................................................... 381 4.3.4 Percentage of Vessels Disc harging in the Harbor............................................... 385 4.3.5 Vessel Discharge Loading Rates ........................................................................ 387 4.3.6 Dissolved Copper Loading Rates from Antifouling Paints ................................ 387 4.4 Hypothetical Harbor............................................................................................ 389 4.5 Model Scenarios.................................................................................................. 391 4.6 Model Results ..................................................................................................... 393 4.6.1 Dilution Factor Analysis..................................................................................... 393 4.6.2 Supplemental Model Run in Response to Comments......................................... 394 4.6.3 Loading Rate Analysis........................................................................................ 395 4.7 Conclusions......................................................................................................... 399 CHAPTER 5 Summary of Findings........................................................................................ 401 5.1 Summary of Classes of Vessels Covered By this Study..................................... 401

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## 5.2 Summary of Effluent Char acterization of Select Di scharges from the Study Vessels ................................................................................................................ 401 5.2.1 Estimated Volumes of Select Disc harges from the Study Vessels..................... 402 5.2.2 Analytes of Potential Risk in Select Discharges from Study Vessels ................ 404 5.3 Summary of Predicted Impacts from Select Pollutants in Study Vessel Discharges........................................................................................................... 417 5.3.1 Potential Watershed-Wide Im pacts from Study Vessels .................................... 417 5.3.2 Potential Localized or Near-Field Imp acts of Vessel Discha rges to Receiving Waters ................................................................................................................. 418 5.4 Possible Benefits to Human Health, Welfare, and the Environment from Reducing, Eliminating, Controlling, or Miti gating One or More of the Discharges from the Study Vessels ....................................................................................... 420 CHAPTER 6 Analysis of the Extent to Whic h Incidental Discharg es are Currently Subject to Regulation Under Federal Law or a Binding International Obligation of the United States ............................................................................................... 422 6.1 International Agreements.................................................................................... 422 6.1.1 The International Convention for the Prevention of Pollution from Ships (MARPOL 73/78) ............................................................................................... 422 6.1.2 The International Conventi on on the Control of Harmfu l Anti-Fouling Systems on Ships.................................................................................................................... 432 6.1.3 International Convention for the Safety of Life at Sea (SOLAS)....................... 435 6.1.4 Boundary Waters Treaty..................................................................................... 436 6.1.5 Great Lakes Water Quality Agreement............................................................... 436 6.1.6 St. Lawrence Seaway Regulations...................................................................... 439 6.2 Federal Laws....................................................................................................... 440 6.2.1 Act to Prevent Pollution from Ships (APPS)...................................................... 440 6.2.2 Clean Water Act (CWA) §§ 311, 312/Oil Pollution Control Act....................... 444 6.2.3 Organotin Antifouling Paint Control Act ........................................................... 446 6.2.4 National Invasive Species Act ............................................................................ 447 6.2.5 Hazardous Materials Transportation Act............................................................ 448 6.2.6 National Marine Sanctuaries Act........................................................................ 448 6.2.7 Resource Conservation and Recovery Act ......................................................... 449 6.2.8 Federal Insecticide, Fungicide, and Rodenticide Act ......................................... 450 6.3 Additional Internationa l and Federal Laws......................................................... 451 6.3.1 International Convention on the Preventi on of Marine Pollution by Dumping of Wastes and Other Matter .................................................................................... 451 6.3.2 International Convention on Oil Poll ution, Preparedness, Response and Cooperation......................................................................................................... 452 6.3.3 International Convention Relating to Interv ention on the High Seas in Cases of Oil Pollution Casualties ...................................................................................... 452 6.3.4 Comprehensive Environmental Response, Compensation, and Liability Act.... 452 6.3.5 CWA § 402, National Pollutant Discharg e Elimination System (NPDES)........ 453 6.3.6 Title XIV of the Consolidated Appropri ations Act, 2001—Certain Alaskan Cruise Ship Operations................................................................................................... 453 6.3.7 Toxic Substances Control Act ............................................................................ 453

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## 6.4 Application of Legal Authorities to Di scharges Incidental to the Normal Operation of Study Vessels................................................................................. 454 CHAPTER 7 References .......................................................................................................... 458 Appendix A List of Acronyms ................................................................................................. A-1 Appendix B Additional Charac teristics of the P.L. 110 – 299 Vessel Population............... B-1 B.1 Vessel Subcategories .......................................................................................... B-1 B.1.1 Population of Vessels undergoi ng Discharge Analysis ...................................... B-2 B.2 Vessel Geographical Area of Operation ............................................................. B-4 B.3 Other Vessel Characteristics: Construction and Propulsion ............................. B-11 B.3.1 Vessel Age ........................................................................................................ B-12 B.3.2 Hull Material Type............................................................................................ B-13 B.3.3 Propulsion Method and Type............................................................................ B-15 B.3.4 Horsepower Ahead............................................................................................ B-16 B.4 Distribution of the Study Vessel Univer se versus the Recreational Vessel Universe ............................................................................................................ B-18 B.5 Vessels Documented, Inspected, and/or State Registered ................................ B-25
B.6 Uncertainty........................................................................................................ B-26 Appendix C Public Law 110-299 (S. 3298) and Public Law 110-288 (S. 2766) ................... C-1 Appendix D List of Ta rget Analytes ....................................................................................... D-1 Appendix E Analyte Concentrations and Summa ry Statistics from Ambient Water Samples ............................................................................................................................ E-1 Appendix F Analyte Concentrations and Summa ry Statistics from Source Water Samples .............................................................................................................................F-1 Appendix G Supporting Information for EPA’s Screening-Level Water Quality Model .G-1 Appendix H Responsiveness Summary...................................................................................H-1 Appendix I List of Prepa rers and Contributors ......................................................................I-1

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## LIST OF TABLES

Table 1.1. Population of Operational, Dom e stic MISLE Vessels by Vessel Length ................... 14 Table 2.1. Number of Vessels Sample d by Vessel Class and Discharge ..................................... 46 Table 2.2. Analyte Groups by Discharge...................................................................................... 52 Table 3.1. Water Quality and Othe r Benchmark Values Used to Screen the Vessel Discharge Data................................................................................................................................... 75 Table 3.2. Major Cation Concen trations in Seawater................................................................... 78 Table 3.3. Major Cation Concentr ations in Freshwater................................................................ 78 Table 3.1.1. Results of Bilgewater Sample Analyses for Dissolved Metals................................. 85 Table 3.1.2. Results of Bilgewater Samp le Analyses for Total Metals ........................................ 86 Table 3.1.3. Results of Bilgewater Sample Analyses for Classical Pollutants............................. 93 Table 3.1.4. Results of Bilgewater Sample Analyses for Pathogen Indicators............................. 97 Table 3.1.5. Results of Bilgewater Sa mple Analyses for Nutrients.............................................. 99 Table 3.1.6. Results of Bilgewater Sample Analyses for SVOCs .............................................. 103 Table 3.1.7. Results of Bilgewater Sample Analyses for VOCs ................................................ 108 Table 3.1.8. Results of Bilgewater Sa mple Analyses for Nonylphenols.................................... 112 Table 3.1.9. Characterization of Bilg ewater Discharge and Summary of Analytes that May Have the Potential to Pose Risk ............................................................................................... 114 Table 3.2.1. Results of Packing Gland Effl uent Sample Analyses for Metals ........................... 118 Table 3.2.2. Results of Packing Gland Effluent Sa mple Analyses for Classical Pollutants....... 125 Table 3.2.3. Results of Packing Gland Efflue nt Sample Analyses for Nutrients ....................... 129 Table 3.2.4. Results of Packing Gland Water Sample Analyses for SVOCs and VOCs............ 133 Table 3.2.5. Results of Packing Gland Wate r Sample Analyses for Nonylphenols ................... 139 Table 3.2.6. Characterization of P acking Gland Effluent and Summ ary of Analytes that May Have the Potential to Pose Risk...................................................................................... 142 Table 3.3.1. Results of Deck Washdown/R unoff Sample Analyses for Metals ......................... 152 Table 3.3.2. Dissolved-to-Total Metal Ratios (f d 

## s) in Paired Deck Washdown/Runoff Samples....................................................................................................................... .... 154 Table 3.3.3. Minimum and Maximum Dissolved a nd Total Metal Concen trations in Vessel Source and Ambient (Harbor) Water Relative to Median Sample Concentrations and Most Stringent Screening Benchmarks........................................................................... 154 Table 3.3.4. Comparison of Metal Concentratio ns in Deck Washdown Discharge Between Fishing Vessels and Non-Fishing Vessels ...................................................................... 155 Table 3.3.5. Mean Concentrations of Dissolved and Total Heavy Metals from Deck Wash Discharges from Fishing Vesse ls and Nonfishing Vessels............................................. 156 Table 3.3.6. Results of Deck Washdown Water Sa mple Analyses for Classical Pollutants ...... 164 Table 3.3.7. Results of Deck Washdown Water Sa mple Analyses for Pathogen Indicators...... 169 Table 3.3.8. Results of Deck Washdown Wate r Sample Analyses for Nutrients....................... 174 Table 3.3.9. Results of Deck Washdown Wa ter Sample Analyses for Long-Chain Nonylphenols .................................................................................................................. 178 Table 3.3.10. Results of Deck Washdown Water Sample Analyses for VOCs and SVOCs...... 182 Table 3.3.11. Characterization of Deck Washdown and Runoff Water and Su mmary of Analytes that May Have the Potential to Pose Risk....................................................................... 187 Table 3.4.1. Results of Fish Hold Effluent Sample Analyses for Total Metals.......................... 195 Table 3.4.2. Results of Fish Hold Effluent Sample Analyses for Dissolved Metals .................. 196

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## Table 3.4.3. Results of Fish Hold Cleaning E ffluent Sample Analyses for Metals .................... 202 Table 3.4.4. Results of Fish Hold Effluent Sa mple Analyses for Classical Pollutants............... 210 Table 3.4.5. Results of Fish Hold Cleaning Effl uent Analyses for Classical Pollutants ............ 211 Table 3.4.6. Results of Fish Hold and Fish Ho ld Cleaning Effluent Sample Analyses for Pathogen Indicators......................................................................................................... 217 Table 3.4.7. Results of Fish Hold (upper half) an d Fish Hold Cleaning Effluent (lower half) Sample Analyses for Nutrients ....................................................................................... 221 Table 3.4.8. Raw Sewage Concentr ations of Nutrients .............................................................. 221 Table 3.4.9. Results of Fish Hold Cleaning E ffluent Sample Analyses for Long-chain Nonylphenols .................................................................................................................. 226 Table 3.4.10. Means (and Standard Deviations ) for Selected Analyte Concentrations, by Geographic Region. Units for All Analytes Expressed as μg/L, Except for BOD (mg/L).................................................................................................................... 230 Table 3.4.11. Characterization of Fish Hold Effl uent and Fish Hold Cleaning Effluent and Summary of Analytes th at May Have the Potential to Pose Risk................................... 233 Table 3.5.1. Results of Graywater Sample Analyses for Pathogen Indicators ........................... 236 Table 3.5.2. Results of Graywater Sample Analyses for Classical Pollutants............................ 241 Table 3.5.3. Results of Graywater Sample Anal yses for Nonylphenols (only long-chain NPEOs and OPEOs were detected) ............................................................................................. 245 Table 3.5.4. Results of Graywater Sample Analyses for Dissolved Metals ............................... 248 Table 3.5.5. Results of Graywater Samp le Analyses for Total Metals....................................... 249 Table 3.5.6. Results of Graywater Samp le Analyses for Nutrients ............................................ 255 Table 3.5.7. Characterization of Gr aywater Effluent and Summary of Analytes that May Have the Potential to Pose Risk ............................................................................................... 260 Table 3.6.1. Sampled Engine Characteristics ............................................................................. 263 Table 3.6.2. Results of Inboard Propu lsion Engine Sample Analyses for Classical Pollutants . 267 Table 3.6.3. Results of Inboard Propulsion E ngine Sample Analyses for Metals...................... 271 Table 3.6.4. Comparison of Metals Results fo r EPA P.L. 110-299 and UNDS Engine Wet Exhaust Sampling ........................................................................................................... 273 Table 3.6.5. Results of Inboard Propulsion E ngine Sample Analyses for SVOCs..................... 280 Table 3.6.6. Comparison of Phenol Results fo r EPA P.L. 110-299 and UNDS Engine Wet Exhaust Sampling ........................................................................................................... 281 Table 3.6.7. Results of Inboard Propulsion Engine Sample Analyses for VOCs....................... 286 Table 3.6.8. Results of Outboard Propulsion E ngine Sample Analyses for Classical Pollutants.................................................................................................................... ..... 292 Table 3.6.9. Results of Outboard Propulsion Engine Sample Analyses for Metals ................... 295 Table 3.6.10. Results of Outboard Propulsion Engine Sample Analyses for SVOCs................ 302 Table 3.6.11. Results of Outboard Propulsion Engine Sample Analyses for VOCs .................. 305 Table 3.6.12. Results of Generator Engine Samp le Analyses for Classical Pollutants .............. 310 Table 3.6.13. Results of Generator Engine Sample Analyses for Metals................................... 313 Table 3.6.14. Results of Generator Engine Sample Analyses for SVOCs ................................. 319 Table 3.6.15. Results of Generator Engine Sample Analyses for VOCs.................................... 324 Table 3.6.16. Mean Concentration Results, UNDS Engine Wet Exhaust Discharge and Background Samples for the LCPL ................................................................................ 330 Table 3.6.17. Mean Concentration Results, UNDS Engine Wet Exhaust Discharge and Background Samples for the RIB ................................................................................... 331

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## Table 3.6.18. Comparison of Dewinterizing Effluent with Propulsion Effluent ........................ 333 Table 3.6.19. Comparison of Number of Det ected Analytes in Engine Effluent ....................... 334 Table 3.6.20. Comparison of Results for Sel ected Analytes in Engine Effluent........................ 334 Table 3.6.21. Characterization of Engine Effluent and Summary of Analytes that May Have the Potential to Pose Risk ..................................................................................................... 336 Table 3.7.1. Results of Firemain System Sample Analyses for Metals...................................... 341 Table 3.7.2. Results of Firemain System Water Sa mple Analyses for Classical Pollutants....... 347 Table 3.7.3. Results of Firemain Wate r Sample Analyses for SVOCs....................................... 350 Table 3.7.4. Characterization of Fi remain Discharge and Summary of Analytes that May Have the Potential to Pose Risk ............................................................................................... 353 Table 3.8.1. Rates of Passive Coppe r Leaching from Vessel AFSs ........................................... 361 Table 3.8.2. Dissolved Copper Release from Vessel AFSs During an Underwater Hull Cleaning “Event”............................................................................................................................ 362 Table 3.8.3. Estimated Dissolved Copper Mass Emi ssions from a 9.1m (30ft) Powerboat....... 362 Table 4.3.1. Offload Frequency by Fishing Vessel Subtype ...................................................... 376 Table 4.3.2. Examples of Field Data and Assu mptions for Flow Rate Calculations by Discharge ..................................................................................................................... ... 377 Table 4.3.3. Vessel Flow Rates................................................................................................. .. 379 Table 4.3.4. Vessel Population Scenario Represen tative Harbors Based on the Top 20 Hailing Ports Cited in the MISLE Database................................................................................ 382 Table 4.3.5. Percentage of Study Vessels Presen t in Representative Fishing Harbor................ 383 Table 4.3.6. Percentage of Study Vessels Presen t in Representative Large Metropolitan Harbor ........................................................................................................................ ..... 383 Table 4.3.7. Percent of Study Vessels Present in Representative Recreational Harbor ............. 384 Table 4.3.8. Vessel Population Scenarios................................................................................... 385 Table 4.3.9. Percentage of Vessels Discharging in the Harbor .................................................. 386 Table 4.3.10. Estimated Average Vessel Length by Vessel Class.............................................. 388 Table 4.4.1. Harbors Selected for Mode l Input Parameter Development................................... 389 Table 4.4.2. Hypothetical Har bor Input Parameters ................................................................... 390 Table 4.4.3. Hypothetical Ha rbor Scenarios............................................................................... 391 Table 4.5.1. Fraction of Freshw ater Model Scenarios................................................................ 392 Table 4.6.1. “Tipping Point” Dilution Factors for Ha rbor Instantaneous Concentration to Equal the NRQWC Based on Vessel Population Scenario Loading Rates 1 

## ............................ 394 Table 4.6.2. Revised Model Assumptions .................................................................................. 394 Table 4.6.3. Supplemental Model Run “Tipping Point” Dilution Factors for Harbor Instantaneous Concentration to Equal the NRQWC Based on Vessel Population Scenario Loading
Rates......................................................................................................................... ....... 395 Table 4.6.4. Comparison of Model Loading Rates w ith Other Potential Point Source Loading Rates................................................................................................................................ 398 Table 5.1. Analytes of Potential Risk by Discharge ................................................................... 411 Table 6. 1. International Treaties and Federal Laws Applicable to Discharges Incidental to the Normal Operation of Vessels...................................................................................................... 455 Table 6.2. International Treaties and Federal Laws Applicable to Vessels (by Length)............ 457

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## LIST OF FI GURES

Figure 1.1. MISLE Population of Operational, Domestic Non-Recreational Vessels by Vessel Service................................................................................................................... 13 Figure 1.2. Number of Study Vessels Recorded in MISLE, by Vessel Service (Type) ............... 16 Figure 1.3. Relationship Between Ve ssel Gross Tons and Length............................................... 19 Figure 1.4. Distribution of MI SLE Vessels by Length and Vessel Service (Type)...................... 20 Figure 1.5. Cumulative Distributi on of MISLE Vessels by Length and Vessel Service (Type).. 21 Figure 1.6. Distribution of Study Vessels by Length (in Feet) and Vessel Service (Type).......... 22 Figure 1.7. Distribution of Study Ve ssels by Gross Tons and Vessel Service (for which gross ton data are given in MSLE)....................................................................................... 23 Figure 3.1.1. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Bilgewater .......................................................................................... 87 Figure 3.1.2. Box and Dot Density Plot of Total Me tals Concentrations M easured in Samples of Bilgewater............................................................................................................. 88 Figure 3.1.3. Box and Dot Density Plot of Potent ial Hazard Quotients for Dissolved Metals in Samples of Bilgewater .......................................................................................... 89 Figure 3.1.4. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Bilgewater .......................................................................................... 90 Figure 3.1.5. Box and Dot Density Plot of Classi cal Pollutant Concentrations Measured in Samples of Bilgewater .......................................................................................... 94 Figure 3.1.6. Box and Dot Density Plot of Potentia l Hazard Quotients for Classical Parameters in Samples of Bilgewater .......................................................................................... 95 Figure 3.1.7. Box and Dot Density Plot of Nutrient Concentrations Measured in Samples of Bilgewater........................................................................................................... 100 Figure 3.1.8. Box and Dot Density Plot of Potentia l Hazard Quotients for Nutrients in Samples of Bilgewater........................................................................................................... 101 Figure 3.1.9. Box and Dot Density Plot of SVOC Concentrations Measured in Samples of Bilgewater........................................................................................................... 104 Figure 3.1.10. Box and Dot Density Plot of Poten tial Hazard Quotients for SVOCs in Samples of Bilgewater........................................................................................................... 105 Figure 3.1.11. Box and Dot Density Plot of VOC Concentrations Measured in Samples of Bilgewater........................................................................................................... 109 Figure 3.1.12. Box and Dot Density Plot of Poten tial Hazard Quotients for VOCs in Samples of Bilgewater........................................................................................................... 110 Figure 3.2.1. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Packing Gland Effluent.................................................................... 120 Figure 3.2.2. Box and Dot Density Plot of Total Me tals Concentrations M easured in Samples of Packing Gland Effluent....................................................................................... 121 Figure 3.2.3. Box and Dot Density Plot of Potent ial Hazard Quotients for Dissolved Metals in Samples of Packing Gland Effluent.................................................................... 122 Figure 3.2.4. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Packing Gland Effluent.................................................................... 123 Figure 3.2.5. Box and Dot Density Plot of Classica l Pollutants Measured in Samples of Packing Gland Effluent..................................................................................................... 126

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## Figure 3.2.6. Box and Dot Density P lot of Potentia l Hazard Quotients for Classical Pollutants in Samples of Packing Gland Effluent.................................................................... 127 Figure 3.2.7. Box and Dot Density Plot of Nutrient Concentrations Measured in Samples of Packing Gland Effluent....................................................................................... 130 Figure 3.2.8. Box and Dot Density Plot of Potent ial Hazard Quotients for Nutrients in Packing Gland Effluent..................................................................................................... 131 Figure 3.2.9. Box and Dot Density Plot of SVOC Concentrations Measured in Samples of Packing Gland Effluent Samples ........................................................................ 134 Figure 3.2.10. Box and Dot Density Plot of VOC Concentrations Measured in Samples of Packing Gland Effluent Samples ........................................................................ 135 Figure 3.2.11. Box and Dot Density Plot of Poten tial Hazard Quotients for SVOCs in Samples of Packing Gland Effluent....................................................................................... 136 Figure 3.2.12. Box and Dot Density Plot of Poten tial Hazard Quotients for VOCs in Samples of Shaft Packing Gland Effluent ............................................................................. 137 Figure 3.2.13. Box and Dot Density Plot of Nonylphe nol Concentrations Measured in Samples of Packing Gland Effluent....................................................................................... 140 Figure 3.3.1. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Deck Washdown Water ................................................................... 157 Figure 3.3.2. Box and Dot Density Plot of Total Me tals Concentrations M easured in Samples of Deck Washdown Water ...................................................................................... 158 Figure 3.3.3. Box and Dot Density Plot of Potent ial Hazard Quotients for Dissolved Metals in Samples of Deck Washdown Water ................................................................... 159 Figure 3.3.4. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Deck Washdown Water ................................................................... 160 Figure 3.3.5. Box and Dot Density Plot of Classi cal Pollutants Measured in Samples of Deck Washdown Water................................................................................................ 165 Figure 3.3.6. Box and Dot Density Plot of Potentia l Hazard Quotients for Classical Pollutants in Samples of Deck Washdown Water ................................................................... 166 Figure 3.3.7 Box and Dot Density Plot of Pathoge n Indicator Concentrations Measured in Samples of Deck Washdown Water ................................................................... 170 Figure 3.3.8. Box and Dot Density Plot of Potent ial Hazard Quotients for Pathogens in Samples of Deck Washdown Water.................................................................................. 171 Figure 3.3.9. Box and Dot Density Plot of Nutrient Concentrations Measured in Samples of Deck Washdown Water................................................................................................ 175 Figure 3.3.10. Box and Dot Density Plot of Poten tial Hazard Quotients for Nutrients in Samples of Deck Washdown Water.................................................................................. 176 Figure 3.3.11. Box and Dot Density Plot of Nonylphe nol Concentrations Measured in Samples of Deck Washdown Water ...................................................................................... 179 Figure 3.3.12. Box and Dot Density Plot of Volatil e Organic Chemical Concentrations Measured in Samples of Deck Washdown Water ............................................................... 183 Figure 3.3.13. Box and Dot Density Plot of Poten tial Hazard Quotients for VOCs in Samples of Deck Washdown Water ...................................................................................... 184 Figure 3.4.1. Box and Dot Density Plot of Total Me tals Concentrations Me asured in Samples of Fish Hold Effluent............................................................................................... 197 Figure 3.4.2. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Fish Hold Effluent............................................................................ 198

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## Figure 3.4.3. Box and Dot Density P lot of Pote ntial Hazard Quotients for Total Metals in Samples of Fish Hold Effluent............................................................................ 199 Figure 3.4.4. Box and Dot Density Plot of Potent ial Hazard Quotients for Dissolved Metals in Samples of Fish Hold Effluent............................................................................ 200 Figure 3.4.5. Box and Dot Density Plot of Total Me tals Concentrations M easured in Samples of Fish Hold Cleaning Effluent ............................................................................... 203 Figure 3.4.6. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Fish Hold Cleaning Effluent ............................................................ 204 Figure 3.4.7. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Fish Hold Cleaning Effluent ............................................................ 205 Figure 3.4.8. Box and Dot Density Plot of Potent ial Hazard Quotients for Dissolved Metals in Samples of Fish Hold Cleaning Effluent ............................................................ 206 Figure 3.4.9. Box and Dot Density Plot of Classi cal Pollutant Concentrations/Values Measured in Samples of Fish Hold Effluent........................................................................ 212 Figure 3.4.10. Box and Dot Density Pl ot of Classical Pollutant C oncentrations/Values Measured in Samples of Fish Hold Cleaning Effluent ........................................................ 213 Figure 3.4.11. Comparison Between the BOD Se condary Treatment Limit from Sewage Treatment Facilities (30 mg/L), Averag e BOD Raw Sewage Concentrations, and BOD Concentrations from Fish Hold Effl uent and Fish Hold Cleaning Effluent ............................................................................................................... 214 Figure 3.4.12. Box and Dot Density Plot of Measur ed Pathogen Concentra tions in Samples of Fish Hold Effluent............................................................................................... 218 Figure 3.4.13. Box and Dot Density Plot of Nutrie nt Concentrations Measured in Samples of Fish Hold Effluent............................................................................................... 222 Figure 3.4.14. Box and Dot Density Plot of Nutrie nt Concentrations Measured in Samples of Fish Hold Cleaning Effluent ............................................................................... 223 Figure 3.4.15. Comparison of Concentrations of Ammonia, TKN, and Total Phosphorus in Different Fishing Vessel Platforms to thos e in the Lobster Tank (which has a live catch and continuously circulating water) .......................................................... 224 Figure 3.4.16. Box and Dot Density Plot of Nonylphe nol Concentrations Measured in Samples of Fish Hold Cleaning Effluent ............................................................................... 227 Figure 3.5.1. Box and Dot Density Plot of Pathoge n Indicator Values Measured in Samples of Graywater............................................................................................................ 237 Figure 3.5.2. Box and Dot Density Plot of Pote ntial Hazard Quotients for Pathogen Indicators Measured in Samples of Graywater.................................................................... 238 Figure 3.5.3. Box and Dot Density Plot of Classi cal Pollutant Concentrations/Values Measured in Samples of Graywater..................................................................................... 242 Figure 3.5.4. Box and Dot Density Plot of Potentia l Hazard Quotients for Classical Pollutants in Samples of Graywater......................................................................................... 243 Figure 3.5.5. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Graywater......................................................................................... 250 Figure 3.5.6. Box and Dot Density Plot of Total Me tals Concentrations M easured in Samples of Graywater............................................................................................................ 251 Figure 3.5.7. Box and Dot Density Plot of Potent ial Hazard Quotients for Dissolved Metals in Samples of Graywater......................................................................................... 252

xii

## Figure 3.5.8. Box and Dot Density P lot of Pote ntial Hazard Quotients for Total Metals in Samples of Graywater......................................................................................... 253 Figure 3.5.9. Box and Dot Density Plot of Nutrient Concentrations Measured in Samples of Graywater............................................................................................................ 256 Figure 3.5.10. Box and Dot Density Plot of Poten tial Hazard Quotients for Nutrients in Samples of Graywater ....................................................................................................... 257 Figure 3.6.1. Box and Dot Density Plot of Classica l Pollutant Values Measured in Samples of Inboard Propulsion Engine Effluent ................................................................... 268 Figure 3.6.2. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Inboard Propulsion Engine Effluent ................................................ 274 Figure 3.6.3. Box and Dot Density Plot of Total Me tals Concentrations M easured in Samples of Inboard Propulsion Engine Effluent ................................................................... 275 Figure 3.6.4. Box and Dot Density Plot of Potent ial Hazard Quotients for Dissolved Metals in Samples of Inboard Propulsion Engine Effluent ................................................ 276 Figure 3.6.5. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Inboard Propulsion Engine Effluent ................................................ 277 Figure 3.6.6. Box and Dot Density Plot of SVOC Concentrations Measured in P.L. 110-299 Study Samples of Inboard Propul sion Engine Effluent ...................................... 282 Figure 3.6.7. Box and Dot Density Plot of Pote ntial Hazard Quotients for SVOCs in P.L. 110- 299 Study Samples of Inboard Pr opulsion Engine Effluent ............................... 283 Figure 3.6.8. Box and Dot Density Plot of Volatile Organic Compounds Concentrations Measured in P.L. 110-299 Study Samples of Inboard Propulsion Engine Effluent ............................................................................................................... 288 Figure 3.6.9. Box and Dot Density Plot of Pote ntial Hazard Quotients for Volatile Organic Compounds in P.L. 110-299 Study Sample s of Inboard Propulsion Engine Effluent ............................................................................................................... 289 Figure 3.6.10. Box and Dot Density Pl ot of Classical Pollutant Values Measured in Samples of Outboard Propulsion Engine Effluent................................................................. 293 Figure 3.6.11. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Outboard Propulsion Engine Effluent.............................................. 297 Figure 3.6.12. Box and Dot Density Plot of Total Me tals Concentrations M easured in Samples of Outboard Propulsion Engine Effluent................................................................. 298 Figure 3.6.13. Box and Dot Density Plot of Poten tial Hazard Quotients for Dissolved Metals in Samples of Outboard Propulsion Engine Effluent.............................................. 299 Figure 3.6.14. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Outboard Propulsion Engine Effluent.............................................. 300 Figure 3.6.15. Box and Dot Density Plot of SVOC Concentrations Measured in Samples of Outboard Propulsion Engine Effluent................................................................. 303 Figure 3.6.16. Box and Dot Density Plot of Volatile Organic Compounds Concentrations Measured in Samples of Outboa rd Propulsion Engine Effluent......................... 306 Figure 3.6.17. Box and Dot Density Plot of Pote ntial Hazard Quotients for Volatile Organic Compounds in Samples of Outboard Propulsion Engine Effluent ..................... 307 Figure 3.6.18. Box and Dot Density Pl ot of Classical Pollutant Values Measured in Samples of Generator Engine Effluent .................................................................................. 311 Figure 3.6.19. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Generator Engine Effluent ............................................................... 314

xiii

## xiv Figure 3.6.20. Box and Dot Density Plot of Total Me tals Concentrations Me asured in Samples of Generator Engine Effluent .................................................................................. 315 Figure 3.6.21. Box and Dot Density Plot of Poten tial Hazard Quotients for Dissolved Metals in Samples of Generator Engine Effluent ............................................................... 316 Figure 3.6.22. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Generator Engine Effluent ............................................................... 317 Figure 3.6.23. Box and Dot Density Plot of SVOC Concentrations Measured in Samples of Generator Engine Effluent .................................................................................. 321 Figure 3.6.24. Box and Dot Density Plot of Poten tial Hazard Quotients for SVOCs in Samples of Generator Engine Effluent .................................................................................. 322 Figure 3.6.25. Box and Dot Density Plot of VOC Concentrations Measured in Samples of Generator Engine Effluent .................................................................................. 326 Figure 3.6.26. Box and Dot Density Plot of Poten tial Hazard Quotients for VOCs in Samples of Generator Engine Effluent .................................................................................. 327 Figure 3.7.1. Box and Dot Density Plot of Disso lved Metals Concentrations Measured in Samples of Firemain Water ................................................................................ 342 Figure 3.7.2. Box and Dot Density Plot of Total Me tals Concentrations M easured in Samples of Firemain Water ................................................................................................... 343 Figure 3.7.3. Box and Dot Density Plot of Potent ial Hazard Quotients for Dissolved Metals in Samples of Firemain Water ................................................................................ 344 Figure 3.7.4. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Firemain Water ................................................................................ 345 Figure 3.7.5. Box and Dot Density Plot of Classica l Pollutants Measured in Samples of Firemain Water................................................................................................................... 348 Figure 3.7.6. Box and Dot Density Plot of SVOC Concentrations Measured in Samples of Firemain Water ................................................................................................... 351Executive Summary



# EXECUTIVE SUMMARY

This report to Congress provides information co llected by the U.S. Environmental Protection
Agency (EPA) on the types of wastewater disc harged from commercial fishing vessels and

nonrecreational vessels less than 79 f eet in length. The report also pr ovides information on the primary
pollutant concentrations in these discharges and the likelihood of any resulting environmental impacts
based on rate, frequency, volume, and location di scharged. This study was conducted to meet the
obligations of EPA under Public Law (P.L.) 110-299 (July 31, 2008). The law provided for a
temporary two-year moratorium on National Poll utant Discharge Elimination System (NPDES)
permitting of discharges from commercial fishing ve ssels, regardless of size, and other nonrecreational
vessels less than 79 feet long that were subject to the 40 CFR 122.3(a) exclus ion. Except for ballast
water discharges (evaluated and assessed elsewhere in other Agency reports) , discharges from these
vessels are not currently covered under the EPA’s Vessel General Permit (VGP). During the two-year
moratorium, which began July 31, 2008, EPA was re quired to study the relevant discharges. EPA
believes that the results from this study will serve as an objective source of information that Congress
can use for statutory decision-making and will provide other readers valuable technical analyses of
these vessels’ incidental discharges. EPA request ed public comment on this draft report in March,
2010: this final report incor porates changes made in response to these comments.

As directed by Congress, the goal of the study wa s to obtain sufficient information to address the following six core objectives:

 A characterization of the nature, type, and co mposition of discharges for representative single vessels and for each class of vessel.

 A determination of the volumes of those di scharges, including the average volumes for representative single vessels and for each class of vessel.

 A description of the locations , including the more common lo cations, of the discharges;

 An analysis of the nature and extent of the potential effects of the discharges, including determinations of whether the discharges pos e risks to human health, welfare, or the environment, and the nature of those risks.

 A determination of the benefits to human health, welfare, and the environment from reducing, eliminating, controlling, or mitigating the discharges.

 An analysis of the extent to which the discha rges are currently subj ect to regulation under federal law or a binding international obligation of the United States.

xvExecutive Summary



## EPA designed and conducted a sampling progra m of discharges from commercial fishing
vessels and other nonrecreational vess els less than 79 feet in length to provide information to achieve the first two objectives of the st udy. As required in P.L. 110-299, the study specifically evaluated the
im pacts of any 1) discharge of effluent from properly functioning marine e ngines; 2) discharge of laundry, shower, and galley sink wast es; and 3) other discharges inci dental to these vessels’ normal operation. In addition, EPA supplemented sample co llection and analysis w ith the collection of contemporaneous information regarding the shipboard processes, equipment, materials, and operations that contribute to the discharges, as well as th e discharge rates, durati on, frequency, and location.

EPA found that commercial fishing vessels and nonrecreational vessels discharge a wide variety of effluents during their normal operation. The Agency decided to focus its evaluation on discharges from engines, bilges, fish holds, decks, and graywater activities because such discharges can release oils, heavy metals, toxic organics, o xygen-depleting substances, nutrients, and endocrinedisrupting compounds to ambient waters in quan tities that may exceed National Recommended Water Quality Criteria (NRWQC). In some circumstances, some of these vessel discharges to water bodies have the potential to impact th e aquatic environment.

Vessel Types

EPA estimates there are between 118, 000 and 140,000 vessels in the United States subject to the permitting moratorium (i.e., study vessels). 1 

## Figure ES. 1 presents the estimated number of study vessels by vessel types (service). Approximately one-half of these vessels are commercial fishing
vessels involved in activities such as fish catching (e.g., longliner, shrimper, trawler), fish processing, fishing tending, and charter fishi ng. The other half is distributed among a variety of vessel classes, including passenger vessels (e .g., water taxis, tour boats, harbor cruise ships, dive boats), utility vessels (e.g., tug/tow boats, research vessels, offs hore supply boats), and freight barges.

1 

### Based on the U.S. Coast Guard Marine Information for Safety and Law Enforcement (MISLE) database. See discussion in Chapter 1 and Appendix B of this report for detailed discussions about vessel estimates and limitations of these estimates.



## xviExecutive Summary



## xvii 4,288 49 287 67 15,012
8,876 56,407

18,660

579

- 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000CommercialFishing VesselFreight BargeFreight ShipPassengerVesselPublic Vessel,UnclassifiedTank BargeTank ShipUtility VesselUnspecified



### Vessel ServiceNumber of Vessels



### Other non-recreational 69,944

8,016
768 20,953

622 923 179 11,034 27,375 140,000 - Total number of vessels, including vessels of unspecified length 118,000 - Number of vessels with specified length less than 79 feet Vessels with unspecified length

Vessels less than 79 feet in length



## Figure ES.1. Estimated Number of Study Vessels by Vessel Service (Type)

To select specific vessel classes for sampling, EP A first developed a list of comm ercial vessel classes based on published information and industr y experience. Next, due to limited time and resources, EPA eliminated those vessel classes belie ved to consist primarily of vessels greater than 79 feet in length, with the exception of commercial fish ing vessels. Examples of vessel classes eliminated
because of their size included cable laying ships, cruise ships, large ferries, and oil and petroleum tankers. Next, EPA eliminated vessel classes that have historically been subject to NPDES permitting, including stationary seafood processing vessels and ve ssels that can be secured to the ocean floor for mineral or oil exploration. After sc reening out these vessel classes, EP A selected a subset of priority vessel classes to study, including commercial fishing boats, tug/tow boats, water taxis, tour boats,
recreational vessels used for nonrecr eational purposes, and industrial support boats less than 79 feet in length. EPA selected these vessel classes because they represent a cross section of discharges and have the potential to release a br oad range of pollutants.

EPA sampled wastewater discharges and gath ered shipboard process information from 61
vessels in nine vessel classes. Ve ssels were sampled in 15 separate cities and towns in nine states across multiple geographic regions, including New England, the Mid-At lantic, the Gulf Coast, theExecutive Summary



## Mississippi River, and Alaska. Tabl e ES.1 presents the types of ve ssels from which EPA sa mpled and gathered shipboard process information for this study. EPA sampled more commercial fishing vessels than any other vessel class due to the large numbe r of fishing vessels subject to the P.L. 110-299 permitting moratorium. EPA also sampled a few recr eational vessels used for commercial purposes (e.g, towboats) to: 1) provide a semiquantitative comp arison of the discharges from these vessels and the other study vessels, and 2) coll ect additional information for EPA’ s related Clean Boating Act (P.L. 110-288) work.

Table ES.1. Vessels Sampled by EPA

Vessel Class Number of Vessels Sampled Fishing:
Gillnetter 5
Lobster Tank 1 Longliner 3
Purse Seiner 5 Shrimp Trawler 6 Tender 3
Trawler 4
Troller 6 Tugboat 9
Water Taxi 4
Tour Boat 3 Tow/Salvage 1 

### 6 Research 1 

### 2
Fire Boat 1 Supply Boat 1
Recreational 2
Total 61 (1) Consists primarily of recreational vessels used for commercial or governmental purposes.



## Sampled Discharges

EPA sampled a total of nine discharge types from the various vessel classes listed above. These
included:

 Bilgewater

 Stern tube packing gland effluent

 Deck runoff and/or washdown

 Fish hold effluent (both refrigerated seawater e ffluent and ice slurry)

 Effluent from the cleaning of fish holds

 Graywater

 Propulsion and generator engine effluent

 Engine dewinterizing effluent

 Firemain

EPA typically sampled one to four discharge types on each vessel, depending on applicability, accessibility, and logistical considerations. Vessel di scharge samples were analyzed for a variety of

xviiiExecutive Summary



## pollutants, including classical pollutant s such as biochemi cal oxygen demand (BOD 5 

## ), total suspended solids (TSS), residual chlorine, and oil and grease; nutrients; total a nd dissolved metals; volatile and semivolatile organic compounds (VOCs and SVOCs); nonyl phenols (used as surfactants in detergents), which are endocrine-disrupting com pounds; and pathogen indicators (i.e., E. coli , enterococci, fecal coliforms).

Summary of Findings

EPA found that the sampled discharges with th e greatest potential to impact surface water quality include deck washdown, fish hold effluent, gr aywater, bilgewater, and marine engine effluent. Though these discharges may have the potential to impact surface water quality, particularly on a localized scale, a screening level model of a hypothetical large harbor indicates that most of these discharges in and of themselves would not cause ex ceedences of national water quality criteria in large water bodies (see additional discussion under envir onmental impacts below). Review of available
literature also indicates that leach ate from antifouling hull coatings used on certain vessels to prevent buildup of organisms, such as barnacles and algae, as well as underwater hu ll cleaning, likely impact surface water quality in some situations.

Deck washdown from utility vessels such as tu g/tow boats, tour boats, water taxis, and supply
boats had elevated dissolved and total metal con centrations (e.g., aluminum) likely associated with particulate metal washing off metal decks or decks with significant metal components. Certain deck washdown samples also contained pollutants such as BOD 5 

## , TSS, nonylphenols, total phosphorous, and total residual chlorine, all of which are a ssociated with detergents and disinfectants.

Fish hold effluent, which is eith er refrigerated seawater or ice slurry water found on fishing boats, had BOD 5 

## and chemical oxygen demand (COD) concentr ations that were several times higher than concentrations typically measured in raw do mestic sewage. Nutrient levels in many fish hold effluent samples were also similar to the concen trations normally found in raw domestic sewage, and ammonia nitrogen was occasionally detected at con centrations acutely toxic to aquatic life. While small fishing boats periodically discharge only a fe w hundred gallons of fish hold wastewater, large fishing vessels, such as offshore trawlers, can disc harge thousands of gallons of fish hold wastewater
in a matter of minutes.

Most fishing vessel owners also clean the fish hold tanks with a deterg ent and/or disinfectant after the fish have been off-loaded. Detergents are suspected of contai ning nonylphenols, which are endocrine-disrupting compounds. Disinfectants such as chlorine bleach contain high concentrations of total residual chlorine, which is toxic to aquatic or ganisms. The samples of fish hold cleaning effluent contained nonylphenols and total resi dual chlorine, along with the same pollutants measured in the fish
hold effluent.

Galleys, sinks, showers, and laundry facilities on board commercial vessels generate graywater, which is typically discharged overboard. Graywater volumes vary considerably depending on the class of vessel and its intended use, ve ssel size, the number of crew a nd passengers onboard, and the types of graywater-generating activities. Pollutants associ ated with the various gr aywater sources depend on

xixExecutive Summary



## a variety of factors, such as th e amount of food waste flushed into the graywater syst em, the level of soiling on clothing being washed in the onboard laundr y, and the use of showers. EPA did not sam ple graywater mixed with sewage, so the results for th is study are for graywater only. EPA’s sampling data found pathogens to be the primary po llutant of concern in graywater. The sampling data show that at least one of the pathogenic organisms (fecal coliforms, enterococci

, and E. coli ) was found in all graywater samples, and that levels of these indicators in most of these samples exceeded the water quality benchmarks, some by as much as four orders of magnitude.

Bilgewater effluent consists of the water that collects in the bottom of the vessel from sources such as precipitation and spray, fuel spills, leakin g sewage and graywater piping, condensates, and deck washing. Bilgewater contained the greate st variety (although not ne cessarily the highest concentrations) of priority pollutants, including both total and disso lved metals, VOCs, and SVOCs. It also contained pathogenic bacteria, nonylphenols, sulfid e, total phosphorous, BOD 5 

## , TSS, and residual chlorine. Both total arsenic and dissolved copper con centrations in bilgewater were consistently above the most conservative screening benchmarks (e.g., EPA’s 2006 NRWQC), and total arsenic concentrations were nearly 1,000 times the safe human health standard.

Propulsion and generation engine effluent varied de pendent upon the type of engine. EPA found that inboard propulsion engine s discharge more pollutants in th eir cooling water than outboard propulsion engines or generators. EPA also found that VOCs and SVOC s are the primary pollutants of concern found in marine engine cooling water di scharges. These pollutants (e.g., benzene and several PAHs, including some that are carcinogenic, or cancer causing) are present in fu els and are products of incomplete combustion. Dissolved copper was also m easured in most inboard engine effluents at concentrations that exceed the NRWQC. Some vessel owners in cold climates also add a solution of propylene glycol (antifreeze) to the internal cooling system of inboard engines to protect them from freezing during winter. In spring, the antifreeze soluti on may be discharged as the cooling system is refilled with ambient water. EPA’s sampling data s howed that the spent antif reeze solution discharged to surface water contained relatively high levels of metals, which are likely a result of corrosion within the engine’s cooling system.

Stern tube packing gland effluent (from tug boats) and firemain discharges (limited to just two tug boats, three tour boats, and a fi reboat) contained elevated levels of some metals (e.g., dissolved copper, total aluminum, total arsenic). For both of thes e discharges (firemain in particular), the effluent samples contained relatively small concentrations of pollutants, most of which could be attributed to the ambient surrounding water predominating the discha rge. For example, stern tube systems have a continual drip of ambient water while the shaft is turning to provide both cooling and lubrication for the system. The source of the additional metals in stern tube packing gl and effluent is likely mechanical system wear or lubricants used in the vessels’ power trains.

Although not directly sampled, EPA gathered ex isting information from the literature to characterize discharges from antif ouling hull coatings. Antifouling hull coatings are specialized paints and other coatings intended to reta rd the growth of algae; weeds; and encrusting organisms, such as barnacles and zebra mussels, on the underwater portion of vessel hulls. The coatings retard growth by

xxExecutive Summary



## continuously leaching b iocides into surrounding wate rs. The most commonly used biocide is cuprous
oxide. The biocide enters the water column through both passive leach ing and underwater hull cleaning and can accumulate in the water of poorly flus hed boat basins to levels that may harm marine life. For example, the leaching of copper from antifouling hull coatings used on recreational boats is a major source of copper pollution in several large boat basins in S outhern California. Copper from antifouling coatings has created documented water qua lity concerns in areas such as the Chesapeake Bay; Port Canaveral, Florida; and seve ral harbors in the state of Washington.

Environmental Impacts

Using the results obtained from this study, EPA modeled a large hypothetical harbor to evaluate the environmental impacts from the nine above mentioned vessel di scharge types that EPA sampled. The screening-level model indicated th at the study vessels’ disc harges would not, in themselves, exceed the aquatic lif e or human health NRWQC; however, the model did not account for background loadings. Certain polluta nts (e.g., total arsenic, dissolved copper) are more likely to contribute to a water quality criter ion being exceeded under real-world conditions in large-scale water bodies. Additionally, many pollutants pr esent in the vessel discharges were at concentrations that exceed an NRWQC at end of pipe; therefore, they have the potential to contribute to an environmental effect in the receiving water on a more localized scale. Based on the study results and literature reviews, EPA believes that total arsenic and diss olved copper represent the greatest environmental concern in vessel discharges, and that they are mo re likely than other po llutants to contribute to exceedances of water quality standards. This is esp ecially true if there ar e other sources of these pollutants (e.g., stormwater runoff) or high concentrations of vessels in confined waters, or the receiving waters already have high background concentrations.

Other notable pollutants of concer n were found in fish hold effluent from fishing vessels. These pollutants include total phosphorus , BOD, COD, reactiv e nitrogen compounds, and pathogens. These pollutants can exacerbate eutrophication in bays and es tuaries, leading to poor surface water quality.

Analysis of Applicable Regulations

This report to Congress includes EPA’s analysis of existing laws and treaties that apply to vessels and their discharges. This analysis desc ribes numerous domestic laws, including the Act to Prevent Pollution from Ships (APPS); the Clean Water Act (CWA); the Federal In secticide, Fungicide, and Rodenticide Act (FIFRA); and the Organotin Antifouling Paint Control Act (OAPC). It also summarizes key elements of several international treaties, including the Inte rnational Convention for the Prevention of Pollution from Ships (MARPOL 73/ 78), the International C onvention on the Control of Harmful Anti-Fouling Systems on Ships, the In ternational Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Ma tter (London Convention), and the International Convention on Oil Pollution, Prepar edness, Response and Cooperation (OPRC). The purpose of this analysis is to summarize these existing regulation s and international obligations and examine the extent to which these discharges ar e subject to thes e obligations.

xxiExecutive Summary



## xxii Conclusion

Some vessel discharges from commercial fishi ng vessels and commercial vessels less than 79 feet in length may have the poten tial to impact the aquatic environment and/or human health. As noted above, using the results obtained in this study, EPA modeled a large, hypothetical harbor to evaluate how the nine vessel discharge types EPA sampled may impact water quality. Based on this evaluation, EPA determined that the incidental discharges from study vessels to a rela tively large water body are not likely to solely cause an exceedance of any NRWQ C. This finding suggests that these discharges are unlikely to pose acute or chronic exceedances of the NRWQC across an entire large water body. However, since many of the pollutants present in the vessel discharges were at end-of-pipe
concentrations that exceeded an NRWQC, there is the potential for these discharges to contribute a water quality impact on a more localized scale. Th e study results indicate that total arsenic and dissolved copper are the most signi ficant water quality concerns for the study vessels as a whole, and that they are more likely than ot her pollutants to contribute to exceed ances of water quality criteria. This is especially true if there are high concentrations of vessels in confined wa ters or other sources of pollutants or the receiving water alrea dy has high background concentrations.

Like an individual house in an urban watershed, most individual vessels have only a minimal environmental impact. As in urban waters, however, the impacts caused by these vessels are potentially significant where there is high vessel concentration, low water circulation, or there are environmentally stressed water bodies. Targeted re duction of certain discharges or pollutants in discharges from these vessels in waters sensitive to the introduction of pollutants from vessels may result in important significant environmental benefits to those waters.Chapter 1 – Introduction to Report



# CHAPTER 1
I NTRODUCTION TO THE REPORT

1.1. C ONGRESSIONAL 

## S TUDY 

## C HARGE



## On July 31, 2008, Public Law (P.L.) 110-299 1 

## was signed into law. It provides a two-year
moratorium for nonrecreational vessels less than 79 f eet in length and all co mmercial fishing vessels regardless of length, from the requirements of the National Pollutant Discharge Elimination System (NPDES) 2 

## program to obtain a permit for discharges in cidental to the normal operation of those
vessels. 3 

## Additionally, P.L. 110-299 directs the United St ates Environmental Protection Agency (EPA) to study the environmental impacts of discharges in cidental to the normal ope ration of those vessels. Specifically, the law directs the agency to study and evaluate the impacts of:

(1) Any discharge of effluent from properly functioning marine engines (2) Any discharge of laundry, show er, and galley sink wastes (3) Any other discharge incidental to the normal operation of a vessel

Congress mandated that EPA include the following elements in the study:

(1) Characterizations of the na ture, type, and composition of the discharges for:

a. Representative single vessels b. Each class of vessels (2) Determinations of the volume (including aver age volumes) of those discharges for:

a. Representative single vessels b. Each class of vessels (3) A description of the locations (including the more common locations) of the discharges. (4) Analyses and findings as to the nature and exte nt of the potential effe cts of the discharges, including determinations of whet her the discharges pose a risk to human health, welfare, or the environment, and the nature of those risks. (5) Determinations of the benefits to human hea lth, welfare, and the environment from reducing, eliminating, controlling, or mitigating the discharges. (6) Analyses of the extent to which the discharges are currently subject to regulation under federal law or a binding international obligation of the United States.

1 

### P.L. 110-299, along with its companio n law for recreational vessels, P.L. 110-28 8 (“The Clean Boating Act”) are presented in Appendix C of this report.

2 

### The NPDES program requires a permit when a point source di scharges a pollutant to wate rs of the US. A NPDES permit contains conditions and limitations on the rates, concentrations, and mass of a pollutant that can be discharged to a water body. The limitations are based on available pollution control te chnologies and water quality standards that are established to protect the designated uses of a water body, such as fishing or swimming.

3 

### Although this report focuses on the discharges from vessels subject to the moratorium, th e Agency became aware during interaction with congressional staff that some members may be interested in additional information on discharges incidental to the normal operation of a larger universe of vessels—in particular, vessels currently subject to the NPDES General Permit for Discharges Incidental to the Normal Operation of a Vessel (“Vess el General Permit”). Therefore, EPA has included some additional information and analysis regarding those vessels where possible.



## 1Chapter 1 – Introduction to Report



## The law expr essly excludes certain discharges from the scope of the study: discharges from vessels owned and operated by the Armed Forces; 4 

## discharges of sewage 5 

## from vessels, other than the discharge of graywater from vessels operating on th e Great Lakes; and discha rges of ballast water.

EPA conducted the study required by P.L. 110-299 a nd is publishing this report to present its findings. Due to the accelerated timeframe required to complete the study, EPA designed this analysis to be accomplished quickly with existing resources. Limitations in the study design are discussed in Chapter 2 of this report. Due to these factors, EPA focused its sampling efforts on the vessels that P.L. 110-299 specifically exempted. EPA henceforth refers to these vessels and vessel types as study vessels. EPA sampled discharges from a few other vessel types, including commercial vessels that were manufactured primarily for pleasure, wh ere resources and logistics allowed.



## 1.2. O RGANIZATION OF THIS REPORT



## The report is organized into seven chapters. In Chapter 1, EPA describes the universe of vessels with discharges subject to the study, the types of di scharges generally thought to originate from those vessels, and the types of pollutants or other constituents generally f ound in those vessel discharges. In Chapter 2, EPA discusses the methods for sampling, the types of vessels sampled, the Quality Assurance and Quality Control (QA/QC) measures taken in the course of sampling, and the limitations of this study. Chapter 3 is the most technical portion of the report, presenting the results from EPA’s sampling and other information gathered from literature revi ews about the vessel discharges. Chapter 4 presents the results of EPA’s screening-leve l model, which was designed to l ook at the large-scale, cumulative impacts of these vessel discharges on large harbor or estuarine system s in order to provide an initial evaluation of the threat the discharges pose to these ecosystems. Chapter 5 discusses the results and identifies those key areas where EPA found discharges most likely to be a concern to human health, welfare, or the environment. Chapter 6 provides a summary of federal law and binding international obligations to which discharges with in the scope of the study are potential ly subject. To a certain extent, Chapter 6 also discusses discharges described in the study that might be beyond the scope of the permitting moratorium in some circumstances. Chapter 7 lists report references.



## 1.3. C LASSES OR 

## T YPES OF 

## V ESSELS



## The study required by P.L. 110-299 could potentially include numerous classes or types of vessels that vary greatly in size . The smallest vessels include recr eational boats used for commercial purposes, which can be less than 20 feet in length. Th e largest vessels, such as super oil tankers, can be more than 1,200 feet in length. Characteristics of these vessels, includi ng construction material, designed purpose, onboard activitie s, crewing requirements, engine type and power, and days in

4 

### The Clean Water Act defines “vessel of the Armed Forces” as an y vessel owned or operated by the Department of Defense, other than a time or voyage chartered vessel; and any vessel owned or operated by the Department of Transportation that is equivalent to one owned by the Department of Defense. 33 U.S.C. § 1322(a)(14).

5 

### “Sewage” is defined as “human body wastes and the wastes from toilets and other r eceptacles intended to receive or retain body wastes except that, with respect to commercial vessels on the Great Lakes, such term shall include graywater.” 33 U.S.C. § 1322(a) (6).



## 2Chapter 1 – Introduction to Report



## 3 operation vary widely. Consequently, the types and vol umes of discharges generated by these different classes or types of vessels also vary to a great extent.

EPA identified many classes or types of nonrecreational vessels in the development of the 2008 Vessel General Permit (VGP). Examples include tank sh ips that transport large volumes of bulk liquids, container ships that transport cont ainerized cargo, barges that tran sport bulk goods, and large cruise vessels that transport hundreds or thousands of passengers. In the VGP, EPA defines a “Cruise Ship” as a passenger ship that is used commercially for pl easure cruises and provides overnight accommodations to passengers. In a separate study, EPA prepared an extensive cruise ship di scharge assessment report characterizing five different discharge types from these vessels. 6



## The moratorium of P.L. 110-299 applies to discha rges from nonrecreation al vessels less than 79 feet in length and all commercial fishing vessels. For some vessel classes or types, such as barges or cruise ships, the majority of that class or type are vessels longer than 79 feet. For other classes or types, such as container ships or oil tanke rs, all the vessels would be expect ed to be longer than 79 feet. EPA
did not include such vessel classe s in this study, as resources did not allow for representative sampling of the larger vessels to provide an assessment of the discharges from those classes and still adequately sample and assess the vessels sp ecifically exempted by P.L. 110- 299. In this study, EPA focused on sampling discharges from the most prevalent classe s or types of vessels defined by the moratorium parameters, but sampled other vessels if the opport unity presented itself. The following subsections briefly describe key characteristics of some of the vessels considered for sampling in the study, but this list is not intended to be comprehensive.

1.3.1. Commercial Fishing Vessels

As defined in P.L. 110-299, commercial fishing vesse ls are vessels that co mmercially engage in the catching, taking, or harvesting of fish or an activ ity that can reasonably be expected to result in the catching, taking, or harvesting of fi sh. Commercial fishing vessels in clude any vessels harvesting fish, crab, lobster, shrimp, or other aquatic organisms for commercial sale. Commercial fishing vessels may employ various methods of collection in cluding nets, trawls, traps, or hoo k-and-line to capture the target species.

The commercial fishing industry is highly diverse, spanning a wide array of ocean and nearshore conditions, differing by both region and fishery. For example, the State of Alaska alone manages 68 fisheries, and there are over three hundred combin ations of species, gear, and regions. Approximately half of the nearly 10,000 Alaska State permitted ve ssels are endorsed for onl y one fishery; vessels working multiple distinct fisheries can be set up in a totally different manner depending on the target species (United Fishermen of Al aska, 2010 and Alaska Trollers A ssociation, 2010). Types of fishing vessels include, but are not limited to:

6 

### This report is available at: www.epa.gov/owow/ocea ns/cruise_ships/pdf/0812cruiseshipdischargeassess.pdf.Chapter 1 – Introduction to Report



## Purse Seiner: Purse seiners catch fish that school cl ose to the surface, such as salmon, herring, and sardines, by encircling them with a long net and drawing (pursing) the bottom closed to capture the fish. The net is retrieved using a winch. When most of the net has b een retrieved, with the remainder laying in a “bag” alongside the vessel, the fish are di pped from the bag and into the vessel’s hold. Seinecaught fish are delivered whole. Pu rse seiners are limited by Alaska la w to 58 feet to more precisely manage their fishing effort (Alaska Department of Fish and Game, 2007).

Purse Seiner Fishing Vessel.

Troller: Troll vessels catch fish such as salmon a nd tuna by “trolling” bait or lures on lines through feeding concentrations of fi sh. Trolling vessels come in a vari ety of sizes and configurations, ranging from small, hand-trolling skiffs to large, ocean-going power trolling vessels of 50 feet or more in length (Alaska Department of Fish and Game, 2007). Hand trollers fish fe wer lines and bring fish aboard with hand operated gurdies or rod and reel; power trollers use hydraulic gurdies to land their catch. Fish caught in the troll fish ery are landed one at a time. Most troll-caught fish are immediately gilled, gutted, and iced; some are la nded in the round and held in slus h ice; and a small component is frozen at sea. In Alaska, the troll fishery occurs n early year-round; however, the va st majority of fish are delivered between July 1 and September 30 (Alaska Trollers Association, 2010).

4Chapter 1 – Introduction to Report



## Troller Fishing Vessel.

Crabber/Lobster: Crabbers and lobster boats target crabs (Dungeness, King, Tanner, and Blue) and lobsters using twine or wire-meshed steel pots (t raps). A line extends from each pot to a surface buoy that marks its location; a power winch is used to re trieve the pots. Baited pots are left to “soak” for up to several days before retrieval. Once onboa rd, the pots are opened and sorted with legal crabs/lobsters retained in aerated seawater tanks. Crabs/lobsters are de livered live to shore stations and retail outlets. Crab and lobs ter boats come in a variety of shapes and sizes, from aluminum skiffs with outboard motors that fish the inside waters, to seagoing vessels 100 or mo re feet in length that fish the Bering Sea and the Gulf of Alaska for King Crab (Alaska Department of Fish and Game, 2007).

Gillnetter: Gillnetters catch a variet y of fish, such as salmon, herring, and chum, by setting curtain-like nets perpendicular to the direction in wh ich the fish are traveling as they migrate along the coast toward their natal streams. Nets can be set in place, such as at or near the mouths of rivers, or allowed to drift freely in deep wate r. Mesh openings are just large e nough to allow the male fish, which are usually larger, to get their head s suck in the mesh. Gillnet vessels are usually 30 to 40 feet long and are easily recognized by the drum on either the bow or the stern on which the net is rolled. Net retrieval is by hydraulic power which turns the drum. Fish are removed from the net by hand as the net is reeled aboard. Gillnet-caught fish are usually iced for de livery (Alaska Department of Fish and Game, 2007).

5Chapter 1 – Introduction to Report



## Gillnetter F ishing Vessel.

Traw ler : Trawlers, also occasionally called draggers , typically catch large quantities of midwater species, such as pollock or pink shrimp, a nd bottom-fish, such as flounder, by towing a large, cone-shaped net. The net is retrie ved using winches and rolled onto a drum. The end of the net (“bag”) holds the fish and is pulled onto the back of the ve ssel via a slanted stern ram p. Fish such as flounder may be processed onboard into fillets or minced. Shrimp are sorted by size and species and frozen either whole or headed. Trawlers range in size from sma ll shrimp trawlers to large 600-foot ocean pollock trawlers that possess onboard processing facilities (Alaska De partment of Fish and Game, 2007).

Trawler Fishing Vessel.

6Chapter 1 – Introduction to Report



## Longliner: Longliners c atch fish (primarily halib ut, black cod, swordfish, and tuna) via a longline that is either laid on the bottom or suspende d in the water column. Each longline can be up to a mile in length and have thousands of baited hooks. A longline vessel typically sets several lines for a 24- hour “soak.” The lines are retrieved over a side roller with a power winch, and the caught fish are packed in ice in the vessel’s hold and are deliver ed whole and bled, whole and gutted, or headed and gutted dressed (Alaska Department of Fish and Ga me, 2007). Longliners range in size from 18-foot open skiffs to 80-foot schooners (Alask a Longline Fishermen’s Association, 2010).

Longliner Fishing Vessel.

Fishing Dredge: A fishing dredge, also known as a scall op dredge or oyster dredge, is a device that is towed along the bottom of the sea by a fishing vessel to collect scallops, oysters, clams, crabs, and even in some cases, sea cucumbers. The dredge is winched up into the vessel and emptied onto the deck. Dredge boats used to collect clams, oysters, a nd crabs in near-shore estu arine waters range from 24 to 50 feet long. Large off-shore dredges used to collect sea scallops can be as long as 190 feet.

Fish Tender: A fish tender vessel supports fishing vessels by providing supplies and storing, refrigerating, or transporting fish, fish products, or other materials.

7Chapter 1 – Introduction to Report



## Tender Vessel.

1.3.2. Tugs/Towing Vessels

Tugboats and towboats serve many functions and in clude vessels that operate solely in river systems to ocean-going vessels. Tugboats can be utilized to push or tow barges and rafts. Tugboats often assist larger vessels in docking ma neuvers in harbors and are generally powerful relative to their size. Although tugboats and towboats can be over 200 feet in lengt h, many are in the 40- to 100-foot range.

8Chapter 1 – Introduction to Report



## Tugboat/Push Boat.

1.3.3. Water Taxis/Small Ferries

Water taxis and small ferries (or water busses) are vessels employed to provide public transport of people from one location to another. Small ferries are vessels for hire that are designed to carry passengers and/or vehicles between two ports, usually in inland, coastal, or near-shore waters. Many of
these vessels can be found in the coastal harbors of New York, Baltimore, Boston, San Diego, Seattle,
and others. The sizes of the vessels in this cl ass vary and can surpass 100 feet in length.

1.3.4. Tour Boats

This vessel class encompasses a variety of vessels used for activities su ch as dinner cruises, ecotourism, whale watching excursions , and sightseeing trips. Vessels in this class can range from small private vessels with just a few passengers to large vessels carrying 50 or more passengers. Large tour boats designed for extended excursions can includ e galley facilities, overn ight accommodations, and laundry.

9Chapter 1 – Introduction to Report



## A Tour Boat (left) and a Water Taxi (right).

1.3.5. Recreational Vessels Used for Non-Recreational Purposes

This class includes vessels manufactured as recrea tional vessels that are used for nonrecreational purposes, such as law enforcement vessels, fire/rescu e vessels, towing and salv age vessels (not to be confused with towboats above), and research vessel s. This vessel class encompasses a broad range of vessel types and sizes. Under the Clean Boati ng Act of 2008 (P.L. 110-288), vessels that are manufactured or used primarily for pleasure are “recreational vessels ” subject to regulation under that

Act.

Recreational Vessel Modified fo r Towing/ Salvage.

10Chapter 1 – Introduction to Report



## 1.4. V ESSEL 

## P OPULATION



## As discussed in Section 1.1, P.L. 110-299 requi res EPA to characterize discharges for representative single vessels and for each class of ve ssel in terms of its nature; type and composition; average volume; location; nature and extent of the potential effects; and benefits of reducing, eliminating, controlling, or mitigating the discharg es. EPA focused its atte ntion on the commercial fishing vessels and other nonrecreationa l vessels less than 79 feet in le ngth covered by the moratorium. Understanding the characteristics of discharges from all commercial fishing vessels and nonrecreational vessels less than 79 feet in length re quires considering these vessels in term of their number, vessel type, onboard equipment, type of service, and area of op eration. A brief overview of the analysis on vessel type and size is presented in th is section. A more complete analys is, including a discussion regarding vessel location (which impacts the lo cation of vessel discharges) and other vessel characteristics, is presented in Appendix B of this report.

1.4.1. Vessel Characteristics Data

In evaluating and describing the vessel population, EPA primarily relied on data gathered by the U.S. Coast Guard. The primary data source used in the vessel population analys is is the U.S. Coast Guard’s Marine Information for Safety and Law Enforcement (MISLE) database (USCG, 2009). MISLE provides a wide range of information regarding vesse l and facility characteristics, accidents, marine pollution incidents, and other pertinent information tracked by the U.S. Coast Guard. Where possible, EPA complemented the data available in MISLE with information obtained from published sources or
from consultations with U.S. Coast Guard personnel or port authorities.

MISLE includes data for nearly 1 million vessels that operate in U.S. waters. The database covers a wide ensemble of vessels (e.g., recreational vessels, commercial fishing vessels, freight barges, tank barges, tank ships, passenger vessels, utility ve ssels), and provides data on various characteristics
for each individual vessel. These data include:

 Identification number(s)

 Vessel category (e.g., class, type, subtype, service)

 Size (e.g., tonnage, length, breadth, depth)

 Area of operation (e.g., hail ing port, route type)

 Passenger and crew capacity

 Propulsion (i.e., method, engi ne type, and horsepower)

 Construction material and design (e.g., hull materi al, design type, hull configuration/shape)

 Year built or age

In compiling MISLE data, the U.S. Coast Guard largely relies on documents submitted by vessel owners or operators in accordance with vessel documentation requireme nts (e.g., certificate of documentation) or on information gathered by U.S. Coast Guard staff directly (e.g., during inspections, vessel boardings, or accident investig ations). While the database scope is not limited to a certain size or class of vessel, the scope of the data included in MISLE is driven in part by the regulatory requirements to which different types of vesse ls are subject or by activities conducted by Coast Guard offices.

11Chapter 1 – Introduction to Report



## MISLE, therefore, is generally most com prehens ive for those vessels that are documented, state registered, and/or subject to inspection requirements.

While MISLE represents the most comprehensive national dataset currently available, it does not capture the entire universe of vesse ls operated on U.S. waters. As discussed at greater length in Appendix B, only limited information is available fo r certain classes of vess els, such as smaller recreational vessels, due to the way in which vessel data are gathere d. Most recreational vessels are not subject to documentation or re gular inspection requirements and thus are not captured in MISLE. 7 

## The MISLE data set currently contains approxima tely 700,000 recreational vessels, approximately 36 percent of which are documented vess els; the other recreational vessels are present in MISLE because of other U.S. Coast Guard activities, such as boa rdings, nonmandatory inspections (e.g., voluntary inspection program), or in cident investigations. 8 

## Shortcomings of the database mostly regard small
recreational vessels. Since recreatio nal vessels are covered separately under the Clean Boating Act of 2008 (P.L. 110-288) and are therefore not the primary focus of this report, EPA believes that data limitations do not preclude the use of the MISLE data for the current analysis to generally describe the characteristics of study vessels.

Additionally, while MISLE captures a wide range of characteristics for each vessel, the information is at times incomplete (e.g., length may be missing or recorded as zero) or may be outdated (e.g., a vessel may no longer be operating while it s status in the database remains “active”). Consequently, the information provided by the database should be seen as approximate and as indicative of the general characteristics of different populations or classes of vessels that operate in U.S. waters.

1.4.2. Overview of Vessel Universe

Information is provided in MISLE for a total of 993,863 vessels. Based on information recorded in the database, 976,649 of these vessels are presum ed currently operational, of which 918,469 vessels are identified as U.S.-flagged vesse ls (referred to as “domestic” ve ssels in the remainder of the section). 9

, 10 

## Nearly 80 percent of the 918,469 operational domestic vessels reco rded in MISLE are recreational vessels (722,522 vessels), while 7.6 percent are identified as commercial fishing vessels. The remainder of the MISLE universe is composed of other types of nonrecreational vessels (10.5 percent) such as freight and tank barges and ships, passenger vessels, and utility vessels, and vessels of unspecified service (3 percent). Figur e 1.1. presents the MISLE population of operational,
domestic vessels for all vessel se rvice categories, excludi ng recreational vessels. While the P.L. 110-299

7 

### While the number of recreational vessels recorded in MISLE is high (over 700,000), the database accounts for only a small fraction of the 16.9 million recr eational vessels estimated to operate in U.S. waters, according to EPA’s Economic Impact Analysis of the Recreational Vessel Permit (USEPA, 2008a) and to the National Marine Manufacturers Association’s (NMMA’s) 2007 U.S. Recreational Boat Registration Statistics (NMMA, 2009).

8 

### Personal communication with U.S. Coast Guard Re presentative, LCDR Scott Muller, on May 15, 2009.

9 

### Approximately 355,000 vessels do not provide a vessel status and 5,000 have an "unknown" status. Following guidance from a Coast Guard representative ( Source: Personal email communication with Haro ld Krevait of the U.S. Coast Guard. March 13, 2009), EPA assumed that thes e vessels are currently operational.

10 

### This count is based on the flag of th e vessel. However, the MISLE database re cords a U.S. hailing port for some vessels that are foreign flagged. Additionally, approximately 57,000 ve ssel records do not identify the vessel flag. EPA assumed that these are domestic vessels.



## 12Chapter 1 – Introduction to Report



## moratorium will gene rally apply to discharges from the vessel service categories shown in the figure, many of the vessels presented in Figure 1.1. are not subject to the P.L. 110-299 permitting moratorium since the law is limited to commercial fishing ve ssels (regardless of size) and other nonrecreational vessels 79 feet or less. Approximate ly one-third of the operational, domestic, nonrecreati onal vessels are commercial fishing vessels. The next largest ve ssel service category is freight barges, with approximately 24 percent of vessels; however, many of these barges may exceed the 79-foot length
restriction.

Freight Barge 46,129
24%

Tank Ship
528
0%

Utility Vessel 16,338
8% Other 96,637
49%

Tank Barge 7,813
4% Passenger Vessel 22,851
12% Freight Ship 1,655
1% Unspecified 29,366
15%

Commercial Fishing Vessel 69,944
35% Public Vessel, Unclassified 1,323
1%

Source: U. S. Coast Guard, MISLE database, 2009.

Note; The chart includes all commercial fishing vessels record ed in MISLE (69,944) and all 96,637 other non-recreational vessel s, regardless of length

. 

## Figure 1.1. MISLE Population of Operational, Domestic Non-R ecreational Vessels by Vessel Service 11 , 12



## Table 1.1 further characterizes the vessel population in term s of length greater than or equal to or
less than 79 feet within each vessel service category. As show n in both Table 1.1 and Figure 1.1., the vast majority of vessels containe d in MISLE are less than 79 feet in length. For example, nearly 77 percent of commercial fishi ng vessels (54,176 vessels out of 69,944) recorded in MISLE have a

11 

### This figure does not include the 722,522 recreational vessels included in the MISLE population of operational, domestic vessels.

12 

### Approximately 74,000 vessels have a vessel service indicated as "unclassified", "unknown", or "unspecified" in MISLE. In approximately 44,000 of those instances, EPA was able to assign a vessel service for the purpose of this analysis based on information provided in other data fields (i.e., using ve ssel class, vessel type, or vessel subtype information).



## 13Chapter 1 – Introduction to Report



## length less than 79 feet. 13 

## Vessels less than 79 feet also are a vast majority (94 percent) of the recreational vessels. Only the othe r nonrecreational vessel service category counts a majority of vessels 79 feet or longer.

Table 1.1. Population of Operational, Domestic MISLE Vessels by Vessel Length

Recreational Commercial Fishing Other Non-Recreational Unspecified Greater than or Equal to 79 ft 2,256 2,231 (2) (3) 

### 54,142 1,991 Less than 79 ft 676,915 54,176 32,799 15,011 Zero or Null (1) 

### 43,351 13,537 9,696 12,364 Total 722,522 69,944 96,637 29,366 Source: U. S. Coast Guard, MISLE database, 2009
(1) 

### MISLE indicates a length of zero or the vessel length field is blank.
(2) 

### A separate estimate provided by U.S. Coast Guard personnel suggests that commercial fishing vessels 79 feet long or greater number approximately 1,800 to 1,900 vessels. 14

(3) 

### Columns with yellow background represent study vessels.



## Recreational vessels are generally excluded from many parts of our analysis because a separate act (the Clean Boating Act of 2008 (P.L. 110-288)) exempts discharges incidental to the normal operation of these vessels from NPDES permitting requirements. The Clean Boating Act defines
recreational vessels as those that ar e either 1) manufactured or used primarily for pleasure or 2) leased, rented, or chartered to a person for the pleasure of that person. Furtherm ore, vessels that are subject to U.S. Coast Guard inspection and that are either engaged in commercial use or that carry paying passengers are not considered recreational vessels unde r the Clean Boating Act. This definition does not necessarily correspond to the service categories us ed in MISLE to identify recreational versus nonrecreational vessels because MISLE categories are base d on the type of service the vessel is used for rather than original manufacture purpose. There ar e additional instances in which MISLE may differ from Clean Boating Act definitions, making the distinct ion between vessels listed in the database that are within and outside the scope of this study not always clear. For ex ample, certain vessels that would appear to fall under the Clean Boat ing Act definition of recreational vessels because they are described as uninspected vessels carrying fewer than 6 passengers are classified as “passenger vessels” in MISLE; however, MISLE does not provide furt her specifications on whether the vessels ar e leased, rented or chartered to a person or whether th ey carry paying passengers. A second example would include charter fishing vessels. Often, these vessels are manufactured or used primarily for pleas ure, or leased, rented, or chartered to a person for the pleasure of that pe rson. Many are not inspected by the US Coast Guard. Charter fishing vessels which are not inspected are exempted from NPDES permitting requirements by the Clean Boating Act (P.L. 110-288). Other charte r fishing vessels are inspected by the US Coast Guard. These inspected, non-recrea tional vessels are not exempted from NPDES by the Clean Boating Act, and are study vessels only if they are less than 79 feet. Since EPA is unable to determine whether certain charter fishing vessels are st udy vessels or Clean Boating Act vessels based on the information in MISLE, all charter fishing vessels listed in MIS LE are included in the following estimates of study
vessels.

13 

### According to a U.S. Coast Guard represen tative, the overall fraction of commercial fi shing vessels that are less than 79 feet in length is estimated to be approximately 95 percent (Perso nal communication with Jack Kemerer, Fishing Vessel Safety Program, May 26, 2009).

14 

### Personal communication with Jack Kemerer, Fi shing Vessel Safety Program, May 26, 2009.



## 14Chapter 1 – Introduction to Report



## 1.4.2.1. Study Vessel Type

Once commercial, non-fi shing vessels longer than 79 feet are removed from the analysis, the relative makeup of the study vessels changes. EPA estimates there are between 118,000 and 140,000 vessels in the United States subject to th e permitting moratorium established by P.L. 110-299. 15


## Figure 1.2. presents the estimated distribution of vessels wi thin the study vessel population by vessel service (type). Approximately one-half of these vessels are commercial fishing vessels involved in such
activities as fish catchin g (e.g., longliner, shrimper, and trawler), fish processing, fishing tenders, and charter fishing. The other one-half are distributed am ong a variety of vessel cla sses, including passenger vessels (e.g., water taxis, tour boats , harbor cruise ships, dive boats) , utility vessels (e.g., tug/tow boats, research vessels, offshore supply boats), and freight barges.

15 

### The range accounts for the exclusion and inclusion, respectively, of other non-recreational vessels for which MISLE does not record the length or for which the recorded length is zero.



## 15Chapter 1 – Introduction to Report

4,288 49 287 67 15,012
8,876 56,407

18,660

579

- 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000CommercialFishing VesselFreight BargeFreight ShipPassengerVesselPublic Vessel,UnclassifiedTank BargeTank ShipUtility VesselUnspecified

Vessel ServiceNumber of Vessels Vesels with unspecified length Vessels less than 79 feet in length

Other non-recreational 69,944

8,016 768 20,953

622 923 179 11,034 27,375 140,000 - Total number of vessels, including vessels of unspecified length 118,000 - Number of vessels with specified length less than 79 feet

Note: The figure is based on operational, U.S.-flagged commercial fish ing vessels (regardless of length) and other nonrecreatio nal vessels less than 79 feet in length.

Commercial fishing ve ssels also include fish processing vessels and fishing vessels . Passenger vessels include passenger (inspected ), passenger (uninspected), passenger barge (ins pected), passenger barge (uninspected), and passenger ships . Public vessel, unclassified includes military and other public service vessels. EPA notes that military vessels ar e specifically excluded in P.L. 110-299. Utility vessels
include towing vessels (i.e., tugs), school ships, research vessels/ships, mobile offshor e drilling units, offshor e vessels, offshore s upply vessels, oil recovery vessels, and industrial vessels. EPA notes that not all of all the vessels re presented in this table are subject to the moratorium at all times (e.g., small mobile offshore drilling uni ts when engaged in industrial activity are required to have pe rmits). Freight barges include general barges

, dry cargo barges

, container barges

, flat deck barges , and unspecified vessel types that operate in freight barge service. Tank barges include bulk liquid (cargo) barges, bulk liquefied gas barges, and unspecified vessel types that operate in tank barge service. Some vessel service categorie s did not fall into one of the listed categories. Therefore, based on the other cla ssification fields (class, type, subtype), EPA determined an appropriate service category.
Source: U. S. Coast Guar d, MISLE database, 2009



## Figure 1.2. Number of Study Vessels Recorded in MISLE, by Vessel Service (Type)

Commercial Fishing Vessels



## As shown in Figure 1.2., approximately 70,000 comme rcial fishing vessels represent the largest category of study vessels. Based on this informati on, EPA sampled more commercial fishing vessels
than other nonrecreational vessels less than 79 feet in length (see di scussion in Section 2.2.1). According to the vessel service categories used by the U.S. Co ast Guard in MISLE, “commercial fishing vessels”

16Chapter 1 – Introduction to Report



## are vessels involved in such activ ities as fish catching (e.g., long liner, shrimper, trawler), fish processing, and charter fi shing. 16


## The U.S. Coast Guard generally describes comme rcial fishing vessels as including fishing vessels, fish tender vessels, and fi sh processing vessels as follows:

 Fish processing vessel 17 

## means a vessel that commercially prepares fish or fish products other than by gutting, decapit ating, gilling, skinning, shucki ng, icing, freezing, or brine chilling.

 Fish tender vessel means a vessel that commer cially supplies, stores, refrigerates, or transports fish, fish products, or materials direct ly related to fishing or the preparation of fish to and from a fishing, fish pro cessing, or fish tender vessel or a fish processing facility.

 Fishing vessel means a vessel that commerc ially engages in the catching, taking, or harvesting of fish or an activity that can reas onably be expected to result in the catching, taking, or harvesting of fish.

While there is some overlap in service use for commercial fishing vessels and other vessel categories, such as passenger vessels (e.g., charter fishing), EPA assumed that the categorization used in MISLE generally follows the U.S. Coast Guar d definition of commer cial fishing vessels. 18



## Other Nonrecreational Vessels

Excluding the approximately 27,000 “unspecifi ed” vessels shown in Figure 1.2., “passenger vessels” have the second highest number of study vessels with approximately 21,000 vessels (approximately 19,000 of these vessels have a length r ecorded as 79 feet or le ss). These vessels are further divided into subtypes according to the types of activities in which they are involved (e.g., diving vessels, charter fishing vessels, ferry, harbor cruise vessels, sailing vessels). Approximately 7,833 vessels are categorized as inspected under 46 CFR (7,753 under part T (small passenger vessels under 100 gross tons), 69 vessels under part K (small passenger vessels carrying more than 150 passengers or with overnight accommodations for more than 49 passengers), and 11 vessels under part H (passenger vessels 100 or more gross tons) 19 

## ). The remaining 13,120 vessels are recorded as uninspected passenger vessels. 20

16 

### Several charter fishing vessels are categorized as “commercial fishing vessels” in MISLE even though they are generally not considered commercial fishing vessels by the U.S. Coast Guard Fishing Vessel Safety Program. That program considers these vessels to be passenger vessels (Source: Personal communi cation with Jack Kemerer, Fishing Vessel Safety Program, May 26, 2009). According to the Coast Guard definition, the key difference between vessels formally classified as commercial fishing vessels and recreational vessels or passenger vessels that may be used in fishing activities is whether the catch is sold.

17 

### The moratorium provided by P.L. 110-299 applies only to discharges incidental to the normal operation of a vessel when operating in a capacity as a means of tran sportation. EPA requires NPDES permits for seafood processing vessel discharges when they are engaged in the processing of seafood (an industrial activity).

18 

### The MISLE classification also depends on the information provided directly by the vessel owner or operator on the application for documentation or renewal ( Source: Personal communication with Jack Kemerer, Fishing Vessel Safety Program, May 26, 2009).

19 

### This last category appears to contain vessels potentially misclassified since their indicated gross tonnage is less than 100 gross tons.
20 

### The definition of passenger vessels used in MISLE is broader than vessels subject to inspection under 46 CFR parts T, K, and H. Therefore, depending on how thes e vessels are operated (e.g., whether they carry paying passengers only or leased,



## 17Chapter 1 – Introduction to Report



## 18 The service category labeled “public vessel, unc lassified” accounts for up to 600 study vessels (e.g., lighthouse tender vessels, hospital ships, law enforcement vessels, ice breakers). The “utility vessels” category covers remaining types of vessels, including tug/tow boats, school ships, research vessels/ships, mobile offshore drilling units, offs hore vessels, offshore supply vessels, oil recovery vessels, and industrial vessels. As many as 11,000 vessels are classified as u tility vessels in MISLE. 21


## Freight barges (4,288 to 8,016 vessels ), freight ships (579 to 768 ve ssels), tank barges (67 to 622 vessels), and tank ships (49 to 179 vessels) account for the rema ining nonrecreational study vessels. 22



### rented or are chartered to a person for the pleasure of that person), they could fall under the Clean Boating Act definition of recreational vessels and would therefore be outside the scope of the permitting moratorium.

21 

### Some vessel service categories did not fall into one of the listed categories. EPA determ ined an appropriate service category based on information provided in other vessel classification fields (class, type, subtype).

22 

### For each range, the minimum value represen ts the number of vessels for which the length is non null or zero and is less than 79 feet while the maximum value represents the total numbe r of vessels when including vessels for which the length is unspecified or zero.Chapter 1 – Introduction to Report



## 1.4.2.2. Vessel Size

Vessels can be characterized by size according to two metrics: length and gross tons. The two metrics are related to each other (g ross tonnage is a function of the sh ip’s enclosed spaces as measured to the outside of the hull framing) , and Figure 1.3 presents a scatter pl ot of gross tons and lengths for commercial fishing vessels and othe r nonrecreational vessels obtained fr om MISLE. In general, most
nonrecreational vessels in MISLE have a length ranging between 26 and 50 feet, which translates into a tonnage generally below 50 gross tons. The 79-foot length threshold for other nonrecreational vessels (the criterion for applicability of P.L. 110-299 moratorium) corresponds ro ughly to a tonnage of 150 gross tons. In Chapter 6 of this report, EPA uses th is information in determining whether certain vessels may be subject to regulation under fe deral law or a binding internationa l obligation of the United States.

Note: This chart is based on all operational, U.S.-flagged commercial fishing vessel s and other nonrecreational vessels, regard less of length.

Source: U. S. Coast Guar d, MISLE database, 2009


## Figure 1.3. Relationship Between Vessel Gross Tons and Length

19Chapter 1 – Introduction to Report



## Approxima tely half of vessels documented in MISLE fall with in the 26- to 50-foot-length category, they have an average vessel length of 41 feet. Figure 1.4 and Fi gure 1.5 illustrate the distribution of vessel length for co mmercial fishing vessels and other nonrecreational vesse ls in terms of the vessel count (Figure 1.4) and cumulative distribution (Figure 1.5). In analyzing the cumulative distribution of vessels by length (F igure 1.5), tank ships are the only vess el service categor y with a large percentage of vessels longer than 300 feet. 23 

## Several other vessel service categories have a significant fraction of vessels above the 79 feet threshold. Step s in the cumulative distri bution (Figure 1.5) indicate common lengths for certain categories of vessels: fr eight barges are generall y around 200 feet in length, while tank barges tend to be 200 feet or 300 feet in length. For almost all other vessel service categories (commercial fishing vessels, passenge r vessels, utility vessels and unspecified vessels), vessels less than 79 feet represent the majority of vessels within the overall population.

0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,00015406590115140165190215240265290

Vessel Length (feet)Number of Vessels Commercial Fishing Vessel Freight Barge Utility Vessel Freight Ship

UNSPECIFIED Tank Ship Tank Barge
Public Vessel, Unclassified Passenger Vessel

79 feet

Note: This figure is based on operationa l, U.S.-flagged commercial fishing vessels and all other nonrecreational vessels (no si ze exclusion).

Source: U.S. Coast Guard, MISLE database, 2009


## Figure 1.4. Distribution of MISLE Vessels by Length and Vessel Service (Type)

23 

### Although a large percentage of tank ships are listed as greater than 300 feet long, this accounts for a very small number of vessels when compared to the overall universe of vessels in the selected service categories; approximately 300 of the 391 tank ships that list a vessel length are longer than 300 feet.



## 20Chapter 1 – Introduction to Report

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%15406590115140165190215240265290315340365390415440465490

Vessel Length (feet)Cumulative Fraction Commercial Fishing Vessel Freight Barge Utility Vessel Freight Ship

UNSPECIFIED Tank Ship Tank Barge
Public Vessel, Unclassified Passenger Vessel

79 feet500 +

Note: This figure is based on operationa l, U.S.-flagged commercial fishing vessels and all other nonrecreational vessels (no si ze exclusion).

Source: U. S. Coast Guar d, MISLE database, 2009


## Figure 1.5. Cumulative Distribution of MISLE Ve ssels by Length and Vessel Service (Type)

As shown in the two previous figures, there is significant variability in vessel length across categories of nonrecreational vessels. Most freight ba rges reported in MISLE are about 200 feet in length and relatively few (10 perc ent) are under 79 feet in length. 24 

## Hence, most freight barges are not subject to the moratorium in P.L. 110-299 and are cu rrently eligible for cove rage under the VGP. In contrast, the majority of utility vessels (e.g., towi ng vessels), passenger vessels, and commercial fishing vessels overall are less than 79 feet in length. Figure 1.6 shows the distribution of all commercial fishing vessels and only nonrecreational ve ssels less than 79 feet in length by length and vessel service (focusing on the study vessels). The majority of commercial fish ing vessels are relatively small compared to other nonrecreational vessels such as barges or utility vesse ls, with 70 percent of commercial fishing vessels for which the length is sp ecified in MISLE in the 26- to 50-foot range. The length of other nonrecreational vessels varies among the subcategories, with as many as 66 percent of

24 

### Freight barges less than 79 feet in length include a wide rang e of vessels used for freight ba rge service, as classified in MISLE. These include, for example, barges operated by oil sp ill response companies or by dred ging companies to transfer recovered oil or dredged material.



## 21Chapter 1 – Introduction to Report



## passenger vessels in the 26- to 50-fo ot range, compared to less than 1 percent of freight barges within
that same range (most freight barges less than 79 f eet in length fall in the 50- to 79-feet range).

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Less than 26 5,631 52 31 1,489 9 36 2 713 5,598

26-50 39,262 214 289 13,496 41 126 23 3,966 8,129

50-79 9,283 4,021 258 3,674 16 124 23 4,196 1,284

79 or more 2,231 Commercial Fishing Vessel Freight Barge Freight Ship Passenger
Vessel Public Vessel, Unclassified Tank Barge Tank Ship Utility Vessel Unspecified

NOT INCLUDED IN SELECTED POPULATION

Note: This figure is based on operati onal, U.S.-flagged comme rcial fishing vessels and other nonrecreational vessels less than 79 feet in length.

The length field is not reported or provides a va lue of zero for approximately 36,000 vessels.

Source: U. S. Coast Guar d, MISLE database, 2009


## Figure 1.6. Distribution of Study Vessels by Length (in Fee t) and Vessel Service (Type)

Figure 1.7 presents the distribution of study vessels by gross tons and vessel service. Overall, nearly 77 percent of study vessels are less than 50 gross tons, while the remaining vesse ls generally fall within the 50- to 300-gross-tons range. Very few vesse ls (less than 1 percent) within the selected vessel population are greater than 300 gross tons. Note that some vessel serv ice categories appear underrepresented because the gross tons field is blank or is listed as zero in MISLE for approximately 56,000 vessels.

22Chapter 1 – Introduction to Report

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Less than 50 36,650 337 409 15,190 35 161 36 4,398 7,474

50-100 4,599 148 119 1,751 5 75 5 2,469 489

100-300 4,048 3,734 26 59 3 24 4 1,356 159

300-500 148 7 1 2 1 4 7

500-1000 158 10 1 4 1 2

1,000 or more 133 1 5 9 2 10 Commercial Fishing Vessel Freight Barge Freight Ship Passenger
Vessel Public Vessel, Unclassified Tank Barge Tank Ship Utility Vessel Unspecified Figure insert: Distribution of Study Vessels by Gross Tons and Vessel Service; for Size Categories representing 10 Percent or Less of Vessels

0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10%

Commercial

Fishing Vessel Freight Barge Freight Ship Passenger
Vessel Public Vessel, Unclassified Tank Barge Tank Ship Utility Vessel Unspecified

Note: This chart is based on operational, U.S.-flagged commercial fish ing vessels and other nonrecr eational vessels less than 7 9 feet in length.

The gross tons field is not reported or provides a value of zero for approximately 56,000 vessels.

Source: U. S. Coast Guar d, MISLE database, 2009


## Figure 1.7. Distribution of Study Ve ssels by Gross Tons and Vesse l Service (for which gross ton data are given in MSLE)

To select specific vessel classes for sampling, EP A first developed a list of commercial vessel classes based on published information and industry experience. Next, EPA eliminated those vessel
classes believed to consist of ve ssels greater than 79 f eet in length, with the exception of commercial fishing vessels. Examples of vesse l classes eliminated because of th eir size include cable laying ships, cruise ships, large ferries, and oil and petroleu m tankers. Next, EPA eliminated vessel classes not subject to VGP permitting, including stationary seafood processing vessels and vessels that can be secured to the ocean floor for mineral or oil expl oration (the CWA regulations separately require NPDES permits for industrial operations onboard vessels ). After screening out th ese vessel classes, EPA selected a subset of priority vessel classes to study, including commercial fishing boats, tug and tow boats, water taxis, tour boats, recreational vessels used for nonr ecreational purposes , and industrial

23Chapter 1 – Introduction to Report



## support boats less than 79 feet in length. EPA select ed these vessel classes beca use they provide a cross section of discharges and a broa d range of potential pollutants.

1.4.2.3. Additional Vessel Charac teri stic Information

Other vessel characteristics such as vessel ag e and engine power (horsepower ahead) likely
influence the characteristics and the volume of many vessel discharges . Intuitively, where a vessel is located and operated can determine the impacts. Add itionally, where there are mo re vessels, there is a greater likelihood of cumulative impacts (e.g., where there are more vessels, there will be a greater impact from vessel discharges).

Appendix B presents additional vessel characteris tic information, including summaries of vessel subtypes, the hailing port of domestically flag ged vessels, and information on construction and propulsion of these vessels, including the vessel age and horsepower ahead. Appendix B also discusses limitations in using the MISLE data. Appendix B lists the most common subtypes of vessel within each vessel type. For example, towing ve ssels are the most common type of utility vessel. Appendix B also
shows where concentrations of vessel activities occu r and what vessels are most predominant in those assemblages. For example, the hailing port of New Orleans has the most registered vessels, including significant numbers of commercial fishing vessels and other nonrecr eational vessels. Finally, Appendix B shows that most study vessels are relatively old, with the majority of them being more than 25 years old. These analyses helped EPA qualitatively and quantitatively analyze the cumulative impact of many vessels’ discharges (see Chapter 4 of this report), a nd to put the numbers and locations of study vessels into perspective rela tive to other vessels, such as recreational vessels and other non-study vessels (e.g., nonrecreational, noncommercia l vessels greater than 79 feet in length).



## 1.5. D ISCHARGES FROM 

## V ESSELS



## EPA developed a substantial list of discharges from vessels and pollutants of concern in each of those discharges during the development and issuan ce process of the VGP in 2008. Starting with this list, EPA developed a subset of discharges preval ent on fishing vessels and nonrecreational vessels less than 79 feet in length that are exp ected to have pollutants of concern. The subset of discharges that EPA selected included: bilgewater, deck washdown and r unoff, propulsion engine effluent, generator engine effluent, firemain systems, fish hol d effluent, fish hold cleaning effl uent, graywater, and shaft packing gland effluent. While EPA did not sample antifouling hull-coating leachate, this discharge is discussed as well because this is a significant discharge fr om many vessels and has b een documented to cause water quality impacts (see Section 3.2.8).

EPA recognizes that there are additional discharges 25 

## that also sometimes are present on study vessels. Some of these were not conducive to samp ling, such as cathodic prot ection, underwater ship husbandry, and oil-to-sea in terfaces. Some discharges are generally combined with other discharges and

25 

### EPA lists many discharges and descriptions of those discharges in the VGP and the accompanying fact sheet. Due to the timeframe and resource limitations of this study, EPA chose to focus on the nine discharges that were a) conducive to sampling and b) most likely to cause or contribute to impacts to human health, welfare, or the environment.



## 24Chapter 1 – Introduction to Report



## are not typically available for i ndependent sampling. An example of this is refrigeration system condensate that is drained to the bilge. Other disc harges are not expected to be commonly generated on commercial fishing vessels or nonre creational vessels less than 79 feet in length. These discharges are typically associated with larger vessels, such as those covered by the VGP, and were not sampled for in this study due to resource limitations. Some exampl es include aqueous film-forming foam, distillation and reverse osmosis brine, exhaust gas scrubber effl uent, elevator pit effluent, and boiler/economizer blowdown. A detailed discussion on the discharges EPA decided not to sample is provided in Chapter 2.

1.5.1. Bilgewater

Bilgewater is defined as the water that collects in the bottom of a vesse l’s hull. This includes water from rough seas, rain, minor leaks (designed or accidental) in the hull or stuffing box, condensate from various types of equipment, spills onboard the ve ssel, and leaks from pumps and seals. Bilgewater can be found on almost every vessel; if too much wate r accumulates, it could threaten the safety and stability of the vessel. For example, the U.S. Coas t Guard requires that ce rtain commercial fishing vessels and fish-processing vessels have automated bilg e pumping systems as part of their basic safety features (46 CFR Part 28.255).

A number of oily and non-oily wastewater sources sometimes drain intentionally or unintentionally into the bilge. Oily wastewater sources include oil, fuel, and antifreeze leaks from engine and machinery operation and maintenance. To prevent floating oils typically found in bilgewater from being discharged overboard, vessels can either use oi l-adsorbent pads in the bilge compartment or pump the bilgewater through a properly oper ating oil-water separation system or oil absorbent filter prior to overboard discharge.

Non-oily wastewater sources in clude non-oily leaks from engi ne and machinery operation and
maintenance and various condensates. Vessels ca n have numerous sources of non-oily machinery wastewater, including chilled wate r condensate drains, fresh- and sa ltwater pump drains, potable water tank overflows, and leaks from propulsi on shaft seals. Large vessels typi cally have separate systems to collect non-oily machinery wastewater in dedicated dr ip pans, funnels, and deck drains for subsequent direct discharge. Small vessels can also genera te non-oily machinery wa stewater; however, these wastewaters likely drain into the bilge.

1.5.2. Deck Washdown and Deck Runoff

Deck wa shdowns are typically performed to prevent slip and fall hazards; to prevent dirt, grit, or other materials from harming the integrity of the deck surface; or to clean the deck after pulling in a catch or unloading cargo. Deck was hdown is typically performed using hoses and mops that move the deck washdown water and cleaning agen ts (if any) to the scuppers thr ough which the water is discharged overboard. Deck cleaning often occu rs while the vessel is underway but is also performed pierside, generally after loading or unloading catch or cargo.

Deck runoff is typically related to either precipitation or surf ace water spray that lands on the deck and flows to the scuppers where it is discharg ed overboard. Operators of the vessel do not have

25Chapter 1 – Introduction to Report



## Deck Washd own Activity of a Wat er Taxi (left) and a Towing and Salvage Vessel (right). control over the volume of discharge related to precipitation events or sea sprays, but they can minimize the pollutants carried by the runoff by util izing appropriate maintenance practices.

Deck washdown and deck runoff have the potential to contain a variety of pollutants, including oil and grease, nutrients, solids, meta ls, detergents, and solvents. Some orall of these pollutants could be introduced to the deck from shipboard activities, stor age of material on the deck, maintenance activities, and the decking material itself.

1.5.3. Engine Effluent

Engines found on commercial vessels are typi cally used for two purposes: propulsion and electricity generation. Engines used for vessel propulsion can be either outboard or inboard engines. Outboard engines are self-contained units designed to be mounted outsi de the vessel hull at the stern (rear) of the vessel. Inboard engine s are enclosed within the hull of the vessel, usually connected to a propulsion screw by a drive shaft. Outboard engines are typically fueled by gasoline, while inboard motors can use either gasoline or diesel fuel. Gasolin e or diesel engines can be either two stroke, which require small amounts of oil to be mixed with the fu el to create a mixture that both lubricates and provides combustion, or four stroke, whic h have separate lubrication systems.

All com bustion engines require cooling systems to remove excess heat. Direct-cooled marine engines draw raw water (either freshw ater or seawater in which the vess el is floating) into the engine and rely on the raw water to absorb the heat directly from the engine. Biocides sometimes are added to the raw water to prevent biofouling of the heat excha nge system (biofouling prev ention). Indirect-cooled marine engines use an enclosed cooling system that requires circulation of a freshwater-coolant solution through the engine to absorb heat . The coolant solution passes thr ough a closed heat exchanger where
the raw water absorbs the heat from the c oolant solution and is then discharged.

Vessels also use keel-cooling systems for indirect ly cooling marine engine s. A keel cooler is essentially a heat exchanger mounted outside the vessel's hull beneath th e waterline. Hot water from the

26Chapter 1 – Introduction to Report



## ma rine engines is pumped through the keel cooler, whic h is in constant contact with the seawater. This closed-circuit cooling system elimin ates the need for an inboard heat exchanger, raw water pumps, and strainers and does not result in a discharge.

Some engines also use water to cool and quiet their exhaust, referred to as boat engine wet exhaust. These engines inject spent cooling water from the engine into the exhaust stream, which results in some of the gaseous and solid components of th e exhaust being entrained into the cooling water discharge.

Vessels that require significant li ghting or have electrical equipment, such as appliances and/or electric motors, are likely equipped with engines used for electricity generation. Electrical generators on these vessels are typically powered by diesel engines. The size of the electrical generators depends on the electrical load requirements for the vessel, but could range from small ge nerators used to power navigation equipment and galley applia nces to large generators used to power electric motors on deck winches and cranes. Similar to vessel engines, elec trical generators will requi re direct or indirect cooling.

Collecting a Sample of Engine Effluent at Full Speed.

27Chapter 1 – Introduction to Report



## Inboard Engine (left) and Outboard Engine (right)

1.5.4. Firemain Systems

Some vessels are equipped with firemain system s to supply water for firefighting and to supply water to other vessel systems. Vessels use either “w et type” or “dry type” firemain systems. The wet type firemain piping is normally filled with water. Wet type systems are particularly used on vessels where the firemain water is used frequently, t ypically for maintenance activities such as deck washdown. In a dry type system, the piping is norma lly empty. Water is only introduced to the pipes when actual firefighting takes place, or for testing or training.

Aqueous film-forming foam (AFFF) can also be used on vessels as a fire suppression agent.
AFFFs are a combination of fluorochemical surfactan ts, hydrocarbon surfactants, and solvents (Koetter, 2008) that are injected into the wa ter stream of a fire hose. These film-forming agents are capable of forming water solution films on the surface of fla mmable liquids, separating the fuel from the air (oxygen). Systems that use AFFFs do not appear to be common on smaller vessels.

Firemain System on a Fire Boat.

28Chapter 1 – Introduction to Report



## Fire Boat.

1.5.5. Fish Hold and Fish Hold Cleaning Effluent (Refrig erated Seawater Discharge or Fish Ice Slurry Discharge)

Commercial fishing vessels util ize different methods to keep seafood fresh after it is caught.
Most seafood is either dead when brought onboard or is killed shortly th ereafter, before being stored in a refrigerated seawater holding tank, with the exception of certain she llfish (e.g., crab, lobster), which must be kept alive. The two most common methods of cooling seawater are by mechanical refrigeration or by adding ice. Mechanical re frigeration is common on tenders, pur se seiners, and trawlers, while chipped and slurry ice tanks are mo re common on trollers, longliners, gillnetters, and some trawlers.

For vessels with refrigerated seawater tanks, fish are typically extracted using a vacuum system that removes both the fish and refrigerated seawat er simultaneously. Any excess refrigerated seawater that is not required to assi st in fish extraction is pu mped overboard pierside. Ve ssels that use chipped or slurry ice generally remove the seafood and then discharge the spent i ce overboard pier side. Occasionally, vessels that store thei r catch in ice slurry also use v acuum filtration systems (e.g., some shrimping boats in the Gulf of Mexico). These di scharges often contain pollutants generated by the catch, such as biological wastes.

Tanks u sed to keep lobster and crab catch aliv e pump surrounding water into the tank constantly to maintain the highest water quality possible. The flow rate through these systems results in a nearly continuous discharge of fish hold effluent. Because the majority of the seafood product remains alive, however, there is little biological decay or degradation in the tank. Furthermore, because these tanks have reasonably rapid flushing times and a continuous discharge, there is a little accumulation of pollutants.

Fish holds are also often clean ed or disinfected by vessel crew s between catches. To rinse the tank, vessel crews use either munici pal water from the pier or dock or they pump water from the surrounding ambient water. Cleaning ma y simply involve rinsing the tanks with this water, or crews

29Chapter 1 – Introduction to Report



## Shoveling Fish Hold Ice Overboard From Ice T ank. sometimes add detergents or disinfectants. Crews al so often use scrub brushes to clean the walls and
floor of the fish hold to maximize the removal of or ganic material. Fish hold cleaning effluent is a
combination of residual fish hold water and ambient or municipal water and often contains soaps or detergents.

View of a Full Refrigerated Seaw ater Tank.

30Chapter 1 – Introduction to Report



## 1.5.6. Graywater

Graywater is generated onboard vessels from do mestic activities such as dish washing, food preparation, laundry, and bathing. Graywater is discha rged through either a si ngle discharge port from a collection system or through multiple , separate discharge ports for each graywater source (e.g., sink, shower, washing machine). Graywater discharge is intermittent and occurs only when the specific activity is performed. Most graywater processe s use onboard potable water (service water).

Smaller vessels can sometimes not generate any gr aywater. Many of these vessels are for day use and do not provide any overnight quarters or heads (toilets). Smaller vessels that do generate graywater (e.g., those that have accommodati ons, sinks, or showers) generall y discharge graywater directly overboard via ports typically located above the waterline. Most larger vessels used for overnight or multiday travel have numerous graywater sources, including showers, bathr oom and kitchen sinks, and laundry. On these vessels, graywate r discharges overboard by drai ning through gravity to either a discharge port above the water line or to a small collection tank locat ed in the vessel hull, where it is immediately pumped to a discharge port above the waterline. Other ve ssels can collect their graywater and treat it along with sewage in Marine Sanitation Devices (MSDs).

Collecting Graywater (Show er) Effluent. Typica l pollutants found in gr aywater often include me tals, pathogens, total suspended solids, biochemical oxygen demand, chemical oxygen demand, oil, grease, ammonia, nitrogen

, 

## and phosphates. Graywater does not include sewage, or “blackwater”, which is exclusively human waste from toilets and urinals. Sewage is regulated under Section 312 of the Clean Water Act and 40 CFR Part 140 (see Chapter 6 of this report for further discussion).

1.5.7. Shaft Packing Gland Effluent

For vessels with propeller shaf ts, a packing gland, or stuffing box, is used to provide a seal around a propeller shaft at the po int where it exits a boat's hull unde rwater. This is a common method for preventing water from entering the hull while still allowing the propeller shaft to turn. In a conventional packing gland, the seal itself is provided by packing rings made of greased flax that is

31Chapter 1 – Introduction to Report



## 32 packed or wound tightly around the propeller shaft a nd compressed in place with a threaded nut and spacer. The gland can also be fitted with an opening for periodic insertion of grease between the rings, and sometimes includes a small grease reservoir.

A packing gland packed with flax rings is de signed to leak a small amount of water—a few drops per minute—to provide lubrication when the sh aft is turning. Water that leaks through the seal sometimes drips into a non segregated bilge or collect s in a segregated area to avoid contact with oily wastewaters. In the case of a segr egated area, the water that collects (referred to as shaft packing gland effluent) is automatically pumped overboard when levels reach a preset depth to prevent overflow.

1.5.8. Antifouling Hull Coatings 26



## Vessel hulls are often coated w ith antifouling compounds to prohibit the attachment and growth of aquatic life. Coatings are formulated for di fferent conditions and purposes, and many contain biocides. Those that contain biocides prevent th e attachment of aquatic organisms to the hull by continuously leaching substances into the surroundi ng water that are toxic to aquatic life. While a variety of different biocides are used, the most co mmonly used is copper. Hull cleaning activities often can cause additional releases of biocides, particular ly if hulls are cleaned within the first 90 days following application of the antifouling coating.

A second metal-based biocide is organotin-bas ed, typically tributyltin (TBT), which was historically applied to vessel hulls. TBT and other organotins cause deformities in aquatic life, including defects that disrupt or prevent re production. TBT and other organotins are also stable and persistent, resisting natural degradation in wate r bodies. As discussed in Chapter 6 of this report, the use of TBTs and other organotins as biocides has been phased out on all vessels by domestic law and international
treaty.



## 1.6. P OLLUTANTS 

## P OTENTIALLY 

## F OUND IN 

## V ESSEL 

## D ISCHARGES



### EPA dev eloped groupings of pollutants of concern in the issuance process of the VGP in 2008. 

## EPA recognizes that while some discharges from all sizes of vessels are essentially the same, many will vary due to the specific machinery and activities conduc ted on these vessels. EPA used slightly different groupings of the pollutants from the discharges sample d for this report to address differences from the discharges covered by the VGP. The pollutants and constituents of concern are broken down into the following groups: classical pollutants, nutrients, pathogen indicators, metals, volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs), and nonylphenols. Not all pollutants are expected to be found in each discharge. For each disc harge, EPA attempted to identify which pollutant groups are of concern.

26 

### Though antifoulant hull coatings are pres ent on some study vessels, particularly th ose operating in areas where there is a significant potential for fouling, it was not feasible to sample discharges from these coatings for this study (see Chapter 2 f or further discussion).Chapter 1 – Introduction to Report



## 1.6.1. Classical Pollutants

For p urposes of this report, EPA uses the te rm “classical pollutants” for the following 14 pollutants: temperature; conductivity ; salinity; turbidity; dissolved oxyge n; total suspended solids (TSS); biochemical oxygen demand (BOD); chemical oxygen demand (COD); total organic carbon (TOC); oil and grease; pH; sulfide; and total residual chlo rine (TRC). These include the CWA conventional pollutants plus other common polluta nts that are of general concern in a wide variety of contexts.

Temperature changes can directly affect aquatic organisms by altering their metabolism, ability to survive, and ability to repr oduce effectively. Increases in temperature are frequently linked to acceleration in the biodegradation of organic material in a water body, which increases the demand for dissolved oxygen and can stress local aquatic communities. Thermal impacts from vessel discharges are generally much smaller than those from traditiona l point sources, and the ve ssel discharge with the greatest potential to alter receiving wate r temperature is engine cooling water.

Conductivity and salinity measurements are rela ted to ionic strength and can indicate what specific ions are present in water or wastewater. Conductivity is a measur e of the ability of water to pass an electrical current. Conductivity in water is affected by the presence of inorganic dissolved solids (or ions). Organic compounds like oil, phenol, alcohol, and sugar do not conduct electrical current very well and therefore have a low conductivity when in water. Conductivity is also aff ected by temperature; the warmer the water, the higher the conductivity. Salinity is a measure of the mass of dissolved salts (ions) in solution. Ions commonly found in water include calcium, magnesium, potassium, and sodium cations and bicarbonate, carbonate, chloride, nitrate, and sulfate anions. The average ocean salinity is approximately 35 parts per thousand (ppt), while freshwater salinity is generally less than 0.5 ppt. The salinity of brackish water, such as estuaries, is between 0.5 ppt and 17 ppt. Conductivity is a good measure of salinity in water and vice versa.

Both tu rbidity and TSS are assessments of the amount of suspended solid s present in the water column. Turbidity is an indicator of water clarity, measuring how much the material suspended in water decreases the passage of light thr ough the water. Higher turbidity incr eases water temperatures because suspended particles absorb more heat. Suspended mate rials, also measured as the mass of TSS, can clog fish gills, reducing resistance to disease in fish, lo wering growth rates, and affecting egg and larval development. As the particles sett le, they can smother fish eggs a nd benthic macroinvertebrates on the bottom substrate. Vessel discharges with relatively high turbidity and TSS concentrations include fish hold effluent, bilgewater, gr aywater, and deck washdown.

The oxygen content of water or wastewater is m easured in its dissolved form as dissolved oxygen (DO). Low DO levels (hypoxia) can impair an imal growth or reproduction, and the complete lack of oxygen (anoxia) will kill aqua tic organisms. Organic material found in vessel discharges (e.g., fish waste, bilgewater, graywater) that are easily bi odegraded will result in depressed DO concentrations in ambient receiving waters. The ability of the organi c material in vessel discharges to biodegrade and depress oxygen levels is measured as either BOD or COD. BOD me asures the amount of oxygen used by naturally occurring microorganisms to metabolize the organic material in the vessel discharge, while COD measures the oxygen needed to chemically oxidize the organic materi al in the vessel discharge. If

33Chapter 1 – Introduction to Report



## there is a large quantity of organic wa ste in water, there will also be a lot of bacteria present working to decompose this waste. In this case, the demand for oxyge n will be high (due to all the bacteria), so the BOD level will be high. COD levels can often be corr elated with BOD levels, though they are generally higher because the measurement exam ines chemicals that are both biol ogically and chemically oxidized. As the waste is consumed or dispersed through the water, BOD levels will begin to decline

.

Oil and grease are other known components of vessel discharges with potentially harmful impacts to humans and to aquatic life. Oil and greas e are measured using hexane extractable material (HEM) and silica gel treated (SGT)-HEM. Vessels some times discharge oil, including lubricating oils, hydraulic oils, and vegetable or organic oils, in everyday operation. Oils pr oduce a visible slick or
sheen 27 

## on the water surface, which decreases natu ral oxygen transfer, resu lting in depressed DO concentrations. Also, oils might contain heavy meta ls and SVOCs, which can bioaccumulate in fish, birds, marine mammals, and ultimately humans. Bilgew ater, fish hold effluent (f ish oils), and graywater (galley wastewater) are the vessel discharges most likely to contain oil and grease.

The term pH is used to indicate the alkalinity or acidity of a substance as ranked on a scale from 1.0 to 14.0. Substances with lower pH (i.e., less than 7) are acidic, while substanc es with higher pH (i.e., greater than 7) are basic. pH a ffects many chemical and biological pr ocesses in the water. The largest variety of aquatic animals prefer s a range of 6.5 to 8.0. pH outside this range can reduce diversity because it stresses the physiological systems of most organisms. Low pH can allow toxic elements and compounds to become mobile and “available” for upt ake by aquatic plants and animals. This can produce conditions that are toxic to aquatic life, particularly sens itive species. Many vessel-cleaning wastewaters can be either acidic (e .g., metal cleaners and t ub, toilet, and sink clea ners) or basic (e.g., degreasers).

Sulfide is a strong reducing agen t typically generated during anaer obic decomposition of organic materials. Sulfides are naturally present in groundw ater as a result of leac hing from sulfur-containing mineral deposits. Surface water does not usually cont ain high sulfide concentrations. Sulfide is a pollutant that is commonly elevated in water dist ribution systems as well as sewers. Sulfur-reducing bacteria, which use sulfur as an energy source, are believed to be the primary producers of large quantities of hydrogen sulfide. Ecologically, these b acteria are common in anaerobic environments (e.g., plumbing systems). For vessels, possible sources of sulfide include trace constituents in the fuel, products of incomplete combustion, or formations in anaerobic systems onboard the vessel. Sulfide generated from anaerobic decomposition is suspected in graywater, bilgewater, and fish holds. Sulfide may also be formed during fuel combustion in a ve ssel’s engine. Sulfide, typically found as hydrogen sulfide, poses a potential long-term hazard to aq uatic life (USEPA, 1986b) at low concentrations.

Chlorine is commonly used as a disinfectant in wastewater and drinking water. Chlorine, measured as TRC, though toxic to humans at high con centrations, is of much gr eater concern to aquatic species, which can experience respiratory problems, hemorrhaging, and acute mortality. TRC is present in potable water supplies, and cons equently, any vessel systems that us e potable water c ould potentially

27 Visible slick or sheen means a “silvery” or “metallic” sheen, gloss, or increased reflectivity; visual color; iridescence, or o il slick on the surface (58 FR 12507 )

.



## 34Chapter 1 – Introduction to Report



## discharge TRC while conducting graywater activities a nd deck washing. Chlorine bleach can also used as a disinfectant in cleaning act ivities, such as cleaning the fi sh hold, general vessel cleaning, and laundry.

Measuring Total Residu al Chlorine Immediately After Sample is Taken.

1.6.2. Nutrients

Nutrients, including nitrogen, phosphorus, and nume rous micronutrients, are constituents of vessel discharges. Though traditionally associated with discharges from sewage treatment facilities and runoff from agricultural and urban stormwater sources, small quantitie s of nutrients from vessels are discharged from deck runoff, graywater, bilgew ater, and fish hold tanks, among other sources. Although outside the scope of this report, se wage discharge (blackwater) is like ly one of the primary sources of
nutrients from vessels.

When excessive amounts of phosphorus and nitrogen are added to the water, algae and aquatic plants can be produced in large qu antities and cause eutroph ication of lakes or ponds. Eutrophication is a natural process whereby primary producers (algae and aquatic plants) exhibit extreme growth due to increased nutrient loading. Eutrophi cation can be greatly accelerated by human activities that increase
the rate at which nutrients enter the water. Increased nutrient discha rges from human sources are a major source of water quality degradation throughout the United States.

Total nitrogen is a measure of all the various forms of nitrogen (nitrate , nitrite, and ammonia) that are found in a water sample. N itrification is the biological oxi dation of nitrogen compounds in both water and soil: ammonia is oxidized to nitrite (via N itrosomas bacteria) and further oxidized to nitrate
via Nitrobacter bacteria. Nitrite and ammonia are relatively toxic forms of nitrogen, while nitrate is relatively nontoxic. Nitrogen in natural waters is usually found in the form of nitrate.

Phosph orus can be measured in either the partic ulate phase or the dissolved phase. Particulate matter includes living and dead plankton, prec ipitates of phosphorus, phosphorus adsorbed to particulates, and amorphous phosphorus. The diss olved phase includes inorganic phosphorus and

35Chapter 1 – Introduction to Report



## organic phosphorus. Phosphorus in natural waters is usually found in the form of phosphates. Phosphates can be in inorganic fo rm (including orthophosphates and polyphosphates) or organic form (organically bound phosphates).

1.6.3. Pathogen Indicators

Pathogens are microbes that cause disease. They include a few types of bacteria, viruses, protozoa, and other organisms. Bact eria associated with human and an imal waste (e.g., total and fecal coliforms, E. coli, enterococci) are often monitored in water a nd wastewater, and the detection of these organisms can be a reliable indicator that other da ngerous pathogens might be present. Pathogens are often found in discharges from vessels, partic ularly in vessel sewage and graywater.

1.6.4. Metals

Metals are a diverse group of pollutants, many of which are toxic to aquatic life and humans. While some metals, including copper, nickel, and zinc , are known to be essential to organism function, many others, including thallium and arsenic, are nonessential and/or are known to have only adverse impacts. Even essential metals can do serious dama ge to organism function in sufficiently elevated concentrations. Adverse impacts can include impaired organ func tion, impaired reproduction, birth defects, and at extreme concentrations, acute mort ality. For example, copper can inhibit photosynthesis in plants and interfere with enzyme function in both plants and animals in concentrations as low as 4

μ g/l. Additionally, through a process known as bio accumulation, metals can accumulate in predator organisms further up the food chain, includ ing commercially harvested fish species.

The toxic potential of a metal depends on its bioa vailability in a given aquatic environment. A metal’s bioavailability is determined by the ch aracteristics of the surrounding environment (e.g., temperature, pH, salinity, TOC) and the species of the affected organism. The environmental conditions determine a metal’s tendency to either adsorb to suspended organic matter and clay minerals or to precipitate out of solution and settle to the sedime nts. Benthic organisms can bioaccumulate metals by consuming metal-enriched sediments and suspended particles or by uptaking ambient water containing
the dissolved form of the metal.

Vessel discharges can contain a variety of metal constituents, which can come from a variety of onboard sources. Graywater, bilgewater, and firemain systems have been shown to contain numerous metals, the exact constituents of which vary depe nding on onboard activities and the materials used in
the construction of the vessel. Ot her metals, such as copper, are known to leach from the antifoulant coatings on vessel hulls and can cause ex ceedances of water quality standards.

1.6.5. Volatile and Semivolat ile Organic Compounds

A variety of organic compounds have been found in vessel discharges, many of which are known to have a broad array of adverse impacts on aqua tic species and human health. For this study, EPA measured VOCs and SVOCs, which can dissolve ot her substances and eva porate readily at room temperature and atmospheric pressure. These carb on-containing compounds in clude a wide range of

36Chapter 1 – Introduction to Report



## chemicals, such as aldehydes, ketones, and hydro carbons, and are present in oily m aterials such as gasoline, motor oil, engine coolan ts, and lubricants used on vessels. VOCs such as benzene, which is found in fuel, have acute hematological toxici ty (ATSDR, 2007) and many SVOCs such as benzo(a)pyrene are persistent, bio accumulative, and toxic compounds.

EPA measured VOCs and SVOCs in vessel discharg es from engines, bilges, and firemains for this study. The most significant rate s and levels of detection were phthalates (plasticizers added to plastics to make them flexible) a nd components of or products of inco mplete combustion of oil and fuel. For example, VOCs and SVOCs detected in engine effluent included multiple polycyclic aromatic hydrocarbons (PAHs), straight-chain hydrocarbons, phenol and methyl phenols, trimethylbenzene, phthalates, and the volatile constituents of fuel, commonly referred to as “BTEX” (benzene, toluene, ethylbenzene, xylene). Many of these compounds are known to cause adverse im pacts on aquatic species
and human health.

1.6.6. Nonylphenols

The general term nonylphenols in this report represen ts two distinct subsets of the broader family of alkylphenols that are commonly us ed in many products such as liquid detergents and soaps. They can degrade to total nonylphenol, or NP, which is toxi c to aquatic life. There are different types of alkylphenols, such as nonylphenol polyethoxylates (NPEOs) and octylphenol polyethoxylates (OPEOs). Because NPEOs and OPEOs are in the same family, th ey have similar chemical properties. These two distinct subsets of alkylphenols ( nonylphenols and the closely related octylphenols) exis t in these and other commercial products as mixtures of isomers (pol yethoxylates) of different length chains. Different isomers are distinguished by lengt h of the branched alkyl side chain. The longer chain nonylphenol polyethoxylates (of which there are 18 isomers dis tinguished by number, e.g., NP18EO) and octylphenol polyethoxylates (of which there are 12 isomers, e.g., OP12EO) eventually will degrade in the
environment to isomers with shorter chained etho xylate groups and ultimatel y, total nonylphenol (NP), which, as discussed above, is toxic to aquatic lif e. In general, the hydrophobicity, persistence, and toxicity of the substance all increa se as the ethoxylate chain becomes shorter. The short-chained isomers may be quite persistent once they are buried in the sediment, and bottom-feeding fish can be significantly exposed to these pe rsistent and toxic compounds. L ong- and short-chain NPEOs and OPEOs are expected to be found in several vessel discharges, incl uding graywater, deck washing wastewater, and bilgewater.



## 1.7. C HAPTER 

## C ONCLUSIONS



## The inf ormation summarized and referenced in this chapter provides an introduction to the study vessel universe. It describes the universe of study vessels , the types of discharg es generally thought to originate from those vessels, and the types of pollutants or other constituents generally found in those vessel discharges. It also references information contained in Appendix B of this report, which provides more detailed information on the study vessel universe , such as vessel locations and characteristics. EPA estimates that there are between 118,000 and 140,000 vesse ls in the United States subject to the NPDES permitting moratorium established by P.L. 110-299. This chapter concludes that commercial fishing

37Chapter 1 – Introduction to Report



## 38 vessels are the most common type of study vessels, although there ar e significant numbers of other commercial study vessels.

The information contained in this chapter helped inform EPA’s decisions of which discharges to sample and the relative importance of each discharge (see Chapters 3, 4, and 5 for additional discussion). Based on EPA’s experience gained during the VGP process, the Agency believes bilgewater, graywater, deck was hdown, fish hold, engine effluent, a nd antifouling hull coating leachate are the primary vessel discharges th at could impact surface water qualit y. Pollutants in these discharges might include metals, organics, nonylphenols, nutr ients, oxygen depleting compounds, and pathogens. The following chapters of this repor t present the methodology EPA used to characterize discharges from vessels subject to the NPDES permitting moratorium , the results of that characterization, and the potential environmental impacts to ambient wate rs that could be caused by these discharges.Chapter 2 – Study Design



## CHAPTER 2

STUDY DESIGN

This chapter documents the methodology that EPA used to conduct this study of discharges incidental to normal operation of st udy vessels. It describe s the steps EPA took to collect information on the nature and pot ential impacts of vessel discharges.



## 2.1 D ATA 

## S OURCES



## EPA collected data from a variety of sour ces, including existing data from other EPA data collection efforts, meetings and telephone c ontacts with trade asso ciation representatives, vessel visits and sampling, literature reviews, and other governmental data sources. Each of these
data sources is discussed below.

2.1.1 Existing EPA Data Sources

A significant source of existing data regardi ng vessel discharges is EPA’s administrative record supporting EPA’s 2008 Vessel General Perm it (VGP). The administrative record is a
collection of all materials EPA considered in developing the VGP, including supporting documents, references, and comments received on the proposed VGP. As a first step in conducting this study, EPA reviewed these existing data sources to determine whether and to
what extent the data and information from thes e sources could be used to satisfy the study objectives. This review also iden tified data and information gaps for EPA to target for additional data collection efforts. In general, these ex isting data sources provi ded useful information regarding the types of vessel di scharges generated by vessel class, as well as the shipboard processes that contribute to their generation; however, the ex isting data sources contained little or no information regarding the nature , composition, and volume of discharges.

Other existing data sources evaluated for this study included supporting documents and
other materials from EPA’s Uniform National Discharge Standards (UNDS) (USEPA, 1999) and cruise ship discharges (USEPA, 2008c) programs. These sources, which pertain to armed forces vessels and large cruise ships, respectively, have limited applic ability to commercial fishing
vessels and nonrecreational vessels less than 79 feet in length; how ever, these data sources did provide supplemental information regarding sh ipboard processes that result in wastewater generation, as well as informati on regarding the types and amount s of pollutants that may be found in selected vessel discharg es such as graywater and bilgewater. One source directly applicable to this study, however, is the UNDS document, Final Sampling Episode Report for Small Boat Engine Wet Exhaust Dischar ge from Compression Ignition Engines (USEPA, 2008b), which provides pollutant data and other re levant information (e.g., vessel power levels) for wet exhaust discharges from two compression ignition engines. EPA used this report as a primary source of information and da ta for this vessel discharge.

39Chapter 2 – Study Design



## 2.1.2 Industry Participation

EPA was contacted by or contacted, met wit h, or otherwise collaborated with trade associations and individual companies. In th e course of these meetings, EPA gathered the following types of information regarding vessel discharges:

 Vessel classes within and outsi de the scope of this study.

 Typical vessel lengths by vessel class.

 Vessel operating seasons and locations.

 Shipboard systems and operations that contribute to vessel discharges.

 Vessel discharges and locations by vessel class.

 Volume, frequency, and nature of discharges.

 Vessel tours to inspect and observe vessel systems and operations that contribute to vessel discharges.

Note that none of the trade associations or individual companies contacted were able to provide pollutant data for vessel discharges.

The trade associations that contacted EPA or that EPA contacted included:

 American Waterways Operators (represents over 250 members that operate carriers, tug boats, towboats, and barges).

 Passenger Vessel Association (represents approximately 600 members that operate vessels such as ferries, dinne r cruises, whale watching expe ditions, site seeing tours, and water taxis).

 National Association of Charterboat Operators (represents over 3,300 charterboat owner and operators who provide fishi ng, sailing, diving, eco-tours, and other excursion vessels that carry passengers fo r hire, as well as recreational for-hire vessels).

 Conference of Professional Operators fo r Response Towing (C-PORT) (represents over 170 members of the commercial marine assistance industry, pr oviding services such as jump starts, fuel de livery, and towing to boaters).

 Pacific Seafood Processors Association (repr esents 10 seafood processing companies in Alaska, Washington, and Oregon).

 At-Sea Processors Association (represents five companies that own and operate 19 U.S.-flag catcher/processor vessels in the Alaskan pollock and West Coast Pacific whiting fisheries).

 Alaskan Longline Fishermen’s Association (represents about 60 members of longline fishing vessel companies and salmon fishing ve ssels that operate in southeast Alaska).

 United Fishermen of Alaska (represents a bout 37 commercial fishing organizations and associations concentrated in Alaska representing thousands of fishing companies operating as harvesters throughout Alaska waters and the ad joining Exclusive Economic Zone).

 Southeast Al aska Fishermen's Alliance (represents commercial fishermen and the commercial fishing industry in southeast Alaska).

40Chapter 2 – Study Design



##  Northeast Seafood Coalition (rep resents comm ercial groundfish fishermen and shoreside businesses from mid-coast Maine to Long Island, New York).

 Southern Shrimp Alliance (alliance of shrimp fishermen and processors in Alabama, Florida, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, and Texas).

 Petersburg Vessel Owners Association (repres ents fishermen in Petersburg, Alaska).

 Alaska Trollers Association (represen ts southeastern Alaska trollers).

 Cordova District Fisherman United (repres ents Cordova, Alaska, area fishermen).

Individual companies that provided additional informa tion (generally after being contacted by thei r respective trade groups) included:

 Potomac Marine, Woodbridge, Virginia.

 Vane Brothers Comp any, Mid-Atlantic.

 Potomac Riverboat Company, Alexandria, Virginia.

 Northeast Seafood Processors, Gloucester, Massachusetts.

 Vulcan Materials Company, Havre de Grace, Maryland.

 Sea Tow, Pensacola, Florida.

 EPA Gulf Ecology Division Laboratory, Gulf Breeze, Florida.

 Sea Tow, Slidell, Louisiana.

 AEP River Operations, Convent, Louisiana.

 Shrimp Charters, Pass Christian, Louisiana.

 Baltimore Water Taxi, Baltimore, Maryland.

 Sitka Sound Seafoods, Sitka, Alaska.

 Seafood Producers Co-op, Sitka, Alaska.

 Silver Bay Seafoods, Sitka, Alaska.

 Argosy Cruises, Seattle, Washington.

 Tidewater Marine, LLC, Gulf Coast.

 E.N. Bisso & Son, Lower Mississippi River.

 Foss Maritime Company, California, Washi ngton, Oregon, the Columbia River, and the Snake River.

 Taku Smokeries, Juneau, Alaska.

 Upper River Services, St. Paul, Minnesota.

 JB Marine Service, St. Louis, Missouri.

 Osage Marine Services, St. Louis, Missouri.

 AEP River Operations, Ne w Orleans, Louisiana.

 Smith Shipyard, Baltimore, Maryland.

 Norfolk Tug Company, Norfolk, Virginia.

 Dann Marine, Baltimore, Maryland.

 Cape Fear Riverboats, W ilmington, North Carolina.

41Chapter 2 – Study Design



## 2.1.3 Vessel Sampling

EPA identified a critical need for pollutant da ta for vessel discharges following its review of existing data sources. To satisfy this requ irement, EPA designed and implemented a vessel discharge sampling program, which is described in detail in Section 2.2 of this document. Through this sampling program , EPA collected wast ewater pollutant char acterization data for nine vessel discharges sampled fr om a total of 61 vessels (one to four discharges sampled per vessel). These samples were collected in 15 diffe rent towns/cities in nine separate states, representing several of the majo r regions of the United States. Another critical component of EPA’s sampling program was the collection of in formation regarding the shipboard processes, equipment, materials, and operations that contribu te to the discharges, as well as the discharge rates, duration, fre quency, and location.

2.1.4 Literature Review

EPA was not able to sample and character ize all study vessel cla sses and discharges (discussed further in Section 2.3 ). To fill this data gap, EPA searched the literature (i.e., scientific and engineering journals or other academic publications) for relevant inform ation. In general, these searches provi ded only general information regarding vessel classes and discharges and little or no specific informa tion, such as discharge composition and volumes. EPA did, however, identify many relevant lite rature sources regarding vessel antifouling leachate. EPA used these literature sources as the primary sources of information and data for this vessel discharge.

2.1.5 Other Governmental Data Sources

EPA’s primary data source for vessel inform ation regarding population and other vessel characteristics is the U.S. Coast Guard’s Marine Information for Safety and Law Enforcement (MISLE) database. The MISLE provides data for n early 1 million vessels that operate in U.S. waters and is used to support th e investigation and in spection activities of the U.S. Coast Guard throughout the United States and its territories . Of the 1 million vessels identified in the database, approximately 139,814 vessels comprise the study vessel population (see Chapter 1 for additional discussion). Relevant vessel characteristics tracked in this database are vessel type, length, geographical area of operation, age, hull material type, propulsion method and type, and horsepower ahead.

EPA used a screening-level an alysis of a hypothetical estuar ine harbor to evaluate the potential environmental impacts from multiple ve ssels discharging to large U.S. water bodies, specifically estuaries and brackish harbors (see S ection 4.2). EPA used the characteristics of harbor salinity, volume, and freshwat er inflow from a variety of U.S. estuaries that receive vessel discharges to develop the characteristics fo r the hypothetical estuary. EPA compiled these characteristics from the following online sources:

42Chapter 2 – Study Design



##  National Oceanic and Atmospheric Ad mi nistration BookletChartTM List

 National Oceanographic Data Center World Ocean Database 2005 (WOD05)

 Southeast Environmental Research Center , Biscayne Bay Water Quality Monitoring Network, Miami, Florida.

 Cronick, T., and A. McGuire. Temperature and Salinity of the Yaquina Bay Estuary and the Potential Range of Carcinus maenas , Corvallis, Oregon.

 Massachusetts Department of Environm ental Protection, Total Maximum Daily Loads of Bacteria for Little Ha rbor, Worchester, Massachusetts.

 U.S. Geological Survey Nati onal Hydrography Dataset Plus.

 U.S. Geological Survey National Water Information System Surface Water Annual Statistics.



## 2.2 EPA V ESSEL 

## D ISCHARGE 

## S AMPLING 

## P ROGRAM



## EPA conducted a sampling program of discharg es from commercial fishing vessels and
other nonrecreational vessels less than 79 feet in length. EPA’s sampling program was designed to provide information to achieve the first tw o objectives of the study mandated by P.L. 110-299:

 A characterization of the nature, type , and composition of discharges for representative single vessels, and for each class of vessel.

 A determination of the volumes of those discharges, including the average volumes for representative single vessels, and for each class of vessel.

Accordingly, EPA’s sampling program incl uded the sampling of large numbers and varieties of vessel classes, vessels, and discharg es, and the analysis of target analytes as discussed in the following subsections. In a ddition, EPA supplemented sample collection and analysis with the collection of information re garding the shipboard processes, equipment, materials, and operations that contribute to th e discharges, as well as the discharge rates, duration, frequency, and location.

Though the Agency was still in the final stages of drafting the 2008 VGP, EPA began designing and planning the sampling program soon after enactment of P.L. 110-299. These activities included developing the size and scope of the program considering overall program schedule and resources; identifyi ng priority locations, vessel cl asses, discharges, and analyte classes for sampling; developing a detailed Generic Sampling Analysis Plan and Quality Assurance Project Plan; procuring EPA regional laboratory and contract laboratory and sampling support; and soliciting industry i nput and volunteers for particip ation in the program. Sample collection was conducted from March through July 2009. The remainder of this section provides a further description of the sampling program, in cluding the vessels sampled and their locations, sampled discharges, target anal ytes, sampling methods, and quality assurance/quali ty control.

43Chapter 2 – Study Design



## 2.2.1 Vessels Sampled and Locations

EPA sampled discharges from a total of 61 vessels in nine vessel classes (see Table 2.1 ).
To select vessel classes for evalua tion, EPA firs t developed a list of commercial vessel classes based on published information and the EPA t eam’s existing understanding of vessels. Next, EPA narrowed the sampling scope to focus largel y on those vessel classes believed to consist primarily of vessels less than 79 feet in length. Some examples of vessel classes on which EPA did not focus, due to their size, include cable laying ships, crui se ships, large ferries, oil and petroleum tankers, and freight ships/barges (most vessels in these classes are typically greater than 80 feet in length). Next, EPA eliminated vessel classes outside the scope of study vessels, including stationary seafood processing vessels and vessels that can be secured to the ocean floor for mineral or oil exploration, be cause the industrial discharges fr om these vessels were outside the scope of the previous 40 CFR Part 122.3(a) exclusion (USEPA, 2008d ). After eliminating these vessels, the following common vessel classes were prioritized for evaluation:

 Commercial fishing vessels and tenders

 Tugs/towing vessels

 Water taxis/small ferries

 Tour boats

Purse Seiner in Alaska (left) and a Shrimp Trawler in Louisiana (right).

44Chapter 2 – Study Design



## A Tugboat in Maryland (left) and a Tow/Salvage Vessel in Virginia (right).

A Water Taxi in Virginia (left) and a Tour Boat in Virginia (right).

45Chapter 2 – Study DesignTable 2.1. Number of Vessels Sampled by Vessel Class and DischargeNumber of Vessels Sampled by DischargeVessel ClassNumber ofVesselsSampledBilgeWaterStern TubePackingGlandDeckWashdownFish HoldCleaning ofFish HoldGraywaterPropulsionEngine EffluentGeneratorEngine EffluentFiremainFishing:Gillnetter5131Lobster111Longliner3131Purse Seiner55111Shrimp Trawler61621Tender332Trawler4234Troller6261Tugboat99952WaterTaxi421141TourBoat312323Tow/Salvage6365Research22FireBoat11111SupplyBoat11Recreational2112Total61893226981956(1) Sampled the lobster hold tank on a trawler.46Chapter 2 – Study Design


## Additionally, EPA sam pled recr eational vessels used for nonr ecreational purposes as part of this study. This sampling was done for two purposes: 1) to provide a semiquantitative comparison of the discharges from these vessels and the other study vesse ls, and 2) to collect
additional information for EPA’s related work on the Clean Boating Act (P.L. 110-288). During the execution of the sampling prog ram, EPA also conducted opport unistic sampling of additional non-priority vessel classes (e.g., fire boats, re creational boats, a supply boat) when EPA had access to these vessels and the resources to samp le them. See Section 1.3 of this document for a short description of different vessel classes or types.

As discussed in Section 2.1.2 , EPA was contacted by or ot herwise developed contacts
with trade associations and indi vidual companies. Many of these entities relayed the purpose of the study to their constituents or peers, som e of whom contacted EPA. Consequently, EPA obtained a pool of individual companies who we re willing to volunteer their vessels for the sampling program. EPA then selected specific co mpanies and vessels within the volunteer pool for sampling to obtain a variety of vessel classe s, vessel platforms, companies, and geographic distribution. In general, EPA se lected the entire volunteer pool within the following geographic areas to maximize the number and variety of sa mpled vessels based on available resources: New England (Gloucester/New Bedf ord, Massachusetts); Mid-Atla ntic (Woodbridge, Virginia; Alexandria Virginia; Baltimore, Maryland; Ha vre de Grace, Maryland; and Philadelphia, Pennsylvania); Gulf Coast (Gulf Breeze, Florida; Pensacola, Florida; Bayou la Batre, Alabama; Pass Christian, Mississippi; Slidell, Louisiana; La Fitte, Louisiana; and Convent, Louisiana); and Sitka, Alaska.

EPA’s vessel selection approach for commercial fishing vess els differed from that of
other vessel classes due to the nature of this industry. During the fishing season, fishing trips typically last for multiple days with no preset schedule. The captain of each vessel determines the end of each fishing trip, returns to the seaf ood processor or tender to offload the catch, and then typically immediately returns to the fi shing grounds. Therefore, EPA identified seafood processors, rather than specific fishing companies and vessels, as the means to obtain a pool of active fishing vessels for sampling. Sampling was conducted at the docks of the seafood processors during the offloading process, and EP A sampled all vessels that arrived while the EPA sampling crew was at the docks (with the perm ission of the captains). In this way, sampling of individual commercial fishing vessels was random. However, EPA did contact the seafood processing facilities prior to sampling to pr ovide sampling details (e .g., nature of the study, discharges of interest, sampling dates). It was the facilities’ di scretion whether or not to share this information with the vessel fleets that use their offloading facilities.

Due to the assistance of trade groups and ot hers, vessel owner/opera tors were generally very cooperative with EPA sampling teams. For example, the EPA vessel team found that most of the fishermen with whom they spoke in Sitk a, Alaska, were aware of the study and that EPA would be sampling in the area during the su mmer. Other vessel owne r/operators took EPA

47Chapter 2 – Study Design


## underway to sample engine effluent, waited to wa sh their dishes or take showers until EPA was
able to colle ct the graywater discharge, and assi sted EPA scientists in answering questions about their vessel operations.

During the public comment period for this report, EPA received comments noting that the types of vessels sampled for this study were not necessarily representative of the industry as a whole, specifically for commercial fishing vess els. Based on public comments, EPA evaluated the representativeness of the sampled commercial fishing vessels in terms of size, class, and geographic distribution. The comme rcial fishing industry is hi ghly diverse (spanning a wide array of ocean and nearshore conditions, differi ng by both region and fishery). With respect to vessel size, EPA notes that the sampled commer cial fishing vessel popula tion does not represent discharges from vessels less than 26 feet in le ngth, which comprise an estimated 10% of the overall commercial fishing vessel population. Ho wever, though EPA did not physically sample these vessels, we visually observed that these sm all vessels typically store their catch in coolers (which do not have a discharge) rather than in refrigerated seawater or ice holding tanks, which is a function of their relatively short fishing voyages. For larger fishing vessels, EPA believes the sampled vessel population is reasonably representative of the overall vessel population, albeit somewhat more heavily weighted toward the larg est of commercial fishing vessels (i.e., 50 feet or more).

With respect to vessel class, EPA’s sa mpled commercial fishing vessel population includes vessels in all of the fishing vessel clas ses. Furthermore, the percentage of sampled vessels by class is similar to or greater than the percentage of th e overall vessel population by class for all vessel classes except for Pot/Trap ve ssels. Pot/Trap vessels include many of the smallest commercial vessels that are not re presented by EPA’s sampled vessel population. EPA also notes that it sampled a much higher percen tage of Seiners than th e overall vessel population (15% of vessels sampled versus only 2% of th e overall vessel population). Sampling in Sitka, AK occurred at the start of the salmon fishing se ason, resulting in a preponderance of Seiners at the docks of seafood processers.

Finally, with respect to geographic distri bution, EPA sampled commercial fishing vessels in the following regions: Alaska (21 vessels); Gulf Coast (6 vessels); and New England (6 vessels). According to the National Marine Fisheries Service, in 2008 these three areas combined represented approximately 77% of U.S. do mestic commercial landings in 2008. Among the remaining geographic regions that EPA was una ble to sample, the Pacific Coast (excluding Alaska) has the greatest landings in 2008 at 13% of U.S. domestic commercial landings; commercials fishing vessels in this region are exp ected to be similar to those in Alaska. Finally, many of other remaining geographic regions that EPA was unable to sample, such as the Chesapeake Bay, Middle Atlantic, and the Great La kes, are likely dominated by small fishing vessels that most likely have low volumes of or no fish hold effluent discharges.

Hence, with the exception of the smallest co mmercial fishing vesse ls, EPA believes that the sampled vessel population is a representative cross-section of vessels and is adequate to evaluate the vessel population for the purpose of this study.

48Chapter 2 – Study Design



## 2.2.2 Sampled Discharges

EPA sampled a total of nine discharg e types during the sampling program (see Table

2.1 ). To identify priority discharges for sampling, EPA first developed a list of vessel discharges
based on information collected from discussions with industry represen tatives (see Section

2.1.2 ), as well as EPA’s understand ing of vessel discharges. Next , EPA prioritized the list to focus on the following discharges that are commonl y generated by the vessel classes of interest
and that are amenable to sam pling (see Chapte r 1 for descriptions a nd locations of these discharges):

 Bilgewater

 Stern tube packing gland effluent

 Deck runoff and/or washdown

 Fish hold effluent (includi ng both refrigerated seawater effluent and ice slurry)

 Effluent from the cleaning of fish holds

 Graywater

 Propulsion engine effluent

 Generator engine effluent

 Firemain discharges

Vessels routinely use ambient waters to conduct normal operational and cleaning
activities that lead to the generation of above discharges . EPA collected samples of ambient water where the vessels were operating. EPA al so collected potable water used onboard the vessels (service water) to characte rize any background concentrations of pollutants that might be detected in discharges from vessel op erations that use service water.

Various Discharges Through Hull Discharge Ports Various Discharges Through Hull Discharge Ports.



## 49Chapter 2 – Study Design


## EPA did not select non-oily machinery wastew ater as a priority discharge for sam pling because it was not expected to be discharged se parately from bilgewater. The vessels that EPA sampled during this program use the bilge system to manage non-oily machinery wastewater (if there is any), such as fresh- and saltwater pum p drains, chilled water condensate drains, and potable water tank overflows, rather than installing dedicated drip pans, funnels, and deck drains to provide for segregated discharge. Note, however, that EPA has not performed a comprehensive investigation of whether or not certain non-oily machinery wastewaters may have segregated discharges on other study vessels.

EPA did not select the discharges listed be low as priority discharges for sampling because they were not reasonable or practical to sample within the overall program schedule and
available resources.

 Anti-fouling hull coatings.

 Cathodic protection.

 Controllable pitch propeller and thrust er hydraulic fluid and other oil-to-sea interfaces.

 Underwater ship husbandry.

EPA did not select the discharges listed be low as priority discharges for sampling because they were not expected to be commonl y generated on commercial fishing vessels or
nonrecreational vessels less th an 79 feet in length.

 Aqueous film-forming foam

 Boiler/economizer blowdown

 Distillation and reverse osmosis brine

 Elevator pit effluent

 Exhaust gas scrubber wash water

 Freshwater layup

 Gas turbine wash water

 Motor gasoline and compensating discharge

 Sonar dome discharge

 Welldeck discharges

 Graywater mixed with sewage

None of these discharges were sampled duri ng the sampling program because none of the 61 vessels that EPA selected for sampling generated these discharges. Note, however, that EPA has not performed a comprehensive inve stigation of whether or not thes e discharges are applicable to other study vessels.

50Chapter 2 – Study Design



## 51 2.2.3 Target Analytes

EPA’s vessel discharge sampling and analysis program included 301 target analytes in the following eight analyte groups: 1



##  Microbiologicals (pathogen indicators)

 Volatile and semivolatile organic compounds

 Total and dissolved metals

 Oil and grease

 Sulfide

 Long and short chain nonylphenol and octy lphenol ethoxylates (i.e., alkylphenol ethoxylates) and tota l nonylphenol (NP)

 Nutrients

 Other physical/chemical parameters

Appendix D lists the target analytes incl uded in each group, along with the analytical methods. EPA selected this comprehensive list of analytes to perform a screening-level analysis of the presence or absence of almost all prior ity pollutants (listed at 40 CFR Part 423, Appendix A), conventional pollutants defined at Section 304(a)(4) of the Clean Water Act, and toxic pollutants from EPA’s 2006 Nationa l Recommended Water Quality Cr iteria for freshwater and saltwater aquatic life and human health, as well as many other nonconventional pollutants. Nearly half of these analytes (147) were never detected in any vessel discharge sample (see Chapter 3).

EPA did not analyze all vessel discharges for all selected analyte groups (see Table 2.2 ). Analyte groups were selected for an alysis base d on their possible presence in discharges, as determined from existing data sources and EPA’s understanding of what constituents are possibly present in the different vessel discharges. For example, long-chain nonylphenol and octylphenol ethoxylates were only analyzed for in those discha rges with the potential to contain detergents (i.e., bilgewater, packing gland, deck washdown, fi sh hold cleaning effluent, and graywater). Furthermore, short-chain nonylphenol and octylphenol ethoxylates and NP were only analyzed for in those discharges for which the lo ng-chain structural isomers of these two subsets of alkylphenol ethoxylates were analyzed, and that also had a holding time onboard the vessel that would allow for the possible degradation of the long-chain isomer s to the short-chain isomers and NP (e.g., bilgewater held in the b ilge, graywater stored in a holding tank).

1 

### Due to overall program resource constraints and other f actors, not all analyte groups of possible concern were selected for this study (see Section 2.3.3).Chapter 2 – Study DesignTable 2.2. Analyte Groups by DischargeVessel Class and Priority Discharge Microbiologicals Volatile and Semivolatile Organic Compounds Metals (Total and Dissolved) Oil and Grease Sulfide Short-Chain Alkylphenol Ethoxylates and NP Long-Chain Alkylphenol Ethoxylates Nutrients BOD 5 , COD, TOC (a) Total Suspended Solids Other Physical/Chemical Parameters (b)Bilgewater√(c)√√√√√√√√√√Stern tube packing gland effluent√√√√√√√√√√Deck runoff and/or washdown√(d)√√√√√√√Fish hold effluent (including both refrigeratedseawater effluent and ice slurry)√√√√√√√√Effluent from the cleaning of fish holds√√√√√√√√√Graywater√√√√√(e)√√√√√Propulsion engine effluent√√√√√√Generator engine effluent√√√√√√Firemain systems√√√(a) Biochemical oxygen demand (BOD5), chemical oxygen demand (COD), and total organic carbon (TOC).(b) Other physical/chemical parameters include: conductivity; dissolved oxygen; pH; salinity; temperature; total residual chlorine; turbidity; and observations ofodor, color, and floating and settleable material.(c) Microbiologicals analyzed for only those vessels with potential for a source of these pollutants to enter the bilge (e.g.,graywater piping, fish hold effluent).(d) Microbiologicals analyzed for only commercial fishing vessels.(e) Short-chain alkylphenol ethoxylates (i.e., nonylphenol and octylphenol ethoxylates) and NP analyzed only for graywater that has been stored in a holdingtank prior to discharge.52Chapter 2 – Study Design



## 2.2.4 Sampling Methods

EPA used a variety of sample collecti on methods depending on the nature of the discharge. This section describes th e most commonly used sampling methods.

Discharge from a discharge por t well above the water line.

Samples of these types of discharges were typically collected directly into a 5-gallon utility bucket lined with a new pail liner. For some samples, the bucket could be lowered by hand, while for other samples, the bucket was lo wered by rope. The sample in the pail liner was then poured into the individual sample bottles. Wh enever possible, samples for analysis of oil and grease were collected directly into the samp le bottles (either held by hand or attached to a pole) to avoid the possible loss of oils to the sides of the sample transfer jar and pail liner. However, when oil and grease sample bottles were filled directly by attaching to a pole, it was typically necessary to “top off” the sample bottle s with sample from the pail liner to ensure adequate sample volume for analysis.

Sample Collection Well Above the Water Line.

Discharge from a discharge port at or below the water line.

Typically, samples of these type s of discharges were impossibl e or too unsafe to collect. In a few cases, however, EPA was able to collect samples upstream of the discharge port via a sampling port. For example, on one vessel, engine effluent could be ac cessed from a petcock valve on the muffler. Samples of these types of di scharges were preferentially collected directly into sample bottles. In some cases, the cleara nce between the sampling port and the vessel hull

53Chapter 2 – Study Design



## was insufficient to accommodate the sam ple bo ttles and instead, required sample collection directly into a new pail liner; the sample in the pail liner was then poured into the individual sample bottles.

Close Up of Petcock Valve Close-up of Petcock Valve.

Deck washdown and runoff.

Deck washdown and runoff wastewater is di scharged through scuppers located along the perimeter of the deck. To collect samples of this discharge, EPA generall y directed the discharge to one or more (up to four) select scuppers us ing a variety of methods. On some vessels, deck washdown water naturally flowed by gravity to one or more scuppers at the lowest end of the deck. On other vessels, EPA used either the spra y from the hose used to wash the deck or the
broom used to wash the deck to direct the d eck washwater to one or more selected scuppers. Finally, on some vessels, EPA arranged the deck washing hose on the vessel deck such that it directed and pooled deck washdown water to one or more selected scuppers. To collect the discharge from a selected scupper, EPA held a ne w pail liner against the hull of the vessel to capture the deck washdown water as it drained through the scupper. If deck washdown water was discharged through multiple scuppers, EPA filled the pail liners proportionally from each scupper (e.g., half from each of two scuppers, one-third from each of three scuppers). The sample in the pail liner was then poured into the individual sample bottles.

54Chapter 2 – Study Design



## Deck Cleaning and Collecting Deck Washdown Sample. Collecting Deck Washdown Sample with Close-up of Scupper ( Indicated with Red Arrow )

.

For select fishing vessels, EPA attempted to collect samp les of runoff during actual fishing operations. EPA arranged to travel with an overnight shrimping vessel on the Gulf Coast; however, due to a temporary seasonal shrimp fish ery closing, EPA obtained a research permit to collect runoff from “demonstration” operations. Because these were demonstration operations and the shrimp fishermen would be unable to keep the catch, the vessel operator used a smaller
net for shorter durations and did not handle the catch as he norm ally would. As a result, these samples only partially resemble normal operatio ns. While in Alaska, the U.S. Coast Guard assisted EPA in attempting to sample deck wa shdown from fishing vessels immediately after they pulled in their catch. EPA and the Coast Guar d attempted to sample three to five vessels during this operation. Due to weather conditions, however, they were only able to sample one vessel successfully.

Fish hold tanks.

Three types of fish hold tanks were sa mpled during the program: tanks containing refrigerated seawater, tanks cont aining ice slurry, and tanks contai ning chipped ice. Refrigerated seawater tanks were common to tenders, purse sein ers, and trawlers, while slurry and chipped ice tanks were common to trollers, l ong-liners, gillnetters, and so me trawlers. For vessels with refrigerated seawater tanks, fish are typically extracted using a vacuum system that removes both the fish and refrigerated seaw ater simultaneously. Both fish and refrigerated seawater are transferred to the seafood processi ng plant. The refrigerated seawater is generally recycled back to the fish hold tank to provide the liquid n eeded to operate the vacuum system. Any excess refrigerated seawater that is not required to assist in fish ex traction is pumped overboard pier side. EPA collected samples of the refrigerated seawater directly into a 5-gallon utility bucket lined with a new pail liner as the water was pum ped overboard. The sample in the pail liner was then poured into the individual sample bottles. Becau se removal of fish and refrigerated seawater

55Chapter 2 – Study Design


## can take several hours depending on the vessel si ze, EPA collected the sample approximately mid-way through the fish removal process. For vesse ls such as trollers and long-liners, which use chipped or slurry ice, EPA collect ed a sample of the ice or slurry once the fish had been removed from the fish hold tank. Ice/slurry was collected into a new pail liner and allowed to melt. Once melted, the sample was poured from the pail liner into the individual sample bottles.

Collecting Fish Hold Sample with a Lined Bucket Collect ined Collect Collect ing F ish H old S ample w ith a L B ucke t

.

Fish hold cleaning.

After the fish hold has been evacuated, the vess el crew cleans the fish hold as described
in Section 1.3. For vessels with refrigerated seawater tanks or chipped ice tanks, the fish hold cleaning wastewater is pumped overboard. EPA collected samples of the fish hold cleaning wastewater directly into a 5-ga llon utility bucket lined with a ne w pail liner as the cleaning water was pumped overboard.

Firemain.

EPA used valving on the firemain system to throttle the flow rate to allow firemain samples to be collected from the fire hose directly into sample containers. None of the vessels visited by EPA for this study tests its firemain system more frequently than once every two weeks, and none operates its system for secondary purposes such as deck washing. Of the six firemain systems sampled, five were wet systems (the firemain piping is normally filled with water) and one was a dry system (t he firemain piping is normally fi lled with air). The resulting

56Chapter 2 – Study Design



## samp ling data are applicable to firemain system s that are operated infrequently with intake provided by surrounding water and wit hout additions to the discharg e (e.g., no addition of foamforming agents).

Composite samples of multiple wastewaters.

To better characterize some discharges, EPA decided to combine multiple samples of wastewaters into a single sample for analysis . The most common example is a vessel that operates its engines at multiple power levels—idl e at the pier, half-speed when motoring through the no wake zone, and three-quarter speed when performing harbor tours. Another example is a vessel that generates two types of graywater— wastewater from a galley sink and wastewater from a shower. In these cases, EPA filled a new pail liner proportionally based on the number of wastewater sources (e.g., one-thi rd from each of three power leve ls, half from each of sink and shower water) using one or more of the sample collection methods described above. The sample in the pail liner was then poured into the individual sample bottles. Whenever possible, EPA collected and analyzed separate samples for each discharge for oil and grease and for volatile organics, rather than using the composite sample; this minimized the possible loss of these target analytes from volatilization during sample tran sfer among multiple sampling equipment or due to
adherence of oils to the sides of multiple sampling equipment.

57 Collecting Engine Effluent with a Transfer Jar. Compositing the Sample in a Lin ed B uc k et

.Chapter 2 – Study Design



## 2.2.5 QA/QC

Quality assurance/quality control (QA/QC) procedures applicable to EPA’s vessel sampling program are outlined in the Quality Assurance Project Plan for Discharges from Commercial Fishing Vessels and Other Non-Recreational Vessels Less Than 79 Feet (QAPP),
which is included in the docket of the Federal Register notice announcing this study. This section describes the QC practices used to assess the pr ecision and accuracy of the analytical data.

2.2.5.1 Analytical Quality Control

Analytical chemistry support for this progr am was provided by EPA’s own laboratories in Regions 2, 3, and 5, as well as several s ubcontract laboratories. The EPA Regions were responsible for the quality of the work generate d by their laboratories and for verifying that laboratory performance was acceptable by conducti ng QC checks of the analytical data as specified by the QAPP. Subcontract laboratories functioned within the quality system of EPA’s sampling contractor, who verified the acceptabili ty of subcontract laboratory performance by conducting QC checks of the analytical data as specified by the QAPP. Based on the data quality review and evaluation of the analytical data under this sampling program, all analytical data were deemed within or sufficiently close to the target analytical QC limits established for the study to assure the data could be used for the specified in tentions. QC failures were generally attributed to matrix interference; these results are not uncommon for complex wastewater samples. Furthermore, the sample collection, handling, prepar ation, and analysis pro cess utilized in this sampling program was deemed acceptable fo r the matrices and conditions sampled.

2.2.5.2 Field Quality Control

Field QA/QC measures and results for the bo ttle blanks, equipment blanks, trip blanks, field blanks, and field duplicates are discussed in this subsection.

Bottle blank.

A representative bottle and cap from the first lot of bottles purchased for collection of samples for analysis of pathogen indicators we re analyzed for wide-s pectrum contamination prior to their use in the sampling program. Bottles were filled with sterile deionized water, and 100–milliliter (mL) aliquots were filtered by me mbrane filtration. The filters were placed on water agar, nutrient agar, m odified mTEC agar (for E. coli cultures), and mEL agar (for enterococci cultures). No pathoge n indicators or other organisms (water or nutrient agar) were detected in the bottle blank, indica ting that the bottl es were sterile.

58Chapter 2 – Study Design


## Equipment blanks.

Two equipment blanks were prepared and analyzed for volatile and semivolatile organic compounds (SVOC), total and dissolved metals, nutrients, soaps and detergents, and other physical/chemical parameters to assess the poten tial introduction of contaminants by sample collection equipment. The sample collection equipment used to co llect the equipment blanks was the same as that used at the sampling points: 1) a new, f actory-cleaned, Teflon ® 

## PFA pail liner from the first lot of bags purchased from the ve ndor, and 2) a 3-foot segm ent of silicone tubing connected to a 25-foot segment of Teflon tubing used in the perist altic pump (only used on three samples throughout the entire project). The pail liner equipment blank was prepared by rinsing the bag with high performance liquid chromat ography (HPLC) water an d then pouring it into sample bottles. The pump tubing equipment blank was prepared by pumping HPLC water through this equipment and collecting directly in to sample bottles. Of the 459 equipment blank sample results, 29 (6.3 percent) were above th e method reporting limit (RL). Of the cases where the equipment blank exceeded the RL, 15 were for SVOC analytes and seven were for VOC analytes. In all 22 of these cases, however, th e analytes were tentatively identified compounds (TICs), which are appropriately la beled in the analytical database as such. The remaining cases where the equipment blank exceeded the RL were as follows: biochemical oxygen demand (BOD) (two instances), chemical oxygen demand (COD) (two instances), tota l Kjeldahl nitrogen (TKN) (one instance), nitrate/nitrite nitrogen (o ne instance), and zinc (one instance). In each instance, the vast majority (greater than 90 per cent) of the associated discharge sample amounts were significantly higher than the equipment blank levels.

Trip blanks.

Trip blanks were prepared and analyzed for volatile organics to evaluate possible contamination during shipment and handling of samples. These samples consisted of HPLC water poured into the sample bo ttles and transported unopened to the field and finally to the laboratory. One trip blank was prepared for each location-specific sa mpling event (e.g., Gulf Coast, New England). Evaluation of the trip blan ks indicated that of the 612 VOC results for these samples, only two analytes were detected (tetramethylsilanol a nd tetrahydrofuran), and
these were at levels below the RL. Neither of thes e analytes was detected in any vessel discharge samples, indicating that there was no sample c ontamination during transport, field handling, and
storage.

Field blanks.

Field blanks were prepared and analyzed fo r all target analytes to monitor for the contamination of samples during sample collect ion and handling. These samples were prepared
aboard selected vessels at th e location of greatest potential for contamination (e.g., the vessel bilge space). The samples were prepared by pouri ng HPLC water into the sample bottles. One field blank was prepared for each location-sp ecific sampling event (e.g., Gulf Coast, New

59Chapter 2 – Study Design


## England). Only six target analyt es (conductivity, dissolved organic carbon, nitrate/nitrite, TKN, turbidity, and total zi nc) were detected in any of the 670 fiel d blank results (0.3 pe rcent) at levels
above the RL . In each instance, the associated discharge sample amounts were significantly higher than the field blank levels.

Field duplicates.

Field duplicate samples were collected and analy zed for all target anal ytes to assess the precision of the entire sample collection, handl ing, preparation, and anal ysis process. Field duplicate samples were collected simultaneously from the same location as the original samples (i.e., poured from the pail liner as a split sample or sampled sequentially when collecting samples directly into sample bottles from discharge por ts). The relative percent difference (RPD) between the two duplicate sample results was calculated and compared to the data quality objective. The occurrence of field duplicate samples (number of samples exceeding out of total number of duplicate samples) where one or more analytes w ithin an analyte type ( VOCs, SVOCs, dissolved metals) exceeded the target RPD was 89 of 356 pair s of field duplicate samples, or 25 percent. The higher RPDs were calculated in samples where the concentrations of the analytes were
detected at levels at or near the detection level for the resp ective methods, mainly for VOCs, Silica Gel Treated N-Hexane (SGT-HEM), a nd residual chlorine. For these methods, the analytical variability increases as analyte concentrations approa ch their detection limits. These results are not uncommon in complex wastewater samples.

2.2.5.3 Database Development

An Access database was created in which to collect and organize all analytical results.
This database contained data and associated qualifier information. Although a number of EPA
and contractor staff were involved in reviewing the results, only one person had the authority to make any changes to the database during its development. This one-person control system eliminated the possibility of someone accidentally creating more than one current version of the
database and minimized the risk of errors. Each time the database was updated, the current date and time stamp were used to name the new vers ion, which was uploaded to a secure FTP server.

After each sampling event, the chains of cust ody (COC) and field data sheets were used to manually enter information into the “COC Information” table. This table contained identifiers given to samples in the field (FieldIDs) asso ciated with vessel name , location, and discharge information, as well as the sample date a nd time. A second person performed a 100-percent
check of the data entered to ensure there were no transcription errors or mistakes made during data entry.

Four analytical chemistry and subcontrac t laboratories —EPA Region 2 (Edison, New Jersey), EPA Region 3 (EPA Environmental Scien ce Center, Fort Meade, Maryland), TriMatrix (Grand Rapids, Michigan), and Admiralty (June au, Alaska)—provided EPA’s contractor with

60Chapter 2 – Study Design



## electronic d ata deliverables (EDDs) in either Excel or delimited text format. EDDs were first imported into the database as new tables that remained unaltered while the fields of interest, contained therein, were appended to a table called “Vessel Results .” The remaining fields were populated using queries. Ten percent of the data in the Vessel Results table from three of the four laboratories were compared to the original hard copy reports, if provided. This ensured consistency between the EDD and hard copy re port, as well as validated the importing procedure. As a further quality assurance m easure, a 100-percent check was done comparing these PDF reports to database entries de rived from the fourth lab’s EDD reports.

Data that were not received in EDD format (i .e., hard copies, PDFs, and field data sheets) were manually entered directly into the Vessel Results table. These da ta were provided by six additional analytical chemistry and subcontract laboratories: EP A Region 5 (Chicago, Illinois), Biomarine (Gloucester, Massachusetts), Envi roChem (Mobile, Alabama), QC Laboratories (Southampton, Pennsylvania), Northeast Environm ental Laboratory (Danvers, Massachusetts), and Sitka Water Treatment Plant (Sitka, Alaska). As with the COC information, a second person did a 100-percent check of th e accuracy of data entry.

In addition to checking for reporting accuracy, a check of laboratory QC procedures was performed. EPA examined laboratory QC para meters, including method type, hold times, laboratory blanks and duplicates , laboratory control samples, and surrogate recovery, where applicable, for all subcontract laboratories.



## 2.3 D ATA 

## C ONSIDERATIONS AND STUDY LIMITATIONS



## 2.3.1 Voluntary Nature of the Sampling Program

All vessel sampling performed for this st udy was conducted on a voluntary basis (i.e., vessel owners/operators voluntarily allowed EPA to sample their vessels). As such, the selection process was not completely random from within the universe of study vessels, nor were the vessels sampled unannounced, with the possibl e exception of fishing vessels (see Section 2.2.1 ). These issues raise po tential concerns regardi ng the representativeness of the sampling and the statistical uncertainty of the resulting data an alyses. To minimize these concerns, EPA provided study volunteers with guidance for participation in the sampling program. This guidance stressed EPA’s desire to sample normal discharge cycles /events and requested th at volunteers not alter vessel operations from normal (typical) operation . The guidance specifically instructed that volunteers should not perform any special cleaning in preparati on for sampling, add or eliminate or alter any typical discharges, or increase or decrease the volum e or other characteristics of discharges, etc. Also, as EPA preferred to coll ect samples pierside rather than underway, EPA instructed volunteers to inform the Agency if conducting sampling pierside compromised, in any way, the characteristics of discharges (sources, volumes, composition).

61Chapter 2 – Study Design


## As a further consideration, EPA assume d th at most of the volunt eers were generally ‘good actors’ who would have the best maintained vessels and be in comp liance with all existing applicable regulations, which could also affect the representativeness of the data collected for the
vessel class as a whole.

2.3.2 Vessels/Discharges Not Sampled

While this study included the sampling of a la rge number of discharges from a large number of vessels, certain vessel classes and di scharges were either not sampled at all or received only limited sampling due to overall prog ram schedule and resource constraints or other factors (see Sections 2.2.1 and 2.2.2 ). EPA supplemented its sampling program with information
and data collected from other data sources to the extent possible; however, the Agency acknowledges remaining gaps in achieving the study objectives for certain segments of the industry. In particular, EPA has lit tle or no information or data re garding freight barges, freight ships, tank barges, and tank ships le ss than 79 feet in length (estimated to represent 7 percent of study vessels). In addition, EPA has little inform ation or data regarding the applicability of several discharges listed in Section 2.2.2 to study vessels.

EPA’s ability to fu lly characterize certain discharges was limited by some practical considerations. For example, on many vessels, disc harges were too close to the waterline, or even under the waterline, precluding the ability to collect an uncontaminated sample. Installation of sample taps upstream of thes e discharge ports was either im possible (i.e., would compromise system integrity) or impractical within time cons traints for the sampling events. On other vessels, collection of vessel discharges under normal opera tions was either impossible or unsafe. These
conditions included:

 Vessel configurations blocking access to discharge ports

 Discharge volumes insufficient for sampling

 Discharges not generated during the sampling event

 Systems such as generators not operational during the sampling event

 Systems operated only during emergency

 Discharges requiring underway sampling

 Fishing vessel platforms inactiv e during the sampling schedule

 Fishing seasons closed or outside the sampling schedule

 Inability to sample all U.S. fisheries

As an example, EPA was able to sample bilgewater on only eight of the 61 sampled vessels (13 percent). Bilgewater sampling was infeasible for appr oximately three quarters of the remaining vessels for three reasons. First, automatic bilge pumps operating while the vessel was underway resulted in an empty bilge when the ve ssel returned to pier. Manual activation of the bilge pump on these vessels did not result in any discharge or only a small volume of discharge. Second, as a matter of policy, many vessels rest rict bilgewater discharges to only while

62Chapter 2 – Study Design


## underway or when outside U.S. waters due to possible concerns of exceeding existing Clean Water Act § 311 requirements. Third, some bilgewater discharges were too close to the waterline for sampling. For the remaining one quarter of vessels, sampling was not performed because the vessels never discharge bilgewater . On these vessels, a contractor steam cleans the bilges once per month, and the resulting cleaning waste is re moved from the vessels for shoreside disposal.

2.3.3 Pollutants Not Sampled

A few candidate analyte groups (pesticides, polychlorinated biphenyls, dioxins/furans, flame retardants, uranium, and asbestos) were not selected for analysis, as they are not anticipated to be present in the vessel discharges due to the lack of a readily apparent source for these pollutants.

While EPA’s list of target analytes include s many persistent, bioaccumulative, and toxic chemicals (PBTs), many other PBTs were not anal yzed for due to the lack of test methods or resources. In general, these unanalyzed compounds either have no known use or source onboard vessels or have no readily available means to enter the vessel discharges. Mercury was not selected for analysis because it requires specia lized sampling techniques inapplicable to vessel sampling to minimize the potential for sample contamination (e.g., vessel sampling cannot be conducted away from sources of metals or sources of airborne contamination such as engines or generators).

Test methods for pharmaceuticals and personal care products (PPCPs) have recently been developed; however, EPA did not select this analyte group for analysis due to a lack of resources. These compounds are most likely to be found in sewage, which is outside the scope of this study; however, they can also be expected to be found in graywater s ources, such as sink and shower wastewater, albeit at very low concentrations.

Although ballast water, and its assessment as a vector for aquatic invasive species, was specifically excluded from this study by the statutory language in P.L. 110-299 (see Appendix C), EPA recognizes that ot her vessel discharges, such as bi lgewater; stern tube packing gland effluent; fish hold effluent; and discharges from vessel hulls, propellers, and other exposed surfaces are also potential vector s for the spread of aquatic invasive species. EPA excluded any aquatic invasive species characteri zation as part of this study in consideration of overall program
schedule and resources.

2.3.4 Application to Other Vessels, Includin g Larger Vessels No t Sampled for this Study

EPA’s primary objective in conducting the vess el sampling program was to characterize discharges specific to commercia l fishing vessels and nonrecreatio nal vessels less than 79 feet (i.e., study vessels). Some data are applicable to other vessels, however, including larger vessels not sampled for this study. This subsection discu sses EPA’s consideration of the applicability of

63Chapter 2 – Study Design



## 64 these sample data to other vessels, as well as factors that data users should consider in determining the broader applicability of the data.

Bilgewater.

The composition and volume of bilgewater is hi ghly dependent on the specific sources of wastewater that accumulate in bilge, as well as vessel size, hull design and construction, vessel operation, and a variety of additi onal factors (see Section 1.3). Any researcher, regulator, or other stakeholder who subsequently uses the da ta collected in this study should evaluate and compare the characteristics of the vessels sample d for this study to thos e of other vessels to determine the applicability of EPA’s sampling da ta. In general, EPA believes that the design, construction, and operation of vessels not sample d for this study (e.g., cruise ships, ferries, barges, tankers) differ considerably from thos e of the sampled vessels, which would result in significantly different bilgewater characteristi cs. Hence, EPA cautions against applying the limited bilgewater results from this study to all vessels.

Stern tube packing gland effluent.

This discharge applies to vessels that colle ct the ambient water that leaks through the stuffing box and packing gland that surround the pr opeller shaft in a segregated area from the general bilge. During this study, EPA observed th is segregated discharge onboard tugboats but not on any other vessel classes. On tugboats, the stuffing box is packed with greased flax rings. EPA’s stern tube packing gland effl uent data should be applicable to other vessel classes (if any) that use this same type of ster n tube packing gland and that co llect the resulting wastewater for segregated discharge.

Deck runoff and/or washdown.

Factors contributing to the volume and co mposition of deck runoff and/or washdown include deck equipment and operations, deck surface material, and method of washing the deck (see Section 1.3). Data users shoul d evaluate and compare the ch aracteristics of the vessels sampled for this study to those of other vessels to determine the applicability of EPA’s sampling data. In general, EPA believes that deck opera tions performed on vessels outside the scope of this study differ significantly from those of th e sampled vessels. For example, deck washdown generated by fishing vessels might be applicable only to this industry, part icularly in cases where these vessels are washing significant organic ma terial from fishing ope rations overboard. As another example, only one sampled vessel, a supply boat, is used to s upport the transfer and handling of non-fish cargo. On the other hand, d eck washdown from sampled passenger vessels might apply to other vessels, such as larger t our boats, water taxis, and possibly cruise ships.Chapter 2 – Study Design


## Fish hold effluent (inclu ding both refrigerated seaw ater effluent and ice sl urry) and effluent from the cleaning of fish holds.

Since only commercial fishi ng vessels or tenders use fish holds for storing seafood products or fish, EPA believes th at fish hold effluent discharg es are unique to commercial fishing operations and are not applicable to other vessels.

Graywater.

The graywater sources sampled by EPA for this study are “domestic” in nature, such as sink water from washing hands and dishes, wastew ater from shower stalls, and laundry water from domestic washing machines. EPA cautions the data user against applying these sampling data to non-domestic graywater operations, such as large-scale industrial dishwashing and laundry equipment. In addition, the graywater sources sampled by EPA were discharged immediately upon generation; therefore, these da ta do not represent graywater that has been retained in collection or storage tanks or graywater mixed with sewage. Finally, EPA’s graywater data do not apply to wastewater discharges from f ood waste processing operations, such as food grinders or food pulping systems.

Propulsion and generator engine effluent.

For this study, EPA sampled propulsion and ge nerator effluent from a large number and variety of engines. These include:

 Inboard and outboard.

 Two-stroke and four-stroke.

 Spark ignition and compression ignition.

 Diesel- and gasoline-fueled.

 New and existing.

 Direct cooling systems (raw water directly cools the engine) and indirect cooling systems (raw water cools antifreeze, which cools the engine).

 With and without wet engine exhausts (some raw water is injected into the exhaust to cool and quiet the exhaust).

 Variety of manufacturers, si zes, and engine horsepower.

 Operation at varying engine power levels (i .e., idle, slow troll, half throttle, threequarters throttle, and full thro ttle) depending on vessel use.

EPA also observed a number of vessels, such as tug boats and larger commercial fishing vessels, that use keel-cooled pr opulsion engines and generators. The closed-loop cooling systems used on these engines do not discharge any wastewater.

Based on an evaluation of the engine effluent sampling results, EPA observed significant differences in the nature and composition of discharges from inboard and outboard propulsion engines and from generators. EPA may also ha ve observed differences between diesel- and

65Chapter 2 – Study Design


## gasoline-fueled inboard propulsi on engines; however, the data set was too small to be conclusive. Based on these findings, EPA believes the engine effluent data are applicable only to engines of similar types, specifically inboard propulsion versus out board propulsion versus generators and diesel- versus gasoline-fueled engines.

Firemain systems.

EPA sampled relatively few firemain syst ems for this study. Firefighting equipment requirements are specified by the U.S. Coast Guard and differ by vessel t ype, size, construction (e.g., open decks versus enclosed sp aces with potential to entrap explosives, flammable gases, or vapors), whether or not the vesse l carries passengers for hire, a nd many other factors. Not all vessels within the scope of this study are required to carry firefighting equipment. For those vessels that require firefighti ng equipment, these requirements are often satisfied by carrying hand-portable fire extinguishers rather than firema in systems. For vessels outfitted with firemain systems, the systems are used during emergency and testing. None of the vessels visited by EPA for this study tests its firemain system more frequently than once every two weeks, and none operates its system for secondary purposes such as deck washing. Operating personnel from three tour boats and two tugboats that EPA visited agreed to enga ge their firemain systems for EPA sampling. Most operated wet rather than dr y systems. The resulting sampling data apply primarily to wet-type firemain systems that ar e operated infrequently, with intake provided by surrounding water and without additions to the discharge (e.g., no addition of foam-forming agents).

Firemain System on a Passenger Vessel Firemain System on a Passenger Vessel.

EPA also sampled the firefighting system onboard a fire boat; however, these sam pling data may only apply to fire boats or other vessels equipped with high-pressure/high-volume fire

pumps.

66Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



# CHAPTER 3

A NALYSIS OF DISCHARGES AND POTENTIAL IMP A CT TO

HUMAN HEALTH AND THE ENVIRONMENT

This chapter summarizes the results of the wa stewater characterizati on data for the nine types of vessel discharges sampled from the 61 ve ssels identified in Chapter 2. It includes the characterization of the nature, t ype, and composition of discharges for each class of vessel, as well as other relevant information collected regard ing shipboard processes, equipment, materials, and operations that might contribute to the level or explain the presence of pollutants in these discharges.

This chapter begins with a description of the approach used for the analyses of contaminants in the various discharges of the vess el classes of interest in this sampling program, and the specific procedures used to reduce, presen t, and interpret these data. Each section in the chapter presents and discusses in detail the re sults found for each discharge type selected for
evaluation in the vessel classes of interest and summarizes the ma jor findings for the discharges associated with each major vessel type. The fi nal section discusses an ti-foulant hull coating,
which warrants discussion based on the results of other studies conducted on this discharge type even though EPA did not sample this discharge in this study.



## 3.1 A PPROACH TO 

## A NALYSES



## EPA’s approach was designed to ensure th at the analyses conduc ted under this study would be as comprehensive as possible and provide results that would represent the different vessels and discharges to the gr eatest extent possible. EPA incl uded the discharge data collected from the vessels selected for this study (primary data) and any relevant data collected from other studies (secondary data) (e.g., engi ne effluent from small Armed Forces vessels covered under EPA’s sampling program for the Uniform Nati onal Discharge Standards (UNDS) rulemaking). Where appropriate, EPA also assessed ambient (h arbor) and potable waters at each geographic location where vessels were sampled.

EPA’s analysis attempted to make full use of the primary and secondary data collected for this study, including data collected from ambient (har bor) and source (vessel service 1 

## or city water supply) waters. However, EPA recognizes th at the analyses are based on a limited number of samples; in some cases, on a sample size of fe wer than five. These results should be regarded as preliminary in nature due to statistical considerations related to small sample sizes.

1 

### Service water here means the vessel potable water supply. For study vessels, vessel service water generally originates from municipal water supply rather than produced on board.



## 67Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## EPA also attempted to identify where the anal yses and results from this study could be reasonably extrapolated to vesse ls other than those vessels sa mpled in this study. Many of the discharges are not unique to vessels subject to the P.L. 110- 299 moratorium in terms of the expected pollutants or volume s and may also be found on larg er nonrecreational vessels or
recreational vessels.

3.1.1 Data Reduction and Presentation

EPA compiled the data collected for the nine vessel discharges sampled from the 61 vessels (see Chapter 2, Section 2.2.5.3) into a Microsoft (MS) Access database developed specifically for this study. For each discharge ty pe, EPA reduced the data for summary according to the following procedure.

First, data were retrieved from MS Acce ss by discharge group, using a query developed specifically for this task. The queried data incl uded the analytical resu lt with the corresponding screening benchmark (defined in Section 3.1.3 ) and ambient and source water concentrations. For each discharge gr oup, the queried data were exported to MS Excel, and then resaved as tabdelimited ASCII text (*.txt) files. Record c ounts were compared between the discharge groupfiltered MS Access query and the MS Excel and ASC II files to ensure that data were not lost.

The ASCII data for each discharge group were read into an Interactive Data Language (IDL) (Research Systems Inc., 2003) program that car ried out a series of calculations for each analyte, based on the following algorithm:

1. Identify and average concentrations measur ed for field replicate samples, including replacing below-detection concentrati ons with 1/2 of the reporting limit 2 

## when at least one replicate was detected. 2. Identify and average concentrations measured for laboratory replicat e samples, including replacing below-detection concentrations with 1/2 of the reporting lim it when at least one replicate was detected. 3. Identify and average concentrations measur ed for vessel replicate samples (e.g., multiple deck wash, graywater, engine effluent samp les from a single vessel), including replacing below-detection concentrations with 1/2 of the reporting limit when at least one replicate was detected. 4. Calculate potential hazard quotients (PHQs) by dividing the vessel average concentration by the corresponding screening benchmark, if one was available (see further details provided in Section 3.1.3 ).

2 

### Laboratory analyses for low concentration pollutants report a detection limit (the presence or absence of a pollutant) and a reporting limit (the level at which the concen tration of a pollutant can be quantified with appropriate certainty). Statistical methods often re quire replacement of values that are be low the detection and reporting limits of an analytical method (especially for zero values). EPA has established conventions on how to conduct this replacement. In this study, certain labs were able to provide a reporting limit for only certain analytes, which is not uncommon. For consistency, EPA chose to use a convention of replacing the nondetects with a value of 1⁄2 of the reporting limit. These are referred to as replacement values below.



## 68Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 5. Output vessel-average re sults to a co mma-separated value (CSV) text file.
6. Calculate nonparametric per centiles of the distribution of vessel-average analyte concentrations using the algorithm of H yndman and Fan (2003). Note that belowdetection vessel average concentrations were not replaced at this step.
7. Replace below-detection vessel average concentr ations for those analytes where at least one concentration was detected with 1/2 of the reporting limit. Calculate detected proportion of vessel concentrations for each analyte. 8. Output vessel-average resu lts to a CSV text file. 9. Calculate average discharge group analyte concentrations from the vessel average concentrations, includin g replacement values. 10. Output statistics for each an alyte (number of samples, number and proportion detected, average, and nonparametric percen tiles) to a CSV text file. 11. Read vessel-average results (including re placement) into SYSTAT Version 6.1 (SPSS, 1996) to generate box and density plots for each analyte class (see Section 3.2.1 below). 12. Read these results into MS Excel and then reassemble into a workbook with the database query exported from MS Access. Generate summary data tables from these workbooks. 13. For each discharge category, reproduce by ha nd the data reduction and statistical calculations identified above for two or more randomly selected analytes as a QA procedure.

All discharge-specific analytes summarized in subsequent sections of this chapter are organized into the following major groups: classical pollutants 3 

## , metals, nonylphenols, nutrients, pathogen indicators, semivolatile organic comp ounds, and volatile organic compounds. For each discharge type, the analyte groups are generally presented according to the order of highest expected significance or risk in that specific discharge (e.g., the graywater section begins with pathogen indicators). The specific list of target analytes by gr oup is provided in Appendix D. EPA did not analyze all vessel discharges for all selected analyte groups; see Table 2.2 for target analyte groups by discharge type.

3.1.2 Summary Statistics and Box Plots

This chapter includes, for each analyte gr oup within a specific discharge type (e.g., bilgewater, deck washdown water), tables that summarize the number of samples analyzed, the number of times a specific analyte within an analyte group was detected, the average concentration (when only one sample was analyze d, the average is equal to the measurement),
and additional standard summar y statistics related to the measured analyte concentrations (median, min, max and selected (10 th 

## , 25 th 

## , 75 th 

## , and 90 th 

## ) percentiles). These additional statistics were only calculated when a sufficient number of samples had detected values for any given

3 

### The classical pollutants group of analytes combines seve ral standard water quality parameters such as conductivity, salinity, temperature, etc. with other parameters EPA defines as conventional pollutants (biochemical oxygen demand (BOD), total suspended solids (TSS), pH, fecal coli form, and oil and grease). Fo r convenience, this group also includes other common analytes such as total residual chlorine, or TRC. For simplicity, these conventional and other common analytes and water quality parameters have all been grouped under the term "classical pollutants.”



## 69Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## analyte (usually five detected valu es or greater). In cases where so me of the concentrations of an analyte were reported as nondetect (censored), the concentration of that sample was estimated as 1⁄2 of the reporting limit for purposes of calculating average concentrations 4



## .
In addition to the summary tables, this sect ion includes figures that graphically present the analyte-specific concentrations that were de tected (as well as any replacement values for nondetects) for each analyte group within a discharg e to better identify data trends related to analytes of potential concern. Th ese figures are shown as box and dot plots, with the names of the analytes along the x (independent)-axis and their associated vessel average concentrations along the y(dependent)-
axis.

For box plots, the bottom and top of the box displays the 25 th 

## and 75 th


## percentile concentrations defined as the interquartile range or IQR (i.e., the “box” contains 50 percent of the data values), respectively. The median is displayed as
the horizontal line within the box. The
“whiskers” show the relative distribution of data points outside of the IQR and represent 1.5 times the IQR. Superimposed over each box plot are the actual data points, shown as small open
circles. Circles surr ounded by large circles are outliers greater or less than 1.5 times the IQR. Circles covered by asterisks are outliers greater or less than three times the IQR. What is a Box Plot?

A box plot is a useful, simple statistical tool used to show basic characteristics of a data set. A box plot can show the approximate center of a data set and how those data are spread over a range in values – in this case, a range of concentrations. Below is an example box plot indicative of the type of graphical data display used throughout this chapter.



## 3.1.3 Calculation of Potential Hazard Quotients

To provide a context for the level of cont aminant concentrations presented, EPA used National Recommended Water Quality Criteria (NRWQC) 5 

## and several other benchmarks as a

4 

### See footnote 2.

5 

### National Recommended Water Quality Criteria (NRWQC) include acute (short-term) and chronic (long-term) criteria (toxicity threshold values) for the protection of aq uatic life, as well as Human Health criteria for protection of humans from consumption of contaminated water or contaminated water and aquatic organisms. EPA's most recent compilation of NRWQC (2006) is presented as a summary table containing recommended water quality criteria for the protection of aquatic lif e and human health in surface water fo r approximately 150 pollutants. These criteria are published pursuant to Section 304(a) of the Clean Water Act (CWA) and provide guidance for states and



## 70Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## preliminary screen f or all discharge data with the potential to cause or contribute to the nonattainment of a water quality standard in a given receiving water body. The “screening-level” benchmarks chosen for this purpose are shown in Table 3.1 at the end of this subsection, and generally represent EPA’s most conservative (prot ective) concentration avai lable for the specific analyte of interest. Several “legacy” standards (for BOD, TSS and total phosphorus) are also included with the screening benchmarks. For BOD and TSS, these benchmarks are EPA’s secondary treatment effluent lim its for sewage treatment plants 6 

## . For total phosphorus, the benchmark of 0.1 mg/L is from EPA’s Go ld Book (USEPA, 1986b) and represents a concentration recommended to prevent nuisan ce algal blooms resulti ng from eutrophication in flowing waters. EPA did not consid er it appropriate to apply ecoregi onal nutrient criteria for this project.

EPA’s NRWQC are recommended concentrations of analytes in a water body that are intended to protect human heal th, aquatic organisms and the water body uses from unacceptable effects from exposures to thes e pollutants. The NRWQC are not directly related to analyte concentrations in a discharge for a number of reasons. First, NRWQC not only have a concentration component, but also a duration an d frequency component. S econd, it is not always necessary to meet all water quality criteria within the discharge pipe to pr otect the integrity of a water body (USEPA, 1991). Under EPA’s regul ations at 40 CFR 122.44(d)(1)(ii), when determining whether a discharge causes, has the r easonable potential to cause, or contributes to
an in-stream excursion above a narrative or numeric criteria within a stat e water quality standard, the permitting authority will use pr ocedures that account for, wher e appropriate, the dilution of the effluent in the receiving water. A mixing zone allows for ambient c oncentrations above the
criteria in small areas near outfalls while dilu tion occurs. To ensure mixing zones do not impair the integrity of the water body, th e permitting authority will determine the mixing zone such that it does not cause lethality to pa ssing organisms and, considering likely pathways of exposure, significant human health risks.

tribes to use in adopting water quality sta ndards. EPA’s 2006 NRWQC are available at: http://www.epa.gov/waterscience/criteria/wqctable/ , hereafter referred to as EPA’s 2006 NRWQC.

6 

### Secondary treatment standards for sewage treatment plants were technology-based limits developed in the late 1970s and early 1980s, and are not the same as the wa ter-quality-based criteria in the 2006 NRWQC. Thus, the PHQs for BOD and TSS calculated as de scribed below are not directly compar able to the PHQs based on criteria designed to protect aquatic life or human health but, by design, such standards are imposed to limit ecological impacts.



## 71Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Nevertheless, com paring analyte concentra tions in vessel discharges to NRWQC (or other equivalent screening benchmark) provide s a conservative screen of whether these discharges cause, have the reas onable potential to cause, or c ontribute to nonattainment of the water quality standards in a water body. EPA cal culated hazard quotients (HQs) by dividing the concentration of a particular analyte 7 

## by its corresponding water qua lity criterion or other
benchmark as an initial screen for the discharge-specific water sa mple data. If the concentration of a given analyte in vessel discharge is less than the applicable screeni ng criterion or benchmark values (HQ<1), the discharge would likely not cause, have the reasonable potential to cause, or contribute to nonattainment of a water quality standard based on that value, particularly after considering assimilation and/or dilution by the receiving water. If the HQ value is greater than one, then there is the possibility of ecological or human
health risk as the concentration of a given analyte in vessel discharge is greater than the applicable screening criterion or benchmark values (USEPA, 1997). However, because discharges in this study are measured at the “end of pipe” before being released into a harbor wher e they are subsequently diluted, HQ values of greater than one do not n ecessarily indicate that a discharge po ses a significant risk or would be likely to cause or contribute to a water quality standard exceed ance. Further, the presence of
additional environmental factors such as dissolv ed organic carbon can reduce the toxicity of certain pollutants (e.g., metals and many organi c pollutants) and redu ce the likelihood of ecological or health risk. Because of these additi onal considerations, EPA uses the term potential hazard quotients (PHQs) instead to indicate this difference, as the PHQs are only intended to indicate that a screening benchmark was exceed ed and the discharge thus warrants further consideration regarding the potential to cause or contribute to nonattain ment of water quality
standards 8



## .
Mobile sources such as vessels complicate th e analysis because they discharge into many different water bodies, but in general, great er mixing and dilution would be expected for discharges from vessels than from stationary so urces when they are in motion while discharging. EPA acknowledges that vessel discharges to areas with high vessel traffi c, areas with a low Mitigating Conditions/Circumstances in a Water Body Compared to the volume of a typical harbor, the effluent volume of any particular vessel discharge is small (see Chapter 4). Therefore, even when pollutant concentrations of a particular effluent are high, the total loading of that pollutant on the receiving water of the harbor can be relatively small. Furthermore, most harbors are continually flushed by freshwater and tidal activity. These dilution factors, in addition to the mitigating capacity of saltwater cations and organic matter, may reduce the toxicity of many of these pollutants.

7 

### PHQs were also calculated using replacement values for no ndetected concentrations, so that such results would be represented in the box and scatter plots. Note: all PHQ va lues in box plots that were calculated with replacement values throughout this chapter are circled.

8 

### EPA does not consider a PHQ that excee ds 1 to signal that these discharges pose a potential risk to cause or contribute to the non-attainment of a water quality standard when the P HQ is based on replacement values for nondetected concentrations.



## 72Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## degree of flushing, or impaired water bodies could reduce m ixing and dilution. With these factors in mind and assuming the data from this st udy are representative of th e class of vessels as a whole, a PHQ marginally above a value of 1 is most likely not of significant concern. On the other hand, a PHQ value substantially above 1 (e .g., 10 or 100) may be more likely to be of concern, particularly if the discharge is of signifi cant volume, is in an area of low flushing, is in an area where there is a high degree of vessel traffi c, or is in a waterbody th at is already impaired
or under other stress.

EPA recognizes that one of the key fact ors in evaluating metal toxicity is the bioavailability of the metal to an organism. Exposur e to metals at toxic levels can cause a variety of changes in biochemical, physiological, morphol ogical, and behavioral patterns in aquatic organisms. In the aquatic environment, elevated concentrations of dissolv ed metals can be toxic to many species of algae, crustaceans, and fish. So me metals have a strong tendency to adsorb to suspended organic matter and clay minerals or to precipitate out of so lution, thus removing the metal from the water column. The tendency of a gi ven metal to adsorb to suspended particles is typically controlled by the pH and salinity of the water body, as well as the organic carbon content of the suspended pa rticles. If the metal is highly sorbed to particulate matter, then it is not likely to be in a dissolved form that aquatic organisms can process (i.e., bioavailable) 9



## .

Accordingly, NRWQC for the protection of aqua tic life for metals ar e typically expressed in the dissolved form. Therefore, a high concentr ation of a metal measured in its total form (dissolved and particulate) may not be an accurate representation of its toxic potential to aquatic organisms. In contrast, human health criteria (f or the consumption of organisms) for metals are commonly expressed in the total metal form becau se human exposure to pollutants is assumed to be through the consumption of organisms, where the digestive process is assumed to transform all forms of metals to the dissolved phase, t hus increasing the amount of biologically available
metals. EPA was mindful of this distinction between aquatic life and human health criteria for metals when comparing the dissolved and total metals concentration data in the various discharges to NRWQC and when calculating PHQs using the screening benchmarks. In particular, in considering the potential for vessel discharges to pose a risk to human health, EPA
also noted the likelihood of hu man exposure to such discharg es (e.g., potential for receiving water to be used as drinking water source).

9 

### Note that the bioavailability of metals is a relative term and depends on many factors. For example, particulate metals complexed to suspended organic matter or clay minerals may be recycled into the water column and become bioavailable due to physical resuspension (dredging activities) of bed sediments or bioturbation (the stirring or mixing of sediment particles by benthic animals). Depending on conditions in the water column and microbiological activity within the surficial sediment and overlying water su rface layers, these physical and biological actions might remobilize the metals in the dissolved bioavailable form for potential uptake by aquatic organisms. Likewise, certain benthic organisms called deposit feeders might consume particulate-bound metals and re-release metals via digestion and excretion or introduce metals into the food chain when consumed by predators.



## 73Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## EPA chose to include the major cations calcium , magnesium, potassium and sodium in the metals analysis to furthe r characterize the vess el discharges. As common ions in surface waters, the concentrations of these ions are indicative of the sample matrix (i.e., freshwater, saltwater, brackish water) rather than po llutant loadings. Accordingly, major cation concentrations are typically elevated (up to thr ee orders of magnitude hi gher) relative to other metals included in the metals analysis (e.g., c opper, lead, and zinc). For example, the typical concentrations of major cations in full and partial (brackish) streng th seawater and in freshwater
of various total water hardness le vels are listed in Tables 3.2 and 3.3 below. Major cations are not toxic except at extreme, uncommon levels.

For convenience, data tables for metals in th is chapter segregate th e presentation of major
cation concentration data from that of the other metals to clearly distinguish between the naturally occurring cations and other metals of potential concern in vessel discharges. It is worth noting that many of the samples coll ected for this study consist entire ly or partially of sea water; consequently, these samples can have high concen trations of components (e.g., salts) that can interfere with the analytical measurement of th e chemical of interest. EPA evaluated whether
measured concentrations of selenium and ar senic may have exhibited “positive interference” (i.e., the measured concentration is higher than the actual concentr ation in the sample – see text
box for more technical informati on). EPA found that trace meta l analysis using a conventional ICP-MS-based analytical method ma y have resulted in positive inte rference for some samples of selenium, and to a lesser extent, ar senic. However, for the majority of samples analyzed in this study, either the samples contained few interferen ces (i.e., samples were from freshwater) or alternate instrumentation, which had the capabilit y of minimizing sample in terferences, was used for analyte measurement. Hence, the majority of arsenic and selenium results did not have positive interference. EPA identified the few samples analyzed using the conventional ICP-MS method, which may have yielded artificially high
values for the measured concentration of arsenic and selenium. Therefore, while such positive interferences were
not found to influence the overall findings presented in this study, the
selenium and arsenic concentrations potentially affected by positive
interference are id entified (noted by footnote in each instance) throughout this chapter. Explanation of Possible Positive Interference on Select Arsenic and Selenium Measurements

Positive interference occurs when components of a sample, other than the analyte, affect the measurement of the analyte of interest by yielding an artificially high value. This occurs when components in the sample interfere with the analytical methodology. Some of the components of sea water (e.g., calcium, magnesium, potassium, sodium), are known to cause positive interference with certain trace elements, such as arsenic and selenium. The potential for interference is based on the analytical method and instrumentation used for th e measurement. In these situations, alternate sample preparation or analytical instrumentation may be required to eliminate or reduce sample interferences, in order to maintain analyte sensitivity.



## 74Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Table 3.1. Water Qual ity and Other Benchmark Values Used to Screen the Vessel Discharge Data

Analyte Screening Benchmarks Units Source 1

1,1,2,2-Tetrachloroethane 0.17 μg/L 2006 NRWQC HH W+O
1,1,2-Trichloroethane 0.59 μg/L 2006 NRWQC HH W+O
1,1-Dichloroethene 330 μg/L 2006 NRWQC HH W+O
1,2,4,5-Tetrachlorobenzene 0.97 μg/L 2006 NRWQC HH W+O
1,2,4-Trichlorobenzene 35 μg/L 2006 NRWQC HH W+O
1,2-Dichlorobenzene 420 μg/L 2006 NRWQC HH W+O
1,2-Dichloroethane 0.38 μg/L 2006 NRWQC HH W+O
1,2-Dichloropropane 0.5 μg/L 2006 NRWQC HH W+O
1,2-Diphenyl hydrazine 0.036 μg/L 2006 NRWQC HH W+O
1,3-Dichlorobenzene 320 μg/L 2006 NRWQC HH W+O
1,3-Dichloropropane 0.34 μg/L 2006 NRWQC HH W+O
1,4-Dichlorobenzene 63 μg/L 2006 NRWQC HH W+O
2,3,7,8-TCDD (Dioxin) 5.0E-09 μg/L 2006 NRWQC HH W+O
2,4,5-Trichlorophenol 1800 μg/L 2006 NRWQC HH W+O
2,4,6-Trichlorophenol 1.4 μg/L 2006 NRWQC HH W+O
2,4-Dichlorophenol 77 μg/L 2006 NRWQC HH W+O
2,4-Dimethylphenol 380 μg/L 2006 NRWQC HH W+O
2,4-Dinitrophenol 69 μg/L 2006 NRWQC HH W+O
2,4-Dinitrotoluene 0.11 μg/L 2006 NRWQC HH W+O
2-Chloronaphthalene 1000 μg/L 2006 NRWQC HH W+O
2-Chlorophenol 81 μg/L 2006 NRWQC HH W+O
2-Methyl-4,6-Dinitrophenol 13 μg/L 2006 NRWQC HH W+O
3,3'-Dichlorobenzidine 0.021 μg/L 2006 NRWQC HH W+O
4,4'-DDD 0.00031 μg/L 2006 NRWQC HH Org Only
4,4'-DDE 0.00022 μg/L 2006 NRWQC HH Org Only
4,4'-DDT 0.0010 μg/L 2006 NRWQC CCC
4,6-Dinitro-2-methylphenol 13 μg/L 2006 NRWQC HH W+O

Asbestos 7000000 fibers/L 2006 NRWQC HH W+O
Acenaphthene 670 μg/L 2006 NRWQC HH W+O

Acrolein 6.0 μg/L 2006 NRWQC HH W+O
Acrylonitrile 0.051 μg/L 2006 NRWQC HH W+O

Aldrin 1.3 μg/L 2006 NRWQC SW CMC
Alkalinity 20000 μg/L 2006 NRWQC FW CCC
alpha-BHC 0.0026 μg/L 2006 NRWQC HH W+O
alpha-Endosulfan 0.0087 μg/L 2006 NRWQC SW CCC
Aluminum, Total 87 μg/L 2006 NRWQC FW CCC
Ammonia As Nitrogen (NH3-N) 1.2 mg/L 2006 NRWQC SW CCC

Anthracene 8300 μg/L 2006 NRWQC HH W+O
Antimony, Total 5.6 μg/L 2006 NRWQC HH W+O
Arsenic, Total 0.018 μg/L 2006 NRWQC HH W+O
Arsenic, Dissolved 36 μg/L 2006 NRWQC SW CCC
Barium, Total 1000 μg/L 2006 NRWQC HH W+O

Benzene 2.2 μg/L 2006 NRWQC HH W+O

Benzidine 0.000086 μg/L 2006 NRWQC HH W+O



## 75Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment

Screening Source 1 Analyte Units Benchmarks Benzo(a)Anthracene 0.0038 μg/L 2006 NRWQC HH W+O
Benzo(a)Fluoranthene 0.0038 μg/L 2006 NRWQC HH W+O
Benzo(a)pyrene 0.0038 μg/L 2006 NRWQC HH W+O
Benzo(b)fluoranthene 0.0038 μg/L 2006 NRWQC HH W+O
Benzo(k)Fluoranthene 0.0038 μg/L 2006 NRWQC HH W+O

beta-BHC 0.0091 μg/L 2006 NRWQC HH W+O

beta-Endosulfan 0.0087 μg/L 2006 NRWQC SW CCC
Biochemical Oxygen Demand (BOD) 30 mg/L 1984 Secondary Treatment Effluent Limits
Bis (2-Chloroethyl) ether 0.030 μg/L 2006 NRWQC HH W+O
Bis (2-chloroisopropyl)ether 1400 μg/L 2006 NRWQC HH W+O
Bis(2-Chloroethyl)ether 0.030 μg/L 2006 NRWQC HH W+O
Bis(2-Ethylhexyl) phthalate 1.2 μg/L 2006 NRWQC HH W+O

Bromodichloromethane 0.55 μg/L 2006 NRWQC HH W+O

Bromoform 4.3 μg/L 2006 NRWQC HH W+O

Bromomethane 47 μg/L 2006 NRWQC HH W+O
Butyl benzyl Phthalate 1500 μg/L 2006 NRWQC HH W+O
Cadmium, Dissolved 0.25 μg/L 2006 NRWQC FW CCC

Carbon tetrachloride 0.23 μg/L 2006 NRWQC HH W+O

Chlordane 0.0040 μg/L 2006 NRWQC SW CCC

Chloride 230000 μg/L 2006 NRWQC FW CCC

Chlorobenzene 130 μg/L 2006 NRWQC HH W+O

Dibromochloromethane 0.40 μg/L 2006 NRWQC HH W+O

Chloroform 5.7 μg/L 2006 NRWQC HH W+O
Chlorophenoxy Herbicide (2,4,5,-TP) 10 μg/L 2006 NRWQC HH W+O
Chlorophenoxy Herbicide (2,4-D) 100 μg/L 2006 NRWQC HH W+O
Chloropyrifos 0.0056 μg/L 2006 NRWQC SW CCC
Chromium, Dissolved 11 μg/L 2006 NRWQC FW CCC
Chrysene 0.0038 μg/L 2006 NRWQC HH W+O
Copper, Dissolved 3.1 μg/L 2006 NRWQC SW CCC
Copper, Total 1300 μg/L 2006 NRWQC HH W+O
Cyanide 1.0 μg/L 2006 NRWQC SW CMC

Demeton 0.10 μg/L 2006 NRWQC FW and SW CCC

Diazinon 0.17 μg/L 2006 NRWQC FW CMC and CCC
Dibenz(a,h)Anthracene 0.0038 μg/L 2006 NRWQC HH W+O

Chlorodibromomethane 0.40 μg/L 2006 NRWQC HH W+O

Dichlorobromomethane 0.55 μg/L 2006 NRWQC HH W+O

Dieldrin 0.0019 μg/L 2006 NRWQC SW CCC
Diethyl Phthalate 17000 μg/L 2006 NRWQC HH W+O
Dimethyl phthalate 270000 μg/L 2006 NRWQC HH W+O
Di-n-butyl phthalate 2000 μg/L 2006 NRWQC HH W+O
Dinitrophenols 69 μg/L 2006 NRWQC HH W+O
E. Coli by MPN 126 MPN/100 ml 1986 NRWQC B FW

Endosulfan Sulfate 62 μg/L 2006 NRWQC HH W+O

Endrin 0.0023 μg/L 2006 NRWQC SW CCC
Endrin Aldehyde 0.29 μg/L 2006 NRWQC HH W+O
Enterococci by MPN 33 MPN/100 ml 1986 NRWQC B FW
Ether, Bis(Chloromethyl) 0.00010 μg/L 2006 NRWQC HH W+O
Ethylbenzene 530 μg/L 2006 NRWQC HH W+O



## 76Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment

Screening Source 1 Analyte Units Benchmarks Fecal Coliform by MF 14 MPN/100 ml 1976 QCW SH

Fluoranthene 130 μg/L 2006 NRWQC HH W+O

Fluorene 1100 μg/L 2006 NRWQC HH W+O
Gamma-BHC (Lindane) 0.16 μg/L 2006 NRWQC SW CMC

Guthion 0.010 μg/L 2006 NRWQC FW and SW CCC
Heptachlor 0.0036 μg/L 2006 NRWQC SW CCC
Heptachlor Epoxide 0.0036 μg/L 2006 NRWQC SW CCC

Hexachlorobenzene 0.00028 μg/L 2006 NRWQC HH W+O

Hexachlorobutadiene 0.44 μg/L 2006 NRWQC HH W+O
Hexachlorocyclo-hexane-Technical 0.0123 μg/L 2006 NRWQC HH W+O
Hexachlorocyclopentadiene 40 μg/L 2006 NRWQC HH W+O

Hexachloroethane 1.4 μg/L 2006 NRWQC HH W+O
Hexane Extractable Material (HEM) 15 mg/L MARPOL 73/78
Ideno(1,2,3-cd)Pyrene 0.0038 μg/L 2006 NRWQC HH W+O
Iron, Total 300 μg/L 2006 NRWQC HH W+O
Isophorone 35 μg/L 2006 NRWQC HH W+O
Lead, Dissolved 2.5 μg/L 2006 NRWQC FW CCC

Malathion 0.1 μg/L 2006 NRWQC FW and SW CCC
Manganese 50 μg/L 2006 NRWQC HH W+O
Mercury 0.77 μg/L 2006 NRWQC FW CCC
Methoxychlor 0.03 μg/L 2006 NRWQC SW CCC
Methylene chloride 4.6 μg/L 2006 NRWQC HH W+O

Mirex 0.001 μg/L 2006 NRWQC FW and SW CCC
Nickel, Dissolved 8.2 μg/L 2006 NRWQC SW CCC
Nickel, Total 610 μg/L 2006 NRWQC HH W+O

Nitrates 10000 μg/L 2006 NRWQC HH W+O

Nitrobenzene 17 μg/L 2006 NRWQC HH W+O

Nitrosamines 0.0008 μg/L 2006 NRWQC HH W+O
Nitrosodibutylamine,N 0.0063 μg/L 2006 NRWQC HH W+O
Nitrosodiethylamine,N 0.0008 μg/L 2006 NRWQC HH W+O
Nitrosopyrrolidine,N 0.016 μg/L 2006 NRWQC HH W+O
N-Nitroso Di-n-propylamine 0.005 μg/L 2006 NRWQC HH W+O
N-Nitrosodimethylamine 0.00069 μg/L 2006 NRWQC HH W+O
N-Nitrosodiphenylamine 3.3 μg/L 2006 NRWQC HH W+O

Parathion 0.013 μg/L 2006 NRWQC FW CCC

Pentachlorobenzene 1.4 μg/L 2006 NRWQC HH W+O
Pentachlorophenol 7.9 μg/L 2006 NRWQC SW CCC

Phenol 21000 μg/L 2006 NRWQC HH W+O
Phorphorus (as phosphate) 0.1 mg/L EPA 1986 Goldbook
Polychlorinated Biphenyls (PCBs) 0.000064 μg/L 2006 NRWQC HH W+O
Pyrene 830 μg/L 2006 NRWQC HH W+O
Selenium, Dissolved 5 μg/L 2006 NRWQC FW CCC
Selenium, Total 170 μg/L 2006 NRWQC HH W+O
Silica Gel Treated HEM (SGT-HEM) 15 mg/L MARPOL 73/78
Silver, Dissolved 1.9 μg/L 2006 NRWQC SW CMC
Solids Dissolved and Salinity 250000 μg/L 2006 NRWQC HH W+O
Sulfide-Hydrogen Sulfide 0.002 mg/L 2006 NRWQC FW and SW CCC

Tetrachloroethene 0.69 μg/L 2006 NRWQC HH W+O



## 77Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment

Screening Source 1 Analyte Units Benchmarks Thallium, Total 0.24 μg/L 2006 NRWQC HH W+O

Toluene 1300 μg/L 2006 NRWQC HH W+O
Total Nonylphenols 1.7 μg/L 2006 NRWQC SW CCC
Total Phosphorus 0.1 mg/L 1986 NRWQC Total Polychlorinated Biphenyls 0.000064 μg/L 2006 NRWQC HH Org Only Total Suspended Solids (TSS) 30 mg/L 1984 Secondary Treatment Effluent Limits
Total Residual Chlorine (TRC) 0.0075 mg/L 2006 NRWQC SW CCC
Toxaphene 0.0002 μg/L 2006 NRWQC FW and SW CCC
trans-1,2-Dichloroethene 140 μg/L 2006 NRWQC HH W+O
Tributyltin (TBT) 0.0074 μg/L 2006 NRWQC SW CCC

Trichloroethene 2.5 μg/L 2006 NRWQC HH W+O
Vinyl chloride 0.025 μg/L 2006 NRWQC HH W+O
Zinc, Dissolved 81 μg/L 2006 NRWQC SW CCC
Zinc, Total 7400 μg/L 2006 NRWQC HH W+O (1) Sources: MARPOL 73/78: International Convention for the Prevention of Pollution From Ships, 1973 as modified by the Protocol of 1978 (MARPOL 73/88, 1978). 1976 QCW SH (shellfish harvesting): Note MPN is most probable number and approximates the unit of measure for fecal coliform in this study of CFU (colony forming units) (USEPA, 1976). 1984 Secondary Treatment Effluent Limits: 49 FR 37006, Sept. 20, 1984. 1986 NRWQC B FW (bathing (full body contact) re creational waters – fresh water): (USEPA, 1986). Quality Criteria for Water 1986 (Goldbook) (USEPA, 1986b). 2006 NRWQC FW CCC (freshwater chronic): (USEPA, 2006). 2006 NRWQC SW CCC (saltwater chronic) (USEPA, 2006). 2006 NRWQC SW CMC (saltwater acute) (USEPA, 2006). 2006 NRWQC HH Org Only (human health for the consumption of organism only) (USEPA, 2006). 2006 NRWQC HH W+O (human health for the consumption of water + organism) (USEPA, 2006).



## Table 3.2. Major Cation Concentrations in Seawater

Seawater Salinity Level Calcium, mg/L Magnesium, mg/L Potassium, mg/L Sodium, mg/L Full Strength 1 

### (35 ppt salinity) 400 1,350 380 10,500
Brackish 2 

### (10 ppt salinity) 114 386 109 3,000 (1) Source: Mowka, 2009. (2) Calculated from full strength seawater concentrations, assuming dilution by ion-free water.



## Table 3.3. Major Cation Concentrations in Freshwater

Freshwater Hardness Level Calcium, mg/L Magnesium, mg/L Potassium, mg/L Sodium, mg/L

Soft (40-48 mg CaCO 3 

### /L) 1 

### 6.99 6.06 1.05 13.1 Moderately Hard (80-100 mg CaCO 3 

### /L) 1 

### 14.0 12.1 2.10 26.3 Hard (160-180 mg CaCO 3 

### /L) 1 

### 27.9 24.2 4.20 52.5 (1) Source: USEPA, 2007.



## 78Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2 C HARACTERIZATION OF 

## D ISCHARGES



## Each subsection of Section 3.2 presents in detail the obser ve d results for the discharge types selected for evaluation in the study vessels: bilgewater; stern tube packing gland effluent; deck runoff and/or washdown; fi sh hold effluent (both refrigera ted seawater effluent and ice slurry) and effluent from th e cleaning of fish holds; gray water; propulsion (inboard and outboard) and generator engine effluent; and disc harges from firemain systems. Tables and figures are presented at the end of each subsection.

3.2.1 Bilgewater

Bilgewater can be found on board every vessel a nd describes the water that collects in the bottom of a vessel. This water may be from rough seas, rain, minor leaks in the hull or stuffing box, etc. Depending on the ship's design and function, bilgewater sometimes contains contaminants such as oil, fuel, graywater, detergents, solvents, chemicals, pitch, and particulates. For this study, EPA collected bilgewater sample s from seven vessels: two tow/salvage vessels, two water taxis, one longline fishing vessel, one shrimping vessel, and one tour boat.

Based on data and field observations from EPA’s vessel sampling program, as well as information from secondary data sources, EPA estimates many commercial vessels generate, on average, between 10 and 15 gallons per day (gpd ) of bilgewater depending on the vessels’ configuration and intended use; however, EPA noted that vessels might generate as little as 2 gallons of bilgewater or as much as 750 gallons of bilgewater per day. For vessels such as small tow/salvage vessels or water taxis with open bow s, bilgewater pump-out can occur frequently throughout the day, resulting in sm all volumes during each pump-out cycle (1-2 gallons). Larger vessels such as commercial fishing boats are like ly to pump less frequently due to larger storage capacity in the bilge; however, the bilgewater discha rge volume can be hundreds of gallons. For example, EPA noted that a 26-f oot, center console Boston Whaler being used as a tow/salvage vessel had accumulated only 2 gallons of bilgew ater following a tow activity. However, a 62- foot shrimp boat sampled by EPA in the Gulf of Mexico discharged approximately 750 gallons of bilgewater during the daily pump-out.

In general, the volume of bilgewater ge nerated by commercial fishing boats and commercial vessels depends on the following factors:

 Hull and deck construction

 Vessel size

 Precipitation

 Frequency of deck cleaning

 Amount of spray re aching the deck(s)

 Accidental spills

 Integrity of hull and below-deck piping systems

 Potential for condensate formation in below-deck areas.

79Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Commercial vessels with open bow and st ern areas (e.g., commercial fishing and tow/salvage vessels) have relativel y large deck areas that are e xposed to precipitation, spray, and cleaning water, which results in greater bilgewat er volumes compared to vessels such as tour boats or water taxis that have less exposed deck. Other sources that c ontribute to bilgewater
onboard commercial vessels include small leaks in potable water, graywater and sewage piping systems, and condensates from the interior of the hull or refrigeration systems. The volume of these additional bilgewater sources is also highly vessel-specific.

In this vessel sampling program, EPA collect ed single grab samples of bilgewater discharge from selected vessels fo r laboratory analysis. The results of the analysis were intended to be representative of bilgewater pollutan t concentrations over th e range of normal vessel operations. Collecting bilgewater samples proved difficult for EPA for a number of reasons including: (1) automatic bilge pumps would disc harge insufficient volumes of bilgewater in a single operating cycle, (2) vessel operators were generally reluctant to discharge bilgewater for fear of exceeding existing CWA § 311 requireme nts (oily discharges), and (3) sampling was often impractical because bilgewater was typicall y discharged via thru-hull openings located at
or near the vessel’s waterline.

Bilgewater samples were analyzed for a wi de range of pollutants including metals, classical pollutants, pathogen indicators, nutri ents, semivolatile and vol atile organic compounds, and nonylphenols. Results for each class of po llutant are presented and discussed in the following subsections.

3.2.1.1 Metals

Bilgewater samples were analyzed for dissolved 10 

## and total (dissolved plus particulate) concentrations of metals. The analytical resu lts are summarized in Table 3.1.1 for dissolved
metals and in Table 3.1.2 for total metals that we re detected in at leas t one bilgewater sample. The following metals were measured in all bilgewater samples:

 Total aluminum

 Total arsenic 11



##  Dissolved and total barium

 Dissolved and total calcium

 Dissolved and total copper

 Dissolved and total magnesium

 Dissolved and total manganese

 Dissolved and total potassium

10 

### Dissolved metals were obtained by filtering the water sample.

11 

### Note that for three of the seven bilgewater sample s analyzed, EPA suspects that the measured arsenic concentrations are likely to be overestimated due to the positive interference of majo r cations in seawater (see discussion on page 74).



## 80Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



##  Dissolved and tota l sodium

 Dissolved and total zinc.

Concentrations of other metals were measured in 50 percent or more of the samples analyzed:

 Dissolved aluminum

 Dissolved arsenic 12



##  Dissolved and total chromium

 Total iron

 Total lead

 Dissolved and total nickel

 Dissolved and total selenium 13



## .

Figure 3.1.1 presents the range
of concentrations measured for dissolved metals in the bilgewater samples. The plots show that dissolved metals concentrations range over six orders of magnitude. Calcium, magnesium, potassium and sodium
were the dissolved metals measured at the highest concentrations. As discussed in Chapter 1 and Section 3.1.3 , these cations naturally occur in seawater and
their levels in the dis charges are similar
to levels seen in ambient seawater. As many discharges use ambient water for onboard activities, and spray would contribute to other discharges, it was not unexpected to find these levels of cations in the bilgewater samples as most vessels were sampled in coastal areas. At these concentrations, these cations are generally not toxic to aq uatic organisms, which is why there there are no NRWQC for these metals , and therefore, no PHQs were calculated (see
Section 3.1.3 for additional explanation). Dissolved aluminum, barium, copper, manganese,
seleni um 13 

## and zinc were also measured at relativel y high concentrations (tens to hundreds of Dissolved versus Total Metals EPA recommends using dissolved metal to set and measure compliance with water quality standards because dissolved metal more closely approximates the bioavailable fraction of metal in the water column than does total recoverable metal (USEPA, 1993). EPA considers that the primary mechanism for toxicity to organisms that live in the water column to be adsorption to or uptake across the respiratory surfaces of aquatic organisms (i.e., the gills) as we ll as the carapace of certain invertebrates, and this physiological process requires metal to be in a dissolved form. This is not to suggest that particulate metals are nontoxic; rather, because toxicity of particulate metals are primar ily restricted to direct ingestion via dietary exposure, they are less toxic overall compared to dissolved metal (USEPA, 1996). There are exceptions, however, particularly for bottom feeding organisms, and for metals that bioaccumulate (also see footnote in Section 3.1.3 r egarding physical and biological recycling of particulate metals). Dissolved metal is operationally defined as that which passes through a 0.45- μm or a 0.40-μm filter and particulate metal is operationally defined as total recoverable metal minus dissolved metal. EPA typically uses the dissolved fraction, or f d 

### , to express the fraction of the total chemical concentration in water that is dissolved. To calculate f d 

### , divide the dissolved concentration by the total concentration. A chemical that is entirely in the dissolved phase has a f d 

### of 1, while a chemical that is entirely in the particulate phase has a f d 

### of 0.

12 

### Note that for three of the six bilgewater samples wh ere dissolved arsenic was detected, EPA suspects that the measured arsenic concentrations are likely to be overestim ated due to positive interference (see discussion on page 74)

13 

### Note: EPA suspects positive interference for all concentrat ions of total and dissolved selenium detected in bilgewater samples (see discussion on page 74). Reported values could be entirely due to this positive interference.



## 81Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## μg/L) in mo st bilgewater samples; dissolved arsenic 14 

## and iron were also measured at concentrations greater than 100 μg/L in individual samples. Among the vessels from which bilgewater was sampled, a tow/salvage boat had the highest concentrations of the most dissolved metals (seven analytes), while the wa ter taxi had only one dissolved metal.

Figure 3.1.2 shows the total meta ls concentrations in the bilgewater samples. The box plots show that the relative ranges of total me tals concentrations are comparable to the concentrations of dissolved metals. Among the ve ssels from which bilgewater was sampled, the shrimper had the highest concentrations of the mo st total metals (11), while the longliner and the water taxi had the fewest (one each). In general, total concentrations for each metal are similar to or slightly higher than the dissolved concentrat ions. To explore this relationship further, EPA calculated the average dissolved fraction f d 

## of each metal in the bilg ewater samples to better understand the potential for aquatic organism im pacts. The metals with the highest average dissolved fractions (f d 

## > 90 percent) included barium, calci um, magnesium, potassium, selenium (see footnote 13 ), and zinc. Metals having intermediate average dissolved fractions (90 percent >
f d 

## > 50 percent) included an timony, arsenic (see footnotes 11 and 12 ), cadmium, chromium, cobalt, copper, iron, ma nganese, and nickel. Al uminum, lead, and vanadium had the lowest average dissolved fractions (f d 

## < 50 percent).

Figure 3.1.3 shows the distributions of PHQs based on the most conservative screening
benchmark for each of the dissolved metals. Per Section 3.1.3 above, points on this plot above the dashed line (demarcating a PHQ of one) indi c ate a dissolved metal concentration exceeding the benchmark; two of the disso lved metals (cadmium and c opper) have PHQs that include values greater than 10, indicating that the measured concentrations were one (or more) order of magnitude greater than the screening benchmar k. EPA suspects that the high PHQs for a third dissolved metal in this discharge (selenium) was elevated due to positive interference due to the major seawater cations in these samples. Th e highest PHQ (113) was for dissolved copper, measured in the bilgewater sample from the tour boat. EPA also found PHQs exceeding one for dissolved arsenic, chromium, lead, nickel, and zi nc, bringing to eight th e number of dissolved metals that exceeded the most stringent 2006 NRWQC in one or more bilgewater sample. Dissolved copper concentrations, ranging from 6.6 to 350 μg/L, exceeded the saltwater acute (4.8 μg/L) and chronic (3.1 μg/L) cr iteria in all seven bilgewater samples; concentrations in all but one bilgewater sample also exceeded the fr eshwater acute (13 μg/L ) and chronic (9 μg/L) criteria. The single elevated dissolved cadmium concentration (10 μg/L) exceeded the freshwater acute (2.0 μg/L) and chronic (0.25 μg/L) criteria, and th e saltwater chronic (8.8 μg/L) criterion. In addition, the highest dissolved arsenic c oncentration (230 μg/L) exceeded the 36 μg/L
saltwater chronic criterion. For the other dissolved metals (chromium, lead, nickel, and zinc),

14 

### As noted in footnote 11, some dissolved arsenic samples may experience positive inte rference. Dissolved arsenic samples not suspected of having positive interference incl ude the measured dissolved arsenic concentration of 230 μg/L for the tow/salvage vessel, the dissolved arsenic concentration of 10 μg/L for the tour boat as well as the relatively low dissolved arsenic concentration of 1.1 μg/L for a sample of bilgewater from a tow/salvage vessel.



## 82Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## concentrations in one or more bilgew ater sample s exceeded saltwater and/or freshwater criteria, although in each of these cases th e PHQs were less than five.

Three of the total metals (aluminum, arsenic 15 

## , and iron) exceeded the most stringent 2006 NRWQC 16 

## in one or more bilgewater samples as shown in Figure 3.1.4. PHQs for total arsenic (those not suspected of significant positive interference) ranged from 306 to 16,170. The total arsenic concentrations in samples associat ed with these PHQs a ll greatly exceeded the human health criterion for consumption of wate r plus organism of 0.018 μg/L, as well as the human health criterion for organism consumpti on alone, 0.14 μg/L. PHQs for aluminum and iron
did not exceed 11. Five of the seven total aluminum concentrations measured in bilgewater (at concentrations ranging from 332 to 940 μg/L) exceed ed the freshwater chronic criterion (87 μg/L, expressed as total recove rable metal). For total iron, con centrations in two of three bilgewater samples exceeded the human health crit erion for water plus organism consumption of 300 μg/L; PHQs for total iron ranged from 0.17 to 6.3.

To further evaluate the significance of the di ssolved and total metals concentrations in the bilgewater samples, EPA compared them to ambi ent dissolved and total metal concentrations in surface water samples collected near the vessels . This was done because surface water might occasionally leak into certain vessel bilges, be used onboard the vessel, or splash onto the vessel and drain into the bilge. In these cases, the con centrations of metals (as well as other analytes) measured in the bilgewater samples might be similar to or significantly influenced by the ambient concentrations. Indeed, EPA found that the concentrations of many of the metals (including aluminum, barium, calcium, chromi um, magnesium, manganese, nickel, potassium, selenium, and sodium) measured in multiple bilg ewater samples were no more than double the ambient concentrations. The similarity in the concentrations of many of these metals in bilgewater and ambient samples suggests that so me proportion of the water sampled in the vessel bilges may be from ambient water. It is le ss clear whether the si gnificant background ambient metals concentrations in the sampled harbors re flect the loading from the cumulative discharges of the many vessels that operate there, or load ings from other point and/or nonpoint pollutant
sources to these water bodies.

On the other hand, the highest concentrations of some of the dissolv ed and total metals measured in bilgewater were substantially elevated a bove the corresponding ambient concentrations. For dissolved copper, the ambient concentration that accompanied the highest bilgewater concentration (350 μg/L from a tour boat) was below the detection limit. The next two highest dissolved copper con centrations in bilgewater (119 and 120 μg/L) were from water taxis with a somewhat higher correspondi ng ambient concentration of 24 μg/L.

15 

### Measured total arsenic concentration where no positive in terference is evident include 291 μg/L for a tow/salvage vessel, 19 and 5.5 μg/L for the tour boat and longliner fi shing vessel, respectively, and 1.3 μg/L for a sample of bilgewater from a tow/salvage vessel.

16 

### PHQs for total metals are based on NRWQC for human health and not aquatic life, as stated in Section 3.1.3.



## 83Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 84 For dissolved aluminum, the ambient con centration that accompanied the highest bilgewater concentration (520 μg/L from the long liner) was 870 μg/L; in this case, and several others, even the highest concen tration for a metal in bilgewat er was exceeded by the ambient
concentration.

The data for total metals also demonstrate considerable variability in the relationships between bilgewater and ambient concentrations . The highest total arse nic concentration in bilgewater (291 μg/L from a tow/salvag e boat) exceeded the corresponding ambient concentration (12 μg/L) by a considerable margin . The ambient concentration that accompanied the next highest total arsenic concentration in bilgewater (32 μg/L from the shrimper) was a comparable 29 μg/L, although this moderately high concentration of total arsenic measured in the bilgewater sample from the shrimper is likely an overestimate due to positive interference (see discussion on page 74 ).

The results s hown here illustrate that rela tionships between metals concentrations in bilgewater and ambient samples are quite variable, even for the hi ghest concentrations of metals measured in bilgewater. EPA acknowledges that such variability could be due to type of bilgewater production and dilution onboard. For example, a shrimper might have used a
substantial amount of ambient water for washdown as compared to a tow boat, and thus, dilute what might be a similar actual bilge sample ab sent the washdown. Clearly the potential for metals in bilgewater discharges to pollute receiving waters may be overe stimated if the ambient
metals concentrations and other consideratio ns (type and dilution of bilgewater) are not appropriately considered.

In summary, metals were frequently de tected in bilgewater samples. EPA found relatively high concentrations of a number of disso lved and total metals in these samples. Total arsenic and dissolved copper c oncentrations were significant ly elevated above the most conservative screening benchmarks in individual samples, with P HQ values from greater than 10 to over 1,000. Dissolved cadmium concentrations in a single bilgewater sample also generated PHQs in this range. For these and other metals (including total aluminum and iron and dissolved chromium, lead, nickel, and zinc), concentrations measured in one or several bilgewater samples
exceeded saltwater and/or freshwat er criteria. EPA found that the concentrations of many of the metals measured in bilgewater samples (excep t for dissolved copper and total arsenic) were comparable to the ambient receiving water concentrations.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.1.1. Results of Bilgewater Sample Analyses for Dissolved Metals1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Heavy and Other MetalsAluminumμg/L7686150379.7420520520NAAntimonyμg/L51200.660.651.31.3NAArsenic3μg/L768641101.12123023036Bariumμg/L551004943383839626464NACadmiumμg/L71141.910100.25Chromiumμg/L7571121.617565611Cobaltμg/L52401.01.82.52.5NACopperμg/L77100100566.66.6251203503503.1Ironμg/L51207587170170NALeadμg/L73432.34.27.27.22.5Manganeseμg/L7710034283.93.913507979NANickelμg/L76869.28.84.71415158.2Selenium4μg/L745724303657575Vanadiumμg/L51200.620.551.11.1NAZincμg/L7710013010053537219025025081Cationic MetalsCalciumμg/L771007600076000330003300047000100000140000140000NAMagnesiumμg/L771001800001800008300830014000310000420000420000NAPotassiumμg/L551006700065000980098003700098000120000120000NASodiumμg/L5510014000001400000120000120000730000200000027000002700000NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.(3) See footnotes11and12.(4) See footnote13.85Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment86Table 3.1.2. Results of Bilgewater Sample Analyses for Total Metals1AnalyteUnitsNo.samplesNo.detectedDetectedproportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Heavy and Other MetalsAluminumμg/L7710037033026262864094094087Antimonyμg/L51201.30.651.31.35.6Arsenic3μg/L7710053121.31.35.5322902900.018Bariumμg/L5510050443838386667671000Cadmiumμg/L71142.61212NAChromiumμg/L7686253.52379696NACobaltμg/L51201.30.71.41.4NACopperμg/L771001501308.58.5502104304301300Ironμg/L5360520250110019001900300Leadμg/L76869.67.52.3182626NAManganeseμg/L7710053527.47.437799797100Nickelμg/L7686129.46.2172424610Selenium4μg/L74572525386666170Vanadiumμg/L52402.61.41.71.7NAZincμg/L77100160875656722603603607400Cationic MetalsCalciumμg/L771007600077000360003600047000110000130000130000NAMagnesiumμg/L771001800001800009200920014000310000390000390000NAPotassiumμg/L5510068000650009600960037000100000130000130000NASodiumμg/L5510014000001400000120000120000740000200000026000002600000NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.(3) See footnotes11and12.(4) See footnote13.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 87 Figure 3.1.1. Box and Dot Density Plot of Diss olved Metals Concentrations Measured in Samples of Bilgewater (Note: As discussed in footnotes 12 and 13 , all but possibly one of the bilgewat er samp les analyzed for dissolved selenium and three of the bilgewater samples analyzed for dissolved arsenic may be elevated due to positive interference. The measured dissolved arsenic concentratio n of 230 μg/L for the tow/salvage vessel and measured dissolved arsenic concentration of 10 μg/L for the tour boat are not expected to have had positive interference)

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## 88 Figure 3.1.2. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Bilgewater (Note: As discussed in footnotes 11 and 13 , all but one of the bilgewater samples analyzed for total selenium and three of the bilgewater samples analyzed for total arsenic may be elevated due to probability of positive interference. Exceptions are the total arsenic concentration of 291 μg/L for the tow/salvage vessel, concentrations of 19 and 5.5 μg/L for the tour boat and longliner fishing vessel, resp ectively, as well as the concentration of 1.3 μg/L for a sample of bilgewater from a tow/salvage vessel). A

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## 89 Figure 3.1.3. Box and Dot Density Plot of Pote ntial Hazard Quotients for Dissolved Metals in Samples of Bilgewater (Note: Values circled here and through out the rest of this chapter indicat e PHQs calculated based on replacement values for non-detects. Non-det ect (censored) concentrations were replaced with 1⁄2 of the reporting limit for use in these plots. Also, as discussed in footnotes 11 and 13 , all but one of the bilgewater samples analyzed for total selen i um and three of the bilgewater samples analyzed for total arsenic may be elevated due to probability of positive interference). A

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## 90 Figure 3.1.4. Box and Dot Density Plot of Potential Hazard Quotients f 

## or Total Metals in Samples of Bilgewater (Note: Replacement values for non-detects are circled. Also, as discussed in footnotes 11 and 13, all but one of the bilgewater samples analyzed for total selenium and three of the bilgewater samples analy zed for total arsenic may be elevated due to probability of positive interference). A

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## 3.2.1.2 Classical Po llutants

Bilgewater samples were analyzed for 14 classical pollutants (see Table 3.1.3). These pollutants include measurements that are qualitatively quite diffe rent: physical properties (pH, temperature, conductivity, salinit y, turbidity, TOC, TSS), oxyge n consumption (BOD and COD), oil and grease (hexane extractable material (H EM) and silica-gel treated hexane extractable material (SGT-HEM)), as well as concentrations of several chemicals (sulfide, DO, TOC and TRC). 17 

## Figure 3.1.5 illustrates the vari ability of the concentrations/values measured for the classical pollutant in bilgewat er. The highest concentrations of BOD, COD and TOC (770, 2970, and 732 mg/L, respectively), as well as HEM, SG T-HEM, and TRC, were measured in a single bilgewater sample from a tow/salvage boat. B OD and TOC concentrations were highly variable among the bilgewater samples, ranging from 2 to 770 mg/L for BOD and from 9 to 730 mg/L for
TOC.

Oil and grease were measured as HEM and petroleum hydrocarbons were measured as
SGT-HEM. HEM and SGT-HEM were detected in all of the bilgewater samples, with concentrations ranging from 1.1 to 43.6 mg/L (H EM) and 1.1 to 18.2 mg/L (SGT-HEM). These concentrations were compared to the existing in ternational and U.S. re gulatory limit of 15 mg/L of oil and grease that can be discharged from a moving ship when within 12 nautical miles from
land 18 

## . Some type of oil collector (s orbent pad, rags, etc.) was used on four of the seven vessels sampled for bilgewater. A single value taken fr om the tow/salvage boat exceeded the 15-mg/L benchmark by threefold. Oil and grease discharges at this concentration are significant enough to cause a visible sheen. The tow/salvage boat had no equipment or management practices in place to remove oil or other pollutants prior to overboard discharge of bilgewater.

Sulfide was detected in two bilgewater sa mples, at concentrations of 0.015 and 0.2 mg/L. These concentrations exceeded the NRWQC of 2 μg/L (0.002 mg/L) by factors of 7.5 to 100. Sulfide (hydrogen sulfide) is a pollutant that is commonly elevated in wa ter distribution systems
as well as sewers. Sulfur-reducing bacteria, which use sulfu r as an energy source, are believed to be the primary producers of large quantit ies of hydrogen sulfide in bilgewater. Ecologically,
these bacteria are common in anaerobic environments (e.g., plumbing systems)

. Sulfur-reducing bacteria are apparently present in at least some of the vessels, because sulfide was not detected in the ambient water sampled at the vessel locations.

Figure 3.1.6 presents box and dot density plot s of the PHQs for classical pollutants. PHQs were calculated for the six classical polluta nts for which benchmarks were available. As this figure shows, all of the detected TRC concentrations ex ceeded the saltwater chronic

17 

### See Section 3.1.1 this chapter for the rationale to use this term for this large group of conventional, nonconventional, and other physico-chemical factors.

18 

### International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL).



## 91Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 92 NRWQC benchmark of 0.0075 mg/L and yielded P HQs ranged from 6.7 to 21. The highest TRC concentration (0.16 mg/L) was measured in a bilg ewater sample collected from a tour boat.

EPA compared classical pollutant concentratio ns in the bilgewater samples to ambient concentrations in surface water samples collected near the vessels. Concen trations of a number of the classical parameters (including conductiv ity, pH, salinity, temperature, and (to a varying degree) turbidity in bilgewater were comparab le with ambient water. This was expected, considering the likelihood of ambi ent water leaking into vessel bilges. The concentration of DO measured in one bilgewater sample (1.8 mg/L in the longliner) was hypoxic (<2 mg/L), although the ambient DO value at this location (Sitka, Alaska) was also very low (1.0 mg/L). TRC
concentrations were elevated at 0.1 mg/L in two of the seven b ilge samples; for the remaining samples, TRC concentrations were comparable be tween bilgewater and ambient samples. For the remaining classical pollutants (BOD, COD, HEM, SGT-HEM, sulfide, TOC, and TSS) the concentrations measured in bilgewater greatly exceeded those measured in ambient samples. BOD concentrations in three of the bilgew ater samples (189, 325, and 770 mg/L) were high enough to be comparable to values typical of raw domestic sewage (110 to 400 mg/L; Metcalf and Eddy, 1979). These three bilgewater sample s also exceed EPA’s secondary treatment effluent limit of 30 mg/L for BOD. COD concentrat ions in four of the bilgewater samples (430, 546, 780, and 2,970 mg/L) were again high enough to compare with values for raw domestic sewage (250 to 1,000 mg/L; Metcalf and Eddy, 1979). These high levels of BOD and COD in bilgewater discharges could potentially cause stress on a wate r body (e.g., where there are many sources of oxygen demand, where there may be limited circulation or flushing, or where the water body is under existing hypoxic or anoxic st ress). Although TSS c oncentrations in bilgewater were not as high as values for raw sewage, four of the bilgewater samples exceeded the 30 mg/L effluent limit for TSS by factors rang ing from 1.2 to 3. EPA realizes that these effluent limits are based upon the high removal ef ficiencies for BOD and TSS that are achievable by land-based sewage treatment plants, and may be overly conservative as benchmarks for vessel discharge. However, as discussed in Section 3.1.3 , the benchmarks are still useful in a screening level analysis as a startin g poi nt for evaluating the potential of these pollutants to cause or contribute to ecological stress on a water body.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.1.3. Results of Bilgewater SampleAnalyses for Classical Pollutants1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Biochemical Oxygen Demand (BOD)mg/L77100190142.02.04.133077077030Chemical Oxygen Demand (COD)mg/L7710074043091919878030003000NAConductivitymS/cm661005.06.90.0170.0170.569.31414NADissolved Oxygenmg/L661005.35.51.81.83.46.91111NAHexane Extractable Material (HEM)mg/L771009.35.21.11.11.27.0444415pHSU771007.27.06.96.96.97.38.08.0NASalinityppt661005.54.50.400.403.18.91313NASilica Gel Treated HEM (SGT-HEM)mg/L771004.42.41.11.11.23.5181815Sulfidemg/L72290.0340.0150.200.200.0020TemperatureC7710020219.09.014272828NATotal Organic Carbon (TOC)mg/L551002001108.98.916440730730NATotal Residual Chlorinemg/L73430.0770.130.160.160.0075Total Suspended Solids (TSS)mg/L7710039383.73.75.571888830TurbidityNTU7710041203.53.55.241160160NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.93Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 94 Figure 3.1.5. Box and Dot Density Plot of Classical Pollutant Concentrations Measured in Samples of Bilgewater



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## 95 Figure 3.1.6. Box and Dot Density Plot of Po tential Hazard Quotients for Classical Parameters in Samples of Bilgewater (Note: Replacement values for non-detects are circled). 

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## 96 3.2.1.3 Pathogen Indicators (Microbiologicals)

Bilgewater samples 19 

## from two commercial fishing ve ssels were analyzed for the pathogen indicator bacteria E. coli , enterococci, and fecal coliform (commercial fishing vessels only) (see Table 3.1.4). E. coli and enterococci were detected in a bilgewater sample collected from a shrimping vessel, and fecal coliform were de tected in bilgewater from two fishing vessels (a longliner and the shrimper).

The NRWQC for pathogen indicators referenc es the bacteria standards in EPA’s 1986 Quality Criteria for Water , commonly known as the Gold Book. NRWQC standards for bacteria

are described in terms of three different water body use criteria: freshwater bathing, marine water bathing, and shellfish harvesting waters.

For each of the pathogen indicators, the lo west NRWQC was exceeded in one of the bilgewater samples. The E. coli value (393 MPN/100 mL) exceeds the freshwater bathing NRWQC of 126 MPN/100 mL. The enterococci va lue (4,100 MPN/100 mL) exceeds the bathing NRWQCs of 33 CFU/100 mL for fr esh water and 35 CFU/100 mL for salt water. One of the two fecal coliform values (118 CFU/100 mL) exceed s the NRWQC of 14 MPN/100 mL for shellfish harvesting 20



## .
Values of the pathogen indicators measured in these bilgewater samples exceed the values measured in nearby ambient surface water samples by factors ranging from 4 (for enterococci) to 15 ( E. coli ), suggesting that leakage or othe r entry of ambient water is not a significant source of these pathogen indicators in bilgewater. EPA is unsure as to the source of pathogen indicators in bilgewater.

19 

### Logistics prevented EPA from delivering all bilgewater sa mples to laboratories within allowable holding times.

20 

### MPN is most probable number and approximates the unit of measure for fecal coliform in this study of CFU (colony forming units).Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.1.4. Results of Bilgewater Sample Analyses for Pathogen Indicators1AnalyteUnits2No.SamplesNo.detectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM3E. ColiMPN/100 ml11100390130EnterococciMPN/100 ml11100410033Fecal ColiformCFU/100 ml22100611204.04.04.012012012014Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) MPN = Most Probable Number; CFU = Colony Forming Units.(3) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.97Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.1.4 Nutrients

Bilgewater sa mples were analyzed for f our nutrient-related parameters: ammonia nitrogen, nitrate/nitrite, tota l Kjeldahl nitrogen (TKN), and total phosphorus (see Table 3.1.5). The box and dot density plots in Figure 3.1.7 i llustrate the variability of the nutrient concentrations measured in bilgewater. Amm onia, TKN and total phosph orus concentrations were elevated in a single bilgewater sample collected from a longliner fishing vessel. The elevated nutrient concentrations may be attributab le to seepage from the/ ice slurry in the fish hold of the longliner. Water cont aining biological material (e.g., fish waste tissues, excreta) might seep down into the bilge compartment, resu lting in an increase in nutrient discharge.

Ammonia is the only nutrient for which there are currently numeric NRWQC. EPA
established these numeric criteria based on ch ronic toxicity to aqua tic life, not nutrient enrichment. An ammonia-nitrogen concentration of 7.6 mg/L, measured in the bilgewater sample from the longliner fishing vessel, exceeded th e NRWQC chronic criteria in both salt water (1.2 mg/L) and fresh water (1.24 mg/L). Three of the five bilgewater samples for total phosphorous exceeded EPA’s 0.1 mg/L 1986 Gold Book criterion. The highest total phosphorus concentration, 13 mg/L, exceeded the benchmar k by a factor of 130. Figure 3.1.8 presents box and dot density plots of the PHQs calculated for the nutrient data.

EPA compared nutrient concentrations in the bilgewater samples to ambient concentrations in surface water samples collected near the vessels. Ammonia was detected in one of the ambient samples at a concentration of 0.11 mg/L, comparable (within a factor of two) to
the concentration in the corres ponding bilgewater sample, 0.13 mg/L . TKN was detected in three ambient samples; in one, the ambient concen tration of 0.60 mg/L marginally exceeded the bilgewater concentration of 0.55 mg/L. However, ambient TKN concentrations were less than the bilgewater concentrations in the other two cases. Fo r total phosphorus, the comparison
showed the concentrations detected in tw o ambient samples were comparable to the corresponding bilgewater concen trations; however, total phosphorus was not detected in the ambient samples corresponding to the three b ilgewater samples having the highest total phosphorus concentrations. Thus, although ambien t nutrient concentratio ns appear to be comparable to the lower concentrations of nutrien ts in bilgewater and ma y be a partial source of these nutrients in some samples, th ey cannot explain the sources of the higher nutrient concentrations measured in other samples.

98Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.1.5. Results of Bilgewater Sample Analyses for Nutrients1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Ammonia As Nitrogen (NH3-N)mg/L54801.70.240.0644.07.67.61.2Nitrate/Nitrite (NO3/NO2-N)mg/L75710.380.180.361.91.9NATotal Kjeldahl Nitrogen (TKN)mg/L55100162.50.550.551.0397373NATotal Phosphorusmg/L551003.00.470.0840.0840.0937.113130.10Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.99Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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100Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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## 101Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 102 3.2.1.5 Semivolatile Organic Compounds (SVOCs)

Bilgewater samples were analyzed for 79 S VOCs. Out of the 79 analytes, 56 were not detected in any of the bilgewater samples. Of the remaining 23 SVOCs, 18 were only detected in a single bilgewater sample and five were found in multiple samples (see Table 3.1.6). Of these, bis(2-ethylhexyl) phth alate was detected in more than 50 per cent of the samples. This SVOC is a
manufactured chemical that is commonly added to plastics to ma ke them flexible and can be found in a variety of products used on vessels such as hoses, tubing, a nd gaskets. Di-n-butyl phthalate, di-n-octyl phthalate, naphthalene, and phe nanthrene were also detected in more than one bilgewater sample. There was no obvious tr end in the occurrence of SVOCs based on the type of vessel sampled.

Figure 3.1.9 presents the range of concentrations measured fo r SVOCs in the bilgewater samples. Concentrations of five SVOCs (2-but oxy ethanol, 2- methyl-n aphthalene, dimethyl phthalate, indole, and naphthalene) exceeded 100 μg /L in single (but not the same) bilgewater samples. It was difficult for EPA to compare the concentration distributions between SVOCs because the majority were detected in a si ngle sample. Bis(2-ethylhexyl) phthalate and phenanthrene concentrations ranged over nearly two orders of magnitude.

The distributions of PHQs, based on the most conservative screening benchmarks, are displayed for each SVOC in Figure 3.1.10. PHQs for two SVOCs, 2,4,6-trichlorophenol and bis(2-ethylhexyl) phthal ate, exceeded the screening threshold of one. The 2,4,6-trichlorophenol concentration (24 μg/L) measured in a single bilg ewater sample from a tour boat exceeded the 1.4 μg/L human health (water and organism consumption) criterion by a factor of 17 21 

## . Bis(2- ethylhexyl) phthalate was detected in four of the seven bilgewater samples, at concentrations that exceeded the 1.2 μg/L human health (water and or ganism consumption) criterion by factors that ranged from 1.1 to 59. As shown in Figure 3.1.10, th e PHQs for four other SVOCs were orders of magnitude less than 1, and therefore, likely pose little risk as po llutants from bilgewater discharges.

SVOCs were detected in two ambient samples, and for these chemicals (bis(2-ethylhexyl) phthalate and Di-n-butyl phthala te) the ambient concentrations were only comparable to the lowest concentrations measured in bilgewater.

21 

### Because of elevated reporting limits for this SVOC in several samples, replacement values for the nondetected concentrations exceed the benchmark (e.g., PHQ >1). However, these values were not based on measured concentrations and are therefore uncertain.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.1.6. Results of BilgewaterSample Analyses for SVOCs1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM22,4,6-Trichlorophenolμg/L71147.024241.42-Butoxy ethanolμg/L11100260NA2-Methylnaphthaleneμg/L51203988180180NA3-Methyl-butanoic acidμg/L1110057NA4-Methyl-pentanoic acidμg/L1110038NABenzeneacetic acidμg/L1110029NABenzenepropanoic acidμg/L1110032NABenzothiazoleμg/L1110045NABis(2-ethylhexyl) phthalateμg/L7457151.42171711.2Cholesterolμg/L1110088NADimethyl phthalateμg/L711424140140270000Di-n-butyl phthalateμg/L72294.01.44.94.92000Di-n-octyl phthalateμg/L72294.13.13.53.5NAHeptadecaneμg/L1110056NAIndoleμg/L11100160NANaphthaleneμg/L73431002.3700700NAn-Hexadecaneμg/L1110039NANonadecaneμg/L1110049NAp-Cresolμg/L51207.78.71717NAPhenanthreneμg/L7229121.36969NAPhenolμg/L71141810010021000Pyreneμg/L71146.83434830Triethyl Phosphateμg/L1110020NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs..103Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 104 Figure 3.1.9. Box and Dot Density Plot of SVOC Concentrations Measured in Samples of Bilgewater SVOCs are identified as follows (replacemen t values for non-detects are circled): (1) 2,4,6-Trichlorophenol (2) 2-Butoxy Ethanol (3) 2-Methylnaphthalene (4) 3-Methyl-Butanoic Acid (5) 4-Methyl-Pentanoic Acid (6) Benzeneacetic Acid (7) Benzenepropanoic Acid (8) Benzothiazole (9) Bis(2-Ethylhexyl) Phthalate (10) Cholesterol (11) Dimethyl Phthalate (12) Di-N-Butyl Phthalate (13) Di-N-Octyl Phthalate (14) Heptadecane (15) Indole (16) Naphthalene (17) N-Hexadecane (18) Nonadecane (19) P-Cresol (20) Phenanthrene (21) Phenol (22) Pyrene (23) Triethyl Phosphate 

# 0 2 4 6 8 10 12 14 16 18 20 22 24 

# SVOCs 1 10

C o n c e n t r a t io n ( u g / L ) 

# 100Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 105 Figure 3.1.10. Box and Dot Density Plot of Po tential Hazard Quotients for SVOCs in Samples of Bilgewater SVOCs are identified as follows (replacement values for non-detects are circled): (1) 2,4,6-Trichlorophenol (2) 2-Butoxy Ethanol (3) 2-Methylnaphthalene (4) 3-Methyl-Butanoic Acid (5) 4-Methyl-Pentanoic Acid (6) Benzeneacetic Acid (7) Benzenepropanoic Acid (8) Benzothiazole (9) Bis(2-Ethylhexyl) Phthalate (10) Cholesterol (11) Dimethyl Phthalate (12) Di-N-Butyl Phthalate (13) Di-N-Octyl Phthalate (14) Heptadecane (15) Indole (16) Naphthalene (17) N-Hexadecane (18) Nonadecane (19) P-Cresol (20) Phenanthrene (21) Phenol (22) Pyrene (23) Triethyl Phosphate 

# 0 2 4 6 8 10 12 14 16 18 20 22 24 

# SVOCs 0.00001 0.00010 0.00100 0.01000 0.10000 1.00000 10.00000

P o t e n t ia l H a z a r d Q u o t ie n tChapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 106 3.2.1.6 Volatile Organic Compounds (VOCs)

Bilgewater samples were analyzed for 72 VOC s. Out of the 72 analytes, 46 VOCs were not detected in any of the bilgewater samples. Of the remaining 26 VOCs, 11 were detected in more than one bilgewater samples and 15 were detected only in one bilgewater sample (see Table 3.1.7). Of the 11 VOCs that were detected in more than one bilgewater sample, the following were detected in more th an 50 percent of the samples:

 1,2,4-Trimethylbenzene

 1,3,5-Trimethylbenzene

 Acetone

 Benzene

 m-,p-Xylene (sum of isomers)

 Methylene chloride

 O-Xylene.

2-butanone, ethylbenzene, styren e, and toluene were also de tected in more than one bilgewater sample.

Figure 3.1.11 presents the range of concentrations measured for VOCs in the bilgewater samples. The VOC concentrations measured in bilgewater samples varied widely, with concentrations of a half-dozen VOCs ranging ov er three orders of magnitude. The maximum concentrations of four VOCs (1,2,4-trimethylbe nzene, m-,p-xylene, o-xylene and toluene) exceeded 1,000 μg/L (1 mg/L), while the maximum concentrations of four other VOCs (1,3,5- trimethylbenzene, benzene, ethylbenzene and n-propylbenzene) exceeded 100 μg/L. Each of
these maximum VOC concentrations was measur ed in the bilgewater sampled from one tow/salvage boat. These VOCs are commonly c onstituents of petroleum products, refining byproducts, and gasoline additives, and are used as solvents.

Figure 3.1.12 presents the distributions of PHQs for each VOC, based on the most conservative screening benchmarks. The maximu m PHQ for benzene, based on the 2.2 μg/L human health (water plus organism consumption) criterion benchmark, was 187. The maximum PHQ for toluene was marginally higher than on e; the highest concentration of toluene (1,700 μg/L) exceeded the human health (water and orga nism consumption) criterion of 1,300 μg/L. For two other VOCs (chloroform and tetrachloroethene ), only one of seven sample concentrations were detected, and these detected concentrations were below the screening benchmark. However,
because the method detection limits for thes e two compounds were more than double their respective screening benchmarks, th e resulting PHQs for these com pounds, as reported in Figure 3.1.12, are greater than one when concentrations equal to 1⁄2 of the det ection limit are included. Because these PHQ values were not based on de tected concentrations, EPA considers them highly uncertain.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 107 Finally, two VOCs (acetone and methylene chlo ride) were measured in ambient samples at concentrations comparable to the correspond ing bilgewater concentr ation. However, these ambient concentrations were only comparable to the lowest concentrations of these VOCs measured in some bilgewater samples. Therefore, it is unlikely that leak age or other entry of ambient water is a significant source of th e elevated acetone and methylene chloride concentrations measured in bilgewater.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.1.7. Results of Bilgewater Sample Analyses for VOCs1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.3MedianConc.MinimumConc.10%25%75%90%MaximumConc.3ScreeningBM21,2,4-Trimethylbenzeneμg/L53602200.5054011001100NA1,3,5-Trimethylbenzeneμg/L5360650.10160320320NA2-Butanoneμg/L52402.62.83.73.7NA4-Isopropyltolueneμg/L51203.33.36.56.5NAAcetoneμg/L5510013102.32.34.3233131NABenzeneμg/L7457610.101.34104102.2Biphenylμg/L51204.50.871.71.7NACarbon disulfideμg/L51202.00.0500.100.10NAChloroformμg/L71143.34.14.15.7cis-1,2-Dichloroetheneμg/L51202.30.751.51.5NACyclohexaneμg/L51205.89.51919NAEthylbenzeneμg/L7343681.3460460530Isopropylbenzeneμg/L51209.9204040NAm-,p-Xylene (sum of isomers)μg/L53603700.5093019001900NAMethyl tertiary butyl ether (MTBE)μg/L51202.00.0500.100.10NAMethylcyclohexaneμg/L51205.48.51717NAMethylene chlorideμg/L74571.60.100.200.300.304.6Nonanalμg/L111003.1NAn-Pentadecaneμg/L1110058NAn-Propylbenzeneμg/L51202660120120NAO-Xyleneμg/L53602400.2059012001200NAStyreneμg/L524011203939NATetrachloroetheneμg/L71142.60.400.400.69Tolueneμg/L73432400.30170017001300Trichloroetheneμg/L71142.60.300.302.5Trichlorofluoromethaneμg/L71143.55.55.5NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.(3) In some cases, the detected concentration(s) for an analytecould be lower than the replacement value (1⁄2 of the reporting limit) for a concentration that was nondetected. In anextreme (but possible) case, this couldresult in an average concentration for an analyte that is greater than the maximum detected concentration.108Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 

# VOCs 0.1 1.0 10.0 100.0 1000.0

C o n c e n t r a t io n ( u g / L )



## Figure 3.1.11. Box and Dot Density Plot of VO C Concentrations Measured in Samples of Bilgewater
VOCs are identified as follows: (1) 1,2,4-Trimethylbenzene (2) 1,3,5-Trimethylbenzene (3) 2-Butanone (4) 4-Isopropyltoluene (5) Acetone (6) Benzene (7) Biphenyl (8) Carbon Disulfide (9) Chloroform (10) Cis-1,2-Dichloroethene (11) Cyclohexane (12) Ethylbenzene (13) Isopropylbenzene (14) M-,P-Xylene (sum of isomers) (15) Methyl Tertiary Butyl Ether (Mtbe) (16) Methylcyclohexane (17) Methylene Chloride (18) Nonanal (19) N-Pentadecane (20) N-Propylbenzene (21) O-Xylene (22) Styrene (23) Tetrachloroethene (24) Toluene (25) Trichloroethene (26) Trichlorofluoromethane



## 109Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 110 Figure 3.1.12. Box and Dot Density Plot of Po tential Hazard Quotients for VOCs in Samples of Bilgewater VOCs are identified as follows (replacemen t values for non-detects are circled): (1) 1,2,4-Trimethylbenzene (2) 1,3,5-Trimethylbenzene (3) 2-Butanone (4) 4-Isopropyltoluene (5) Acetone (6) Benzene (7) Biphenyl (8) Carbon Disulfide (9) Chloroform (10) Cis-1,2-Dichloroethene (11) Cyclohexane (12) Ethylbenzene (13) Isopropylbenzene (14) M-,P-Xylene (sum of isomers) (15) Methyl Tertiary Butyl Ether (Mtbe) (16) Methylcyclohexane (17) Methylene Chloride (18) Nonanal (19) N-Pentadecane (20) N-Propylbenzene (21) O-Xylene (22) Styrene (23) Tetrachloroethene (24) Toluene (25) Trichloroethene (26) Trichlorofluoromethane 

# 100.0000

0 2 4 6 8 10 12 14 16 18 20 22 24 26 

# VOCs 0.0001 0.0010 0.0100 0.1000 1.0000 10.0000

P o t e n t ia l H a z a r d Q u o t ie n tChapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 111 3.2.1.7 Nonylphenols

Bilgewater samples were analyzed for 34 long- and short-chain nonylphenol and octylphenol ethoxylates (two di screte subsets of alkylphenol ethoxylates), as well as total nonylphenol. Of these analytes, 14 alkylphenol et hoxylates were not detected and 20 were detected in a single bilgewater sample (s ee Table 3.1.8). Of the 20 distinct alkylphenol ethoxylates detected, 16 were detected in the bilgew ater from a tour boat, three were detected in the bilgewater from a tow/salvage boat, and one wa s detected in the bilgewater from a shrimper. Measured concentrations of ethoxyl ates in bilgewater ranged from less than 1 μg/L for three of the octylphenol ethoxylate isom ers (OP10EO, OP12EO, and OP11EO) to 1,050 μg/L for total nonylphenol polyethoxylates (sum of NPEOs – NP 5EO through NP18EO). This latter maximum concentration was measured in the bilgewater sample from the tour boat. According to the operator(s), the bilgewater discharg ed from this vessel is expected to possibly contain oil, grease, fuel, cleaning solvents, detergent and water from deck washdown. Of these pollutants, detergents
are the most common source of NPEOs. A lthough there is no NRWQC for the sum of alkylphenol ethoxylates, they can degrade to to tal nonylphenol, which does have a NRWQC, in
fresh and salt water.

The one detected concentration for total nony lphenol (NP, representative of the same nonylphenol isomers in the commercial mixtur e upon which EPA’s NRWQC is based – CAS #84852-15-3) of 4.9 μg/L exceeded the saltwater chr onic criterion of 1.7 μg/L by a factor of 2.9. Although the vessel operators added dish soap to the bilgewater prior to overboard discharge, this detergent is not necessa rily the primary or only sour ce of the detected nonylphenol. Lubricants also contain alkylphenol ethoxylates, and oil, grease, and fuel also might accumulate in bilgewater. The operators of three of the other vessels wher e bilgewater was sampled also reported using commercial bilge cleaners, yet NP was not detected in samples from those vessels. Furthermore, the operator of the tour boat from which 16 of the long- and short-chain alkylphenol ethoxylates were dete cted made no comment about us ing bilge clean ers. It is unlikely that ambient water is the source of NP to bilgewater in the detected sample.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.1.8. Results of Bilgewater Sample Analyses for Nonylphenols1AnalyteUnitsNo.samplesNo.DetectedDetectedProportion(%)AverageConc.3MedianConc.MinimumConc.10%25%75%90%MaximumConc.3ScreeningBM2Long-Chain Alkylphenol EthoxylatesTotal Nonylphenol Polyethoxylatesμg/L512026053011001100NANonylphenol octodecaethoxylate (NP18EO)μg/L51200.781.83.63.6NANonylphenol heptadecaethoxylate (NP17EO)μg/L51201.84.28.48.4NANonylphenol hexadecaethoxylate (NP16EO)μg/L51203.68.21616NANonylphenol pendecaethoxylate (NP15EO)μg/L51206.8163131NANonylphenol tetradecaethoxylate (NP14EO)μg/L512012285656NANonylphenol tridecaethoxylate (NP13EO)μg/L512020448888NANonylphenol dodecaethoxylate (NP12EO)μg/L51202761120120NANonylphenol undecaethoxylate (NP11EO)μg/L51203577150150NANonylphenol decaethoxylate (NP10EO)μg/L51203577150150NANonylphenol nonaethoxylate (NP9EO)μg/L51203370140140NANonylphenol octaethoxylate (NP8EO)μg/L51202857110110NANonylphenol heptaethoxylate (NP7EO)μg/L512022428383NANonylphenol hexaethoxylate (NP6EO)μg/L512016275353NANonylphenol pentaethoxylate (NP5EO)μg/L51209.7142727NAOctylphenol dodecaethoxylate (OP12EO)μg/L51200.970.250.490.49NAOctylphenol undecaethoxylate (OP11EO)μg/L51201.40.380.770.77NAOctylphenol decaethoxylate (OP10EO)μg/L51203.20.390.780.78NAShort-Chain NonylphenolsBisphenol Aμg/L41255.3111515NANonylphenolsNPμg/L41259.23.74.94.91.7Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.(3) In some cases, the detected concentration(s) for an analytecould be lower than the replacement value (1⁄2 of the reporting limit) for a concentration that was nondetected. In anextreme (but possible) case, this couldresult in an average concentration for an analyte that is greater than the maximum detected concentration.112Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 113 3.2.1.8 Summary of the Characterization of Bilgewater Discharge

Table 3.1.9 summarizes the specific analytes within bilgewater effluent that may have the potential to pose risk to human health or the environment for these types of vessels based on these samples. EPA’s interpretation of a realized risk likely posed by these analytes, relative to pollutant loadings, background ambient and source water contaminant levels and characteristics,
and other relevant information useful for th is assessment, is presented in Chapter 5.

In summary, among the metals, dissolved coppe rand zinc were consistently measured at concentrations exceeding the most stringent NR WQC in fishing vessels, tow/salvage vessels, water taxis, and tour vessels; total arsenic was also measured at concentrations exceeding the most stringent NRWQC in a Longliner fishing vessel, a tow/salvage vessel, and tour vessel. The classical pollutants BOD, COD, sulfide, TSS, a nd TRC exceeded the screening benchmarks in at least one of the fishing vessels, tow/salvage ve ssels, water taxis, and tour vessels. Among the pathogen indicators, enterococcus, E. coli and fecal coliform bacteria were all present at concentrations exceeding NRWQC; these samples we re collected only from fishing boats. Total phosphorus was the only nutrient to exceed a screening benchmark in bilgewater from all vessel types, while ammonia exceeded the screening benchmark in a fishing vessel (longliner). Concentrations of the SVOC bis(2-ethylhexyl) phthalate exceeded NRWQ C in the bilgewater discharges of fishing vessels, tow/salvage ve ssels, water taxis, and tour vessels, while 2,4,6- trichlorophenol exceeded the screening benchmark in only the tour vessel. Benzene and toluene sampled from tow/salvage vessels were the onl y VOCs found at concentrations exceeding the most stringent NRWQC. The screening benchm ark for total nonylphenol was exceeded in a single sample collected from a fishing vessel.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.1.9. Characterization of Bilgewater Discharge and Summaryof Analytes that May Havethe Potential to Pose RiskAnalytes that May Have the Potential to Pose Risk in Bilgewater Discharge and Vessel Sources1, 2Vessel Type (no. vessels) Microbi ologicals Volatile Organic Compounds Semivolatile Organic Compounds Metals (dissolved) Metals (total) Oil and Grease Sulfide Short- Chain Alkylphenol Ethoxylates and NP Long-Chain Alkylphenol Ethoxylatess Nutrients BOD, COD, and TOC

Total Suspended Solids

Ot her Physical/Chemical ParametersFishing (2)enterococcus,E. coli,Fecal ColiformCu, ZnAsxxTP,AmmoniaBOD,COD,TOCxTRCTow/Salvage (2)Benzene,TolueneBis(2-ethylhexyl)-phthalateCu, ZnAsxxTPBOD,COD,TOCxTRCWater Taxis (2)Bis(2-ethylhexyl)-phthalateCu, ZnAsTRCTour (1)Bis(2-ethylhexyl)-phthalate,2,4,6-TrichlorophenolCu, Cd, ZnAsxTPBOD,COD,TOCxTRC(1) Analytes are generallyboldedwhen a large proportion of the samples have concentrations exceeding the NRWQC (e.g., 25 to 50 percent), when several of the samples havePHQs > 10 (e.g., two or three of five), when a few samplesresult in PHQs greatly exceeding the screening benchmark (i.e., 100sto 1,000s), or, in the case of oil and grease and fornonylphenol, when one or more samples exceed an existing regulatorylimit by more than a factor of 2. See text in Section3.1.3for a definition of PHQs and Table 3.1 for screeningbenchmarks used to calculate these values.(2) EPA notes that the conclusion of potential risk is drawn froma small sample size, in somecases a single vessel, for certain discharges sampled from some vessel classes. EPAincluded these results in the tables to provide a concise summary of the data collected in the study, but strongly cautions thereader that these conclusions, where there are only a fewsamples from a given vessel class, should be considered preliminary and might not necessarily represent pollutant concentrations from these discharges from other vessels in thisclass.114Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.2 Stern Tube Packing Gland Effluent

The packing gland or stuffing box surrounds the propeller shaft at the point it exits a
boat 's hull underwater. Based on the vessels sampled for this analysis, using a packing gland is a

common me thod for preventing water from enteri ng the hull while still allowing the propeller shaft to turn. A stuffing box packed with greased flax rings is designed to leak a few drops per minute of ambient water to cool the gland when a vessel is underway. Stuffing boxes are also used to seal rudder stocks that penetrate the hull below the water line. The packing gland effluent water is often collected in a segr egated section of the bilge that generally contains an automatic bilge pump.

During this study, EPA observed this segregat ed discharge onboard tugboats but not on any other vessel classes. In most of the other ve ssels sampled, the packing gland effluent dripped directly into the bilge. Possibl e constituents of concern in the packing gland effluent include metals (from contact of the discharge with the dr ive shaft), hydraulic flui d, grease or lubricants found in the gland, and fuel constituents since the packing gland is located in the engine
compartment.

Based on field observations from EPA’s ve ssel sampling program, EPA estimated the drip rate into the stuffing box at approximately 10 drips per minute, which is consistent with the literature data (Casey, 2007; Chin, 2005). This equates to a stern t ube effluent generation rate of between 2 and 4 gpd. Since most tugboats had dual propeller systems, these boats are expected to generate between 4 and 8 gpd of stern tube effluent.

For this study, EPA collected samples from the packing gland effluent from nine tugboats. Samples on these vessels were analyzed for metals (dissolved and total), classical pollutants, nutrients, VOCs, SVOCs, and nonylph enols. Packing gland effluent samples were collected by placing a gla ss transfer jar under the shaft to collect any water dripping and then compositing the sample in a Teflon-lined pail. In some cases, EPA dipped the transfer jar into the segregated bilge compartment. If the vessels ha d a dual propelle r system, EPA collected samples from each for the composite. However, samples for analysis of oil and grease and VOCs are not appropriate to composite, so these sa mples were collected separately.

3.2.2.1 Metals

Packing gland effluent samples were analyzed for both total and disso lved concentrations of 22 metals. Of the 22 metals, 18 total metals a nd 15 dissolved metals were detected in the EPA sample set (see Table 3.2.1). Antimony, beryllium, s ilver, and cadmium were not detected in any samples in the total or dissolved form, while cobalt, iron, thallium, and vanadium were not detected in the dissolved form. Figures 3.2.1 a nd 3.2.2 present box and dot density plots of the detected results for dissolved and total metals, respectively. The box and density plots in Figures

115Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## 3.2.3 and 3.2.4 present these same detected results for dissolved and total metals, respectively, normalized by the lowest NRWQC where applicable. Points on these plots above the dashed line (demarking a PHQ of 1) indicate metals conc entrations exceeding the benchmark. With a few exceptions, the metal concentrations normalized by the lowest NRWQC were below the PHQ of

1.

Dissolved and total aluminum were found in all nine samples analyzed. Dissolved
aluminum was detected at con centrations ranging from 7.8 to 150 μ g/L in the packing gland effluent; however, no screening benchmark is av ailable for dissolved aluminum. Total aluminum was detected at concentrations ranging from 50.7 to 6,400 μ g/L and exceeded the screening
benchmark of 87 μ g/L eight times. Arsenic, both total a nd dissolved, was detected in three of nine samples in the packing gland effluent, although the sample with the highest measured total and dissolved arsenic concentrations may be elev ated resulting from positive interference (see
discussion in Section 3.1.3 ). All three total arsenic values exceeded the screen ing benchmark of
0.018 μ g/L (based on the human health criterion for dr inking water plus fish consumption) with values of 2.8, 4.4, and 15.3 μ g/L. None of the three detected dissolved arsenic values (1.2, 1.4
and 14.7 μ g/L) exceeded the screening benchmark of 36 μ g/L (based on the saltwater chronic criterion for the protection of aquatic life). Dissolved copper wa s detected in four of nine samples with values ranging from16.2 to 92 μ g/L. All four sample valu es exceeded the screening
benchmark of 3.1 μ g/L. Total copper was detected in seven of the nine samples from the packing gland effluent, with values ranging from 7 to 891 μ g/L. None of the tota l copper values exceeded the screening benchmark of 1,300 μ g/L.

Dissolved and total nickel was detected in si x of nine and eight of nine packing gland effluent samples respectively. Two of the total nickel results (1,670 and 3,230 μ g/L) exceeded the screening benchmark of 610 μ g/L, while all of the dissolved nickel values exceeded the screening benchmark of 8.2 μ g/L. Zinc was found in seven of nine samples in the dissolved form and eight of nine samples in the total form. One sample value of 120 μ g/L for dissolved zinc exceeded the screening benchmark of 81 μ g/L. Selenium was found in three of nine samples in the dissolved form and only one of nine samples in the total form (the latter an exceptionally high concentration of 42.1 μ g/L suspected of reflecting positive interference). Dissolved
chromium and lead were also detected in se veral samples. Chromium values exceeded the
benchmark criteria of 11 μ g/L in four detected samples. Dissolved lead was detected at a
concentration of 4.9 μ g/L, which slightly exceeded the benchmark of 2.5 μ g/L.

Total iron, manganese, and thallium were all detected at levels below the screening benchmarks, except for one sample for total thalliu m that was detected at the reporting level of 1

μ g/L. This sample exceeded the benchmark of 0.24 μ g/L for thallium and has a PHQ of 4.17 as shown on Figure 3.2.4. Barium, sodium, and potassium, in both forms (total and dissolved) were detected in three of three samples, but did not exceed benchmark criteria. The metals magnesium and calcium, in both forms (total and dissolved); cobalt and vanadium (in total); and dissolved

116Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 117 manganese were detected in one or more samp les but no screening criteria exists for these compounds.

EPA analyzed ambient metal concentrations to determine if dissolved and total aluminum concentrations found in packing gland effluent were contributed primarily by the vessel or reflected contributions primar ily by background ambient concentr ations. For both dissolved and total aluminum, sample concentrations were moderately influenced by ambient background concentrations, with ambient concentrations as high as 130 μ g/L (dissolved aluminum) and 3,950

μ g/L (total aluminum). For both dissolved and tota l arsenic, sample concentrations from stern tube packing gland effluent were strongly in fluenced by ambient background concentrations.
Ambient dissolved and total arsenic concentrations as high as 16.1 and 15.4 μ g/L, respectively, were measured in water surrounding one of the three vessels sampled (a vessel sampled in Baltimore, Maryland), although these measured con centrations may be elevated due to positive interference. Ambient background concentrations of both dissol ved and total copper were comparatively low relative to the packing gland e ffluent sample concentra tions and therefore of little influence (i.e., dissolved a nd total copper concentrations we re largely from packing gland effluent). As in the case of copper, nickel was not found at high levels in the surrounding ambient water; thus, nickel is another metal th at may have a significant source from the packing gland effluent. All of the selenium values were consistent with concentr ations in the surrounding
water. Neither chromium nor l ead was strongly influenced by am bient concentrations in the surrounding water. The concentrations barium, sodium, potassium, magnesium, calcium cobalt, vanadium, and manganese genera lly reflect the concentratio ns in the surrounding water.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment118Table 3.2.1. Results of Packing Gland Effluent Sample Analyses for Metals1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Heavy and Other MetalsAluminum, Dissolved4μg/L99100881107.87.831140150150NAAluminum, Total4μg/L991001200300515117015006400640087Arsenic, Dissolved3μg/L93333.31.31515536Arsenic, Total3μg/L93333.83.6151550.018Barium, Dissolved3μg/L331005363303030666666NABarium, Total3μg/L3310088983232321401401401000Chromium, Dissolvedμg/L9556193.82011011011Chromium, Totalμg/L98892301309.7440760760NACobalt, Total4μg/L32673.02.95.65.65.6NACopper, Dissolvedμg/L9444223892923.1Copper, Totalμg/L9778140203.51508908901300Iron, Total4μg/L3310039002700710710710830083008300300Lead, Dissolved4μg/L91111.84.94.92.5Lead, Totalμg/L93337.98.94343NAManganese, Dissolved4μg/L9889449.62.953250250NAManganese, Total4μg/L99100160110797993230350350100Nickel, Dissolvedμg/L966721013370100010008.2Nickel, Totalμg/L9889610451297032003200610Selenium, Dissolved3μg/L93338.11.2414155Selenium, Total3μg/L91118.642425170Thallium, Total4μg/L31330.671.01.01.00.24Vanadium,Total3μg/L31334.6131313NAZinc, Dissolved4μg/L977834183.35312012081Zinc, Totalμg/L98897073111201801807400Cationic MetalsCalcium, Dissolved3μg/L99100360002400023000230002300035000110000110000NACalcium, Total3μg/L99100370002400022000220002300039000110000110000NAChapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment119Table 3.2.1. Results of Packing Gland Effluent Sample Analyses for Metals1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Magnesium, Dissolved3μg/L9910040000780062006200650011000290000290000NAMagnesium, Total3μg/L9910039000790060006000630012000280000280000NAPotassium, Dissolved3μg/L33100390004700400040004000110000110000110000NAPotassium, Total3μg/L33100370004600460046004600100000100000100000NASodium, Dissolved3μg/L3310081000020000180001800018000240000024000002400000NASodium,Total3μg/L3310081000020000170001700017000240000024000002400000NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.(3) Sample concentrations are strongly influenced by background concentrations in ambient water, accounting for greater than 90% of sample concentrations in the majority ofsamples.(4) Sample concentrations are moderately influenced by backgroundconcentrations in ambient water, accounting for between 50 and 90% of sample concentrations in the majority ofsamples.(5) Maximum concentrations may be elevatedas a result of positive interference.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 120 Figure 3.2.1. Box and Dot Density Plot of Diss olved Metals Concentrations Measured in Samples of Packing Gland Effluent (Note: Maximum concentrations of arsenic and selenium may be elevated as a result of positive interference). 

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## 121 Figure 3.2.2. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Packing Gland Effluent (Note: Maximum concentrations of arsenic and selenium may be elevated as a result of positive interference). Al u

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## 122 Figure 3.2.3. Box and Dot Density Plot of Pote ntial Hazard Quotients for Dissolved Metals in Samples of Packing Gland Effluent (Note: Replacement values for non-detects are circled. Also, maximum concentrations of arsenic and selenium may be elevated as a result of positive interference.) 

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## 123 Figure 3.2.4. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Packing Gland Effluent (Note: Replacement values for non-detects are circled. Also, maximum concentrations of arsenic and selenium may be elevated as a result of positive interference). 

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## 124 3.2.2.2 Classical Pollutants

EPA sampled the packing gland effluent fo r numerous classical pollutants to further
characterize this discha rge type for the tugboats sampled under this program. The classical pollutants include measurements that are physi cal properties (temperatu re, conductivity, salinity, turbidity, TSS), oxygen consumption (BOD, COD) , oil and grease (HEM and SGT-HEM), as
well as chemical concentrations (pH, sulfide, DO, and TRC). Table 3.2.2 presents the data for these parameters.

Figure 3.2.5 illustrates the varied concentrations of measured for these parameters in the packing gland effluent. Most of the concentrations and values re ported reflect the concentrations and values in the ambient water surrounding the vesse l, as this water is the source of the drive shaft water. Two parameters (sulfide and TRC) were not detected in any samples.

The PHQs were calculated for the classical pollutants for wh ich they were available. Only two pollutants exceeded these PHQ scr eening benchmarks (see Figure 3.2.6): oil and grease and TSS. One of the vessel samples had values which exceeded the screening benchmark for oil and grease measured as both HEM and petroleum hydrocarbon (SGT-HEM). The concentrations detected were 66.7 mg/L for HEM and 55.8 mg/L for SGT-HEM, both of which exceeded the benchmark of 15 mg/L. EPA noted a visible oily sheen on the surface of this effluent and evidence of settled hydrocarbons on the bottom of the tank as this sample was collected. Based upon conversations with the vessel engineer, the like ly source is an oil leak that was somehow making its way into this effluent. This seems a plausible explanation given that background concentrations of HEM and SGT-HEM in surrounding ambient water were very low (< 1.5 mg/L) relative to the measured sample concentrations.

Total suspended solids were detected in al l nine samples collected from the packing gland effluent. Two samples with concentratio ns of 269 and 134 mg/L exceeded the screening benchmark of 98 mg/L.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.2.2. Results of Packing Gland Effluent Sample Analyses for Classical Pollutants1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2ConductivitymS/cm991001.60.300.220.220.220.551212NADissolved Oxygenmg/L991008.38.45.35.37.29.31111NATotal Organic Carbon (TOC)mg/L771003.53.52.22.22.64.84.94.9NABiochemical Oxygen Demand(BOD)mg/l99100117.23.33.34.313353530Chemical Oxygen Demand (COD)mg/l944431538888NAHexane Extractable Material (HEM)mg/l9556141.6523676715pHSU991007.17.52.42.47.38.08.28.2NASalinityppt87880.140.200.100.200.200.20NASilica Gel Treated HEM (SGT-HEM)mg/l9556131.719565615TemperatureC9910020209.39.318232626NATotal Suspended Solids (TSS)mg/l9910059285.65.6138127027030TurbidityNTU9910046189.09.01370190190NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.125Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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126Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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## 127Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 128 3.2.2.3 Nutrients

Packing gland effluent samples were analy zed for four nutrient -related parameters: ammonia nitrogen, nitrate/nitrite, TKN, and total phosphorus (see Tabl e 3.2.3). Figures 3.2.7 and 3.2.8 illustrate the variability of the nutrient s in the packing gland effluent. Ammonia, nitrate/nitrite, and TKN were dete cted in most of the samples analyzed, but in relatively low concentrations. Phosphorus was detected in se ven of the nine tugboat samples collected.

Only ammonia has a current numeric NRWQC value. The results for ammonia detected in the packing gland effluent range from 0.07 to 0.23 mg/L, well below the benchmark of 1.2 mg/L. TKN and nitrate/nitrite were detected in all of the nine tugboat samples, with values ranging from 0.40 to 1.8 mg/L for TKN to 0.62 to 1.5 mg/L for nitrate/nitrite. Total phosphorus was detected in seven of the nine sample s for packing gland effluent. The detected concentrations ranged from 0.06 to 0.25 mg/L and only two values, 0.19 and 0.25 mg/L, exceed the 0.1 mg/L benchmark.

Most of these values for ammonia, TKN, and nitrate/nitrite are cons istent with ambient background results in each location. The backgr ound ambient for these total phosphorus samples reported values from 0.06 to 0.19 mg/L, indicatin g a moderate influence of surrounding ambient water on sample concentrations.

In general, it appears that nutrient concen trations from packing gland effluent are generally low and the wastestream does not appe ar to be adding signifi cant nutrients to the surrounding waters. Nutrient addition from packi ng gland effluent was not considered a likely concern in this discharge relative to metals from contact of the discharg e with the drive shaft, hydraulic fluid, grease or lubricants from the gland, and fuel constituents.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.2.3. Results of Packing Gland Effluent Sample Analyses for Nutrients1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Ammonia As Nitrogen (NH3-N)mg/L97780.100.100.0340.140.230.231.2Nitrate/Nitrite (NO3/NO2-N)mg/L991000.690.620.0850.0850.580.801.51.5NATotal Kjeldahl Nitrogen (TKN)mg/L991001.11.40.410.410.691.41.81.8NATotal Phosphorusmg/L97780.130.100.0300.220.250.250.10Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.129Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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130Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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131Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 132 3.2.2.4 Volatile and Semivolat ile Organic Chemicals

Packing gland effluent samples were analyzed for 70 VOCs and 73 SVOCs in nine tugboats (see Table 3.2.4). Of the analyt es tested, six VOC compounds and 10 SVOC compounds were detected in the samples. Figures 3.2.9 and 3.2.10 illustrate the range of concentrations measured for SVOCs and VOCs, respectively.

Three VOCs, m-p-xylene, acetone, and methylen e chloride, were detected in more than one sample. Eight of the 10 SVOCs detected were found in one sample. Bis(2-ethylhexyl) phthalate was found in the effluent of three ve ssels sampled and n-hexadecane was found in the effluent of two of the vessels sampled. Bis(2-et hylhexyl) phthalate was detected at notably high (compared to ambient surrounding water) va lues of 2.8, 5.4, and 23.5 μg/L. The only other compound with a screening benchmark is di-n-butyl phthalate, whic h was detected in one sample with a concentration of 2.45 μg/L, which is we ll below the screening benchmark of 2,000 μg/L. These two phthalate compounds are us ed as plasticizers, and bis(2- ethylhexyl) phthalate is used as a hydraulic fluid and as a dielectric fluid in capacitors.

Figure 3.2.12 presents the di stributions of PHQs, base d on the most conservative screening benchmarks, for each VOC; none of the detected values exceed the screening
threshold 22 

## . PQH was above one for all three sample s of bis(2-ethylhexyl) phthalate, based on the screening benchmark of 1.2 μg/L (Figure 3.2.11).

Of the six VOC and 10 SVOC compounds detect ed in packing gland effluent samples, bis(2-ethylhexyl) phth alate was the only compound whose m easured concentrations in the discharge was substantially higher than in ambient water; all ot her VOCs and SVOCs detected in packing gland effluent appear to reflect the si milar concentrations found in surrounding water.

22 

### PHQs for benzene, methylene chloride and tetrachloroet hene in multiple packing gland effluent samples were based on replacement values of 1⁄2 of the reporting limit for nondetected concentrations. In Figure 3.2.12 the PHQs based on replacement values for nondetected concentrations have been circled for identification. EPA does not consider PHQs that exceed 1 to signal that these discharges pose a potential ri sk to cause or contribute to the nonattainment of a water quality standard when the PH Qs are based on replacement values for nondetected concentrations.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.2.4. Results of Packing Gland WaterSample Analyses for SVOCs and VOCs1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.3MedianConc.MinimumConc.10%25%75%90%MaximumConc.3ScreeningBM2SVOCs2,6,10,14-Tetramethyl Pentadecaneμg/L1110012NA3,6-Dimethylundecaneμg/L111008.7NA5-Butyl-Hexadecaneμg/L111006.7NABis(2-ethylhexyl)phthalateμg/L93334.74.124241.2Di-n-butylphthalateμg/L91111.72.52.52000Dodecaneμg/L111005.0NAEicosaneμg/L111005.4NAn-Hexadecaneμg/L221005.56.05.05.05.06.06.06.0NANonanoic Acidμg/L111004.3NAVOCsAcetoneμg/L331002.92.72.72.72.73.23.23.2NABenzeneμg/L91111.40.200.202.2m-,p-Xylene (sum of isomers)μg/L32671.70.100.100.100.10NAMethylenechlorideμg/L92221.20.100.200.204.6n-Pentadecaneμg/L1110011NASulfur dioxideμg/L1110013NATetrachloroetheneμg/L91111.40.200.200.69Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.(3) In some cases, the detected concentration(s) for an analytecould be lower than the replacement value (1⁄2 of the reporting limit) for a concentration that was nondetected. In anextreme (but possible) case, this couldresult in an average concentration for an analyte that is greater than the maximum detected concentration.133Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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SVOCs are identified as follows: (1) 2,6,10,14-Tetramethyl Pentadecane (2) 3,6-Dimethylundecane (3) 5-Butyl-Hexadecane (4) Bis(2-ethylhexyl) phthalate (5) Di-n-butyl phthalate (6) Dodecane (7) Eicosane (8) n-Hexadecane (9) Nonanoic acid



## 134Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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## 135Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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## Figure 3.2.11. Box and Dot Density Plot of Po tential Haza rd Quotients for SVOCs in Samples of Packing Gland Effluent SVOCs are identified as follows (replacement values for non-detects are circled): (1) 2,6,10,14-Tetramethyl Pentadecane (2) 3,6-Dimethylundecane (3) 5-Butyl-Hexadecane (4) Bis(2-ethylhexyl) phthalate (5) Di-n-butyl phthalate (6) Dodecane (7) Eicosane (8) n-Hexadecane (9) Nonanoic Acid



## 136Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 137 Figure 3.2.12. Box and Dot Density Plot of Po tential Hazard Quotients for VOCs in Samples of Shaft Packing Gland Effluent VOCs are identified as follows (replacemen t values for non-detects are circled): (1) Acetone (2) Benzene (3) m-,p-Xylene (sum of isomers) (4) Methylene chloride (5) n-Pentadecane (6) Sulfur dioxide (7) Tetrachloroethene 

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P o t e n t ia l H a z a r d Q u o t ie n tChapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.2.5 Nonylphenols

EPA analyzed samples of shaft packing gland effluent for long and short chain nonylphenol and octylph enol ethoxylates and NP b ecause of the possibility of alkylphenolcontaining water from the bilge or other areas of the vessel leaking into the shaft packing gland effluent compartment. Table 3.2.5 pr esents the detected results.

Of the nine samples for which long- a nd short-chain nonylphenol and octylphenol ethoxylates were analyzed, only six long-chain isomers of th e octylphenol polyethoxylate (OPEO) type were detected: OP12EO, OP11EO, OP10EO, OP9EO, OP8EO, and OP7EO. All of the detected OPEOs are long-chain octylpheno ls and were found in one tugboat sampled. The OPEO with the longest ethoxylate chain (OP12EO) was detected at the lowest concentration (Figure 3.2.13). The OPEO isomers showed the trend of increasing concentrations as the size of the ethoxylate chain is reduced (from OP12EO to OP7EO), indicating moderately advanced degradation of the long-chain OPEOs in the packing gland.

Average concentrations of OPEOs with the longest ethoxy late chains (OP12EO through OP10EO) were similar to bilgewater effluent (see Table 3.1.8). In contrast to bilgewater effluent, however, NP was not detected in packing gland effluent.

None of the OPEOs detected in the packing gland effluent sample were detected in ambient water, indicating a probable source from onboard the vessel (tugboat) – possibly from seepage from the bilge. Another possible source of OPEOs in packing gland effluent could be from the use of lubricants for which octy lphenol ethoxylates are common constituents.

138Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.2.5. Results of Packing Gland Water Sample Analyses for Nonylphenols1AnalyteUnitsNo.samplesNo.detectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Octylphenol dodecaethoxylate (OP12EO)μg/L91111.71212NAOctylphenol undecaethoxylate (OP11EO)μg/L91112.61515NAOctylphenol decaethoxylate (OP10EO)μg/L91114.82222NAOctylphenol nonaethoxylate (OP9EO)μg/L91115.32626NAOctylphenol octaethoxylate (OP8EO)μg/L9111103030NAOctylphenol heptaethoxylate (OP7EO)μg/L9111132828NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.139Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 140 Figure 3.2.13. Box and Dot Density Plot of No nylphenol Concentrations Measured in Samples of Packing Gland Effluent 

## O P

1

0

E

O
O P

1

1

E

O
O P

1

2

E

O

O P

7E O

O P

8E O

O P

9E O



# Nonylphenols 10 15 20 25 30 35

C o n c e n t r a t io n ( u g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 141 3.2.2.6 Summary of the Characterization of Packing Gland Discharge

Table 3.2.6 summarizes the specific analytes within packing gl and effluent that may have the potential to pose risk to human health or th e environment for these types of vessels based upon these samples. EPA’s interpretation of a rea lized risk likely posed by these analytes, relative to pollutant loadings , background ambient and source water contaminant levels and characteristics, and other relevant information usef ul for this assessment, is presented in Chapter
5.

To summarize the results of packing gland discharge measured in the nine tugboats,
metals were the constituents found most fre quently and with the highest magnitudes of exceedance of their respective screening benchm arks. Among the dissolved forms of metals, concentrations of copper, chromiumand ni ckel exceeded the most stringent NRWQC benchmarks. Among the total forms of metals, al uminum, arsenic, iron, manganese and nickel exceeded the most stringent NRWQC benchmarks. However, concentrations of total iron and total manganese in surrounding (amb ient) waters were similar to concentrations measured in packing gland discharge. Among the classical pollutants, most of the concentrations and values reported reflect the concentrations and values in the ambient wate r surrounding the vessel, as this
water is the source of the drive shaft water. Exceptions were two samples for oil and grease (HEM and SGT-HEM) values which exceeded screening benchmarks. Two (of nine) total phosphorus samples also exceeded the screening be nchmark; however, these concentrations were similar to total phosphorus concentrations in the surrounding waters. Among the remaining contaminants, the SVOC bis(2-et hylhexyl) phthalate had a PHQ of >10 for one of the vessels sampled, and six of the relatively long-chained oc tylphenols were measured in one of the nine vessels sampled.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.2.6. Characterization of Packing GlandEffluent and Summary of Analytes thatMay Have the Potential to Pose RiskAnalytes that May Have the Potential to Pose Risk in Packing Gland and Vessel Sources1Vessel Type (no. vessels) Microbiologicals Volatile Organic Compounds Semivola tile Organic Compounds Metals (dissolved) Metals (total) Oil and Grease Sulfide Short-Chain Alkylphenol Ethoxylates and NP Long-Chain Alkylphenol Ethoxylates Nutrients BOD , COD, and TOC Total Suspended Solids Other Physical/Chemical ParametersTugboats (9)Bis(2-ethylhexyl)-phthalateCu,Cr, NiAl, As, NixxTPx(1) Analytes are generallyboldedwhen a large proportion of the samples have concentrations exceeding the NRWQC (e.g., 25 to 50 percent), when several of the samples have PHQs > 10 (e.g.,two or three of five), when a few samples result in PHQs greatly exceeding the screening benchmark(i.e., 100s to 1,000s), in the case of oil and grease and for nonylphenol, when one or moresamples exceed an existing regulatory limit by more than a factorof 2, or when concentrationsof analytes are sufficiently high that they may have the potential to pose risks to local water bodies.See text in Section3.1.3for a definition of PHQs and Table 3.1 for screening benchmarks used to calculate these values.142Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.3 Deck Washdown

Deck washdowns involve removing dirt, grit , or other materials that can impact the integrity of the deck surface (for aesthetic and safety reasons) and are a common vessel maintenance task. The process uses hoses and/ or swabs (mops) to move the deck washdown water, debris, and cleaning agents (if any) to the scuppers, which then discharge the water overboard. EPA collected samples of deck water as it is drained thr ough the scupper against the hull of the vessel (see Section 2.2.4 Sampling Met hods). More than half the vessels sampled reported using detergents (dish soaps, ZEP TM , Simple Green TM ) or other cleaners (chlorine bleach) during the washdown process. Depending on the vessel's design and function, deck
washdown water sometimes contains contaminants su ch as detergents, metals, oil, particulates, and pathogens (the latter primarily fro m catch brought onboard fishing vessels).

Deck washdowns can occur at any time onboard these classes of vessels. Fishing vessels most often discharge while underway either into the nearshore (< 3 Nm from shore) or farshore (> 3 Nm from shore). Washdowns are usually pe rformed on fishing vessels after nets are pulled, fish are brought onboard and cleaned, while retu rning to port, and afte r offloading the catch. EPA notes that the majority of deck washdown samples from fishing vessels were taken while the vessel was shoreside, and do not reflect cons tituents of deck washdown while the vessel is engaged in fishing operations. Decks are washed le ss frequently for other types of vessels such as water taxis, tour boats, and tow boats. Wash lo cations are generally pier side after excursions or within the harbor for these types of vessels.

The volume of deck washdown water generate d by a vessel depends on the frequency of deck washdown, the flow rate from the hose, an d the washdown time. Since most vessels use a common garden-hose for deck washdowns, EPA estim ated the flow rate to be between 10 and 12 gallons per minute (gpm). The time required for deck washdown varies depending on the type of vessel and size. EPA observed during the vessel sampling program that most deck washdowns were generally 15 minutes or less.

Vessels such as tour boats, water taxis, and tow boats would generate an average deckwash water volume between 20 and 30 gpd dur ing the peak summer season, assuming their decks are washed once every week. Deckwash wa ter volume for fishing boats varies depending on the type of boat. For example, trollers, trawlers, gill netters, and purse seiners sometimes wash their decks three to four times per day while fishing, plus one additional time after unloading seafood at the processing facility. For these vessels, deckwash volumes might range between 750 and 900 gpd.

143Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Collecting Deck Washdown Samples from a Tow and Salvage Vessel

Deck Washdown Sample Collected in a Lined Bucket

144Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## For this study, EPA collected deck wa s hdown samples from 32 vessels: 11 fishing vessels (gillnetter, trawlers, and trollers), nine tugboats, six tow/ salvage vessels, two tour boats, a water taxi, a fire boat, a supply boat, and a recreational boat (see Tabl e 2-1). EPA collected single grab samples from one or more scuppers (composited sample if more than one accessible scupper) on selected vessels for laboratory analysis in order to determine re presentative pollutant
concentrations for deck washdown across the range of normal vessel operations.

EPA also sampled a deck runoff discharge dur ing a rain event. Deck runoff differs from washdown in that the runoff discharge occurs be cause of precipitation or spray landing on the deck in sufficient quantities to mobilize pollutant s on the deck surface rather than an intentional introduction of washdown water (often including de tergents). However, deck runoff incorporates pollutants that would have been included in an eventual washdown so the samples are comparable. The deck runoff sample was collect ed from a fishing trawler that was being unloaded at a fish processing facility in the Northeastern United States.

EPA focused its sampling effort on the following analyte groups in deck washdown/runoff that were expected to be present in the discharge: metals, classical pollutants, pathogen indicators (commercial fishing vessels only), nutrients, nonylphenols, and semivolatile and volatile organic compounds (tow /salvage vessels only). Results for each class of pollutant are presented and discussed in the subsections below.

3.2.3.1 Metals

Deck washdown water samples were analy zed for dissolved a nd total metals. The analytical results are summarized in Table 3.3.1. The following metals were detected in 90 percent or more of the deck washdown water samples:

 Dissolved and total aluminum

 Dissolved and total barium

 Total chromium

 Total cobalt

 Dissolved and total copper

 Total iron

 Total lead

 Dissolved and total manganese

 Dissolved and total zinc.

Concentrations of a number of other metals we re detected in 50 percent or more of the samples analyzed:

 Total antimony

145Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



##  Dissolved and tota l arsenic 23 24



##  Dissolved chromium

 Dissolved cobalt

 Dissolved iron

 Dissolved and total nickel

 Dissolved selenium 25



##  Dissolved and total vanadium.

Figure 3.3.1 presents the concentration ranges for dissolved metals detected in the samples. These plots show that dissolved metals concentrations span three orders of magnitude.
Aside from the alkali and alkali earth metals that are the major cations in seawater (Na, K, Ca, Mg), average dissolved concentr ations of iron, aluminum, and zinc were highest, followed by dissolved barium, manganese, and copper. Concentra tions of total metals are displayed in Figure 3.3.2, and follow the same general pattern, but are much higher than their corresponding dissolved metal concentrations (f d 

## s substantially <1.0), except for Na, K, Ca, and Mg, which exist almost entirely in thei r dissolved forms (see Table 3.3.1).

For all metals, the mean ratios of dissolved to total metal concentrations (fds) in a particular sample range from a low of 0.11 for aluminum to 0.89 for selenium (Table 3.3.2). The fds for the 13 (out of 14) metals for which co rresponding data are availa ble are approximately equal to or less than 50 percent, indicating that at least half of the total metal concentration in deck washdown water samples is in particulate fo rm. Such results were expected from certain vessels (e.g., tugboats and supply boats) where particulate material was readily visible on deck surfaces. Particulate metal is less biologically ava ilable than dissolved metals, and therefore less likely to cause an immediate toxic effect in aquatic organisms.

Dissolved cadmium concentrations were dete cted in two of the 31 vessels sampled - a supply and tow/salvage boat. The concentr ations were 1.2 (supply boat) and 22.4 μg/L (tow/salvage boat), which exceeded the saltwater chronic aquatic life crit erion (8.8 μg/L) in the case of the tow/salvage boat and the freshwater ch ronic aquatic life criter ion (0.25 μg/L) in both

cases.

23 

### Even though a dissolved metal is detected in 50% of the samples, it does not mean that the total metal value (which includes dissolved and particulate metals) is consid ered to be detected in the laboratory analyses. All dissolved metal detections are not considered total metal detections because the detection limits differ for a given sample based on dissolved versus total recoverable metal analyses. For example, in the case of selenium, the detection limit for total recoverable selenium was 5 μ g/L for the analysis. In contrast, the detection limit for dissolved selenium in these analyses was as low as 1 μ g/L.

24 

### EPA suspects that in a very limited number of deck wash samples (deck wash samples from two shrimping vessels), measured concentrations of dissolved and total arsenic may be elevated due to positive interference from major seawater cations.

25 

### EPA suspects that in a limited number of deck wash samples (i.e., deck wash samples from two shrimping vessels and two tow/salvage vessels), measured concentrations of dissolved and total selenium may be elevated due to positive interference from major seawater cations.



## 146Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Deck washdown water samples collected from 29 of the 31 vessels sampled contained dissolved copper concentrations that exceeded the saltwater chronic aquati c life criterion of 3.1 μg/L. Dissolved copper concentrations ranged from2.5 μg/L for a tug and fishing (trawler) boat to 204 μg/L for the supply boat. The dissolved co pper concentrations in deck washdown samples from the tug and assorted fishing boats were evenly distributed acro ss the entire range of measured dissolved copper concentrations, whil e the tow/salvage, fire , taxi, tour, and supply boats all had relatively high dissolved copper concentrations (above 30 μg/L).

Dissolved lead concentrations exceeding the freshwater chronic aquatic life criterion (2.5 μg/L) were limited to just three (of nine) tugboats , five (of six) tow/salvage boats, one of the two tour boats, and the fire and supply boats. Di ssolved lead concentrations exceeding chronic aquatic life criterion co ncentrations ranged from 2.9 μg/L fo r one of the tugboats to 53.5 μg/L for the supply boat.

Similar to dissolved copper, dissolved zinc in deck washdown samples collected from the majority of vessels sampled (22 of 31) exceeded the most stringent 2006 NRWQC - the saltwater chronic aquatic life criterion of 81 μg/L. In contrast to dissolved copper, however, only the deck washdown samples from the various types of fish ing boats appeared to be evenly distributed throughout the entire measured disso lved zinc concentration range, while dissolved zinc in deck washdown water samples collected from all the t ugboats exceeded the criterion. Dissolved zinc concentrations in deck washdown water samples ranged from 16 μg/L for a fishing vessel (the gillnetter) to 1,200 μg/L for one of the tugboats. All but one of the tow/salvage boats produced dissolved zinc in deck washdown water samples ex ceeding the criterion, as did the tour, fire, and supply boats (the last with a measured di ssolved zinc concentration of 465 μg/L).

For the other dissolved metals (chromium, nickel, and selenium) where measured
concentrations exceeded the saltwater and/or fres hwater criteria in one or more of the deck washdown water samples, the PHQs were generally less than two (most likely less than one for
dissolved selenium after consider ing there may be elevated measured concentrations as a result of positive interference for the four samples with measured dissolved selenium concentrations exceeding 5 μg/L )



## . For both chromium and nickel, the tow/sa lvage vessel type had the greatest
number of dissolved metal concentration exceedances for their respective most stringent criteria. No information was available concerning the fr equency of deck washdowns for the supply vessel, although this particular vessel is known to transport pe troleum products, and its deck appeared visibly “soiled” to the samplers. According to the surveys, the tow/salvage boats generally undergo deck washdowns once to tw ice per week, about the same frequency as tugboats, but less frequent than the fishing and tour boats.

Four of the total metals (aluminum, arse nic, iron, and manganese) exceeded the most stringent 2006 NRWQC in approx imately half (manganese) or all the deck washdown water samples (aluminum, arsenic, and iron), although samp le concentrations of these metals appear to

147Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## be greatly influenced by surrounding ambient water concentrations (see Table 3.3.3). T his pattern was identical to the one observed for bilgew ater discharge. In contrast to the bilgewater samples, about half the deck washdown water samples for a fifth metal (antimony) exceeded the most stringent 2006 NRWQC in the deck was hdown water samples, as shown in Figure 3.3.4. PHQs for total arsenic ranged from 56 to 4,600. A ll of the total arsenic concentrations exceeded the most stringent human health (water plus or ganism consumption) criterion of 0.018 μg/L, as well as the human health criterion for organi sm consumption alone, 0.14 μg/L. The protective
human health criteria values for total arsenic are driven by the carcinoge nic potential of this metalloid. However, when compared to the less st ringent saltwater chronic aquatic life criterion for arsenic of 36 μg/L, only five of the 31 vessels produced total arsenic concentrations in deck washdown water samples that exceeded this less stringent criterion, and the corresponding PHQs ranged only from 1.0 to 2.3. These total arseni c exceedances were found on a shrimping vessel (positive interference may ha ve elevated the measured concentration, see footnote 24 ), three (of the six) tow/salvage vessels, and the fire boat. In fact, the total arsenic concentrations in deck washdown water samples from all six of the tow/sa lvage boats were close to or within the upper quartile of samples.

Figure 3.3.3 displays the distri bution of PHQs based on the most conservative (most protective) screening benchmark for each of the di ssolved metals. PHQs for four of the dissolved metals (cadmium, copper, lead, and zinc) incl ude values from grea ter than 10 to over 100, indicating that the measured concentrations were one or more orders of magnitude greater than the most conservative screening benchmark. In addition, although the mean dissolved selenium PHQ was less than one, there were two m easured occurrences where PHQ exceeded 10, however, the high measured concentration of dissolved selenium in these two samples are likely due to positive interference, see footnote 25 ). PHQs exceeding one were also observed for
dissolved chrom ium and nickel, bringing to seve n the number of dissolved metals that exceeded the most stringent 2006 NRWQC in one or more deck washdown water samples.

PHQs for total aluminum were also hi gh, ranging from 7.5 to 150, followed closely by total iron, with PHQs ranging from 3.1 to 48. For both metals, the majority of tug and tow/salvage boats were consisten tly above the median (middle concentration of the range) of total metal concentrations (in addition to the fi re and supply boats), whil e the fishing boats were below the respective median total metal concentr ations. Conversely, only three of the PHQs for total manganese exceeded a value of 5 (a tugboat, the supply boat, a nd the water taxi).

The frequency of PHQ exceedances for antimony, like total arsenic, ar e driven by the low human health (water plus organism consumpti on) criterion of 5.6 μg/L (the human health criterion for organism consumption alone (640 μg/L ) is much higher). Only five of the 19 vessels from which deck washdown water samples were obtained had PHQ below 1, and were collected from the supply, fire, recreational, and two of the salvage vessels. Among the PQHs for antimony that were greater than 1, the low P HQ of 5.2 corresponded with the supply boat, and

148Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## the high PHQ of 47 corresponded with a tow/salv age vessel – a PHQ value three times higher
than in the r ecreational vessel (PHQ = 15).

From the perspective of potential risk, the di scharges of metals where dissolved and total
concentrations exceed EPA’s most stringent criteria correlate most strongly to utility, passenger, or general service vessels such as the supply boa t, tow/salvage boats, tugboats, water taxi, and fire boat. Commercial fishing vessels may not be a source of concern except for metals such as dissolved copper.

EPA tested the hypothesis that the utility, service, and passenger vessels (referred to as nonfishing vessels) discharged metals at higher concentrations than fishing vessels per discharge event using two approaches. For both approaches , 20 nonfishing vessels (the tow/salvage boats, tugboats, tour vessels, fire boat, water taxi, and supply vessels) we re compared to the 10 fishing vessels (six shrimping vessels, two trawlers, one troller, and a gill netter). For the analysis, when multiple minimum detection limits were repor ted for a particular metal, the minimum
concentration was set to 1⁄2 of th e highest reporting limit. This mo re conservative approach was
chosen to reduce the likelihood of detecting a difference that wa s not a “true” difference (Type I error).

For the first approach, a subset of the metals with the highest fre quencies of screening benchmark (NRWQC) exceedance from the nonfishing ve ssels were compared to those from the fishing vessels. Although there is no NRWQC for total lead, th is metal was used in these analyses because of the high proportion of nondetect s in the dissolved form. This analysis was performed using modified t-tests for unequal sa mple sizes and uneven variances (see Table 3.3.4). Concentrations of dissolved zinc and to tal lead were signifi cantly higher in deck washdown discharges of non-fish ing vessels (e.g., tug boats) than fishing vessels. Although concentrations of total arsenic were not signi ficantly different between nonfishing and fishing vessels, when the six tow/salvage vessels were compared to the remaining 24 vessels, total arsenic concentrations in the tow/salvage vessels were significantly higher than in other vessels (Table 3.3.4). When this analysis was performed for dissolved lead desp ite the occurrence of nondetects, the results were the same (i.e., concentr ations of dissolved lead in industrial vessels were higher than in fishing vessels).

For the second approach, mean concentrations for both dissolved and total forms of the heavy metals (cadmium, chromium, copper, lead, nickel, zinc) were compared using an exact binomial test. This approach assumes that, even if the difference in mean concentrations between nonfishing and fishing vessels for any given metal is not statistically si gnificant, if the mean metal concentrations from a particular vessel cla ss are always or nearly always lower than those of another class of vessels, then the overall tre nd may be statistically significant. Both dissolved
and total metals concentrations of all six heavy metals were higher in nonfishing vessel discharges than in fishing vessel discharges (see Table 3.3.5). A bino mial test was then

149Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## performe d to determine whether the overall patt ern of lower mean metal concentrations in fishing vessel discharges could be attributed to chance, assuming an equal likelihood that concentrations in fishing vessels or industrial ve ssels would be lower. The probability that mean
concentrations of all six metals (either dissolved or total) wo uld be lower in fishing vessels compared to nonfishing vessels, given an equa l likelihood of either outcome occurring, was statistically significant (P = 0.016). The probability of concentrations being lower in fishing vessels for all 12 comparisons (six dissolved metals + six total metals) was also statistically significant (P = 0.0002). The mean concentrations of these heavy metals by vessel class are
shown in Table3.3.5. Results of th is analysis support the assertion that metals from deck washdown discharges from nonfishing (utility, serv ice, and passenger) vesse ls tend to be higher than metals from deck washdown discharges from fishing vessels for each discharge event.

One possible explanation for the higher metal co ncentrations in nonfishing vessels is that the frequent washing of fishi ng vessels’ decks may prevent metal build-up and keep metal
concentrations lower in each indivi dual deck washdown discharge.

With regard to assessing potential risk, it is important to understand that, for most of the metals identified above as of potential c oncern in deck washdown water, maximum metal
concentrations in the ambient or potable water used for deck wa shdown (see left two thirds of Table 3.3.3) were higher than the median metal c oncentrations in deck washdown water samples (Table 3.3.1). The ambient receiving waters to which these deck washdown waters are being discharged have metal concentrations that often exceed the most stringent NRWQC (see far right column of Table 3.3.3). The relatively high metals concentrations for four dissolved metals (copper, manganese, nickel, zinc) in potable water and four total metals (aluminum, arsenic, iron, lead) in ambient water can at le ast partially account for the high concentrations of metals found in some of the deck wash discharges. Furtherm ore, based on corresponding concentrations of the major seawater cations (calcium, magnesium, sodium, and potassium) in the deck washdown water samples (see Table 3.3.1), few, if any, of the potentially toxic dissolved metal concentrations are likely to be bioavailable to biological organisms because of the high hardness values, which reduce metal bioavailability.

In summary, metals were frequently detect ed in deck washdown water samples, with certain metals occurring much more frequently at levels that may have potential for risk than others. EPA found high concentrations of a numb er of dissolved and total metals in these samples. Dissolved cadmium, copper, lead, nickel and zinc were consistently elevated above the most conservative screening benchmarks, with all the PHQ values in the 1 to 100 range. However, dissolved cadmium concentrations measured in deck washdown water samples were only detected in two of 31 vessels. For these and other metals (total aluminum, arsenic, iron, and manganese), concentrations measured in most if not all of the water samples exceeded saltwater and/or freshwater criteria, however they genera lly did not exceed concentrations in the ambient

150Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 151 or potable water used for washdown, and would ge nerally not be bioavailable to organisms in

seawater.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.3.1. Results of Deck Washdown/Runoff Sample Analyses for Metals1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Heavy and Other MetalsAluminum, Dissolvedμg/L3128904202601.73157011001900NAAluminum, Totalμg/L31309734001900820990470083001300087Antimony, Dissolvedμg/L199477.34.21391NAAntimony, Totalμg/L191368261.929862605.6Arsenic, Dissolved3μg/L3119616.42.39.8132836Arsenic, Total3μg/L312374188.32949830.018Barium, Dissolvedμg/L191910063422327336996280NABarium, Totalμg/L1919100270100525970160130014001000Cadmium, Dissolvedμg/L31261.3220.25Cadmium, Totalμg/L315162.01.736NAChromium, Dissolvedμg/L3117555.12.39.1161811Chromium, Totalμg/L31299434243.18.35584130NACobalt, Dissolvedμg/L1912632.71.33.98.214NACobalt, Totalμg/L1918956.04.11.12.06.72026NACopper, Dissolvedμg/L31299442235.67.2591202003.1Copper, Totalμg/L31311001301106.412471603405301300Iron, Dissolvedμg/L191263520190110011003000NAIron, Totalμg/L19189544002300950170053001300015000300Lead, Dissolvedμg/L3115486.04.719542.5Lead, Totalμg/L31309748233.68.042160260NAManganese, Dissolvedμg/L31299460352.71191200240NAManganese, Totalμg/L312890210984.3553005401300100Nickel, Dissolvedμg/L3119616.94.88.213178.2Nickel, Totalμg/L31258116126.21827100610Selenium, Dissolved4μg/L3117558.91.12.125825.0Selenium, Total4μg/L3112399.51.82396170Thallium, Dissolvedμg/L19150.643.2NAVanadium, Dissolvedμg/L1914741.91.32.05.27.6NAVanadium,Totalμg/L1916849.86.22.99.82058NA152Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment153Table 3.3.1. Results of Deck Washdown/Runoff Sample Analyses for Metals1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Zinc, Dissolved μg/L 31 31 100 260 120 16 35 51 430 620 1200 81Zinc, Totalμg/L 31 31 100580 330 20 52 150 720 1400 4000 7400Cationic MetalsCalcium, Dissolved μg/L 31 31 100 73000 34000 5900 25000 32000 83000 190000 320000 NACalcium, Total μg/L 31 31 100 77000 39000 7300 27000 34000 88000 190000 310000 NAMagnesium, Dissolved μg/L 31 31 100 130000 14000 6600 7000 7900 59000 510000 1000000 NAMagnesium, Total μg/L 31 31 100 130000 19000 6800 7800 9200 59000 510000 1000000 NAPotassium, Dissolved μg/L 19 19 100 30000 8000 3300 4000 5400 24000 140000 180000 NAPotassium, Total μg/L 19 19 100 30000 8100 3600 3900 5600 25000 130000 180000 NASodium, Dissolved μg/L 19 19 100 510000 79000 26000 38000 45000 410000 2800000 3600000 NASodium,Total μg/L 19 19 100 510000 78000 24000 38100 45000 400000 2600000 3600000 NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.(3) See footnote24.(4) See footnote25.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Table 3.3.2. Dissolved-to-Total Metal Ratios (f d 

## s) in Paired Deck Washdown/Runoff Samples

Summary Statistics of Dissolved:Total Metal Ratios Calculated for Select Metals Metal
Geomean Median Min Max

Aluminum 0.10 0.12 0.010 1.00

Iron 0.12 0.090 0.050 0.33

Lead 0.14 0.18 0.030 0.62
Chromium 0.16 0.13 0.060 0.76

Vanadium 0.25 0.26 0.12 1.13 Manganese 0.25 0.28 0.010 0.93 Antimony 0.30 0.34 0.14 0.64 Copper 0.33 0.34 0.050 1.04

Arsenic 0.38 0.47 0.060 0.93
Cadmium 0.48 0.49 0.36 0.62

Nickel 0.50 0.53 0.17 0.93
Cobalt 0.53 0.52 0.26 1.25

Zinc 0.54 0.54 0.18 2.95
Selenium 0.89 0.89 0.61 1.30



## Table 3.3.3. Minimum and Maximum Dissolved a nd Total Metal Concentrations in Vessel Source 1 

## and Ambient 2 

## (Harbor) Water Relative to Med ian Sample Concentrations and Most Stringent Screening Benchmarks

Metal Source Water Conc. (min) Source Water Conc. (max) N Median Conc. From Table 3.3.1 Ambient Conc. (min) Ambient Conc. (max) N Most Stringent Screening BM

Aluminum, Dissolved 6.3 310 6 258 0 870 12 NA Aluminum, Total 8.6 250 6 1900 44.5 3950 15 87 Arsenic, Dissolved 0 1.9 3 2.3 2 26 8 36 Arsenic, Total 0 1.8 3 8.3 2.9 28.9 8 0.018 Copper, Dissolved 2.4 36 5 23.1 0 24.2 10 3.1 Copper, Total 2.6 51 4 109 0 23.3 11 1300 Iron, Dissolved 0 0 1 189.5 226 259 2 NA Iron, Total 0 801 4 2330 114 4180 8 300 Lead, Total 1.2 6 2 23 0 3.1 3 2.5** Manganese, Dissolved 0 33 6 34.8 0 106 11 NA Manganese, Total 3.6 37 6 97.8 8.3 165 13 100 Nickel, Dissolved 0 3 4 4.8 2.3 7.2 10 8.2 Nickel, Total 0 2.7 4 12 2.4 16.7 11 610 Selenium, Dissolved 0 1.6 3 1.1 1.7 75.5 3 

### 8 5



## 154Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Table 3.3.3. Minimum and Maximum Dissolved a nd Total Metal Concentrations in Vessel Source 1 

## and Ambient 2 

## (Harbor) Water Relative to Med ian Sample Concentrations and Most Stringent Screening Benchmarks

Metal Source Water Conc. (min) Source Water Conc. (max) Median Most

N Conc. Ambient Ambient Stringent From Table 3.3.1 Conc. (min) Conc. N Screening (max) BM

Selenium, Total 0 1.9 2 0 19.4 3 

### 86.5 3 

### 6 170 Zinc, Dissolved 4.1 1200 6 124 0 116 13 81 Zinc, Total 4.1 1100 6 331 0 23.9 15 7400 N = sample size. (1) Ambient water was collected from background water surrounding the vessel sampled. (2) Source water was collected from the city tap wa ter supply while pierside, except for one tugboat in Havre De Grace, Maryland, where source water was collected from a potable water storage tank on the vessel (service water) that was filled with city water. (3) As discussed in footnote 25 , EPA suspects positive interference may have resulted in these high measured co nce ntrations of total and dissolved sele nium detected in ambient deck wash samples.



## Table 3.3.4. Comparison of Metal Concentratio ns in Deck Washdown Discharge Between Fishing Vessels and Non-Fishing Vessels 1



### Welch’s Modified Average Metal Concentration (μg/L) by Vessel Type 2-Sample t-Test Metal Form Fishing Non-Fishing t df P<|t α /2 

### | Copper Dissolved 27.7 50.7 -1.68 18.2 0.110 Nickel Dissolved 6.19 7.23 -1.05 20.7 0.306 Zinc Dissolved 161 314 -2.15 14.9 0.049 Arsenic 2 

### Total 14.0 20.5 -0.49 19.8 0.629 Lead Total 5.48 70.7 -3.76 19.1 0.001 Notes: (1) Nonfishing vessels defined as tow/salvage vessels, t ugboats, tour vessels, fire boat, water taxis, and supply vessels. The recreational vessel is not a study vessel and was excluded from these analyses. (2) Total arsenic concentrations discharged from the si x tow/salvage boats were significantly higher than for the other 24 vessels (Welch’s Modified 2-Sa mple t-test, t=-5.26, P<0.001, on 16.7 df).



## 155Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Table 3.3.5. Mean Concentrations of Dissolved and Total Heavy Metals from Deck Wash Discharges from Fishing Ve ssels and Nonfishing Vessels 1,2



### Conc. (μg/L) in Conc. (μg/L) in Metal Form Fishing Vessels n Not Det. (%) Non-Fishing Vessels n Not Det. (%) Cadmium Dissolved 0.750 10 100 1.86 20 90 Chromium Dissolved 3.79 10 70 5.93 20 35 Copper Dissolved 27.7 10 0 50.7 20 0 Lead Dissolved 2.00 10 100 8.85 20 45 Nickel Dissolved 6.19 10 40 7.23 20 40 Zinc Dissolved 161 10 0 314 20 0

Cadmium Total 2.00 10 100 3.77 20 90 Chromium Total 15.7 10 20 42.3 20 0 Copper Total 93.2 10 0 157 20 0 Lead Total 5.48 10 10 70.7 20 0 Nickel Total 8.65 10 40 19.4 20 10 Zinc Total 207 10 0 791 20 0 Notes: (1) Nonfishing vessels defined as tow/salvage vessels, tugboats, tour vessels, fire boat, water taxis, and supply vessels. The recreational vessel is not a study vessel and was excluded from these analyses. (2) F or these comparisons, minimum concentrations were set at 1⁄2 of the reporting limit of the highest minimum detection level, when multiple detection limits were present. Average concentrations of dissolved and total forms of all six heavy metals were lower in fishing vessels than in nonfishing vessels.



## 156Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 157 Figure 3.3.1. Box and Dot Density Plot of Diss olved Metals Concentrations Measured in Samples of Deck Washdown Water (Note: As discussed in footnotes 24 and 25 , EPA suspects positive interfence may have resulted in elevated measured concentrations for a limited number of deck wa sh samples analyzed for dissolved arsenic and dissolved selenium). A l u

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C o n c e n t r a t io n ( u g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 158 Figure 3.3.2. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Deck Washdown Water (Note: As discussed in footnotes 24 and 25 , EPA suspects positive interfence may have resulted in elevated measured concentrations for a limited number of deck wash samples analyzed for total arsenic and dissolved selenium). Al u

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C o n c e n t r a t io n ( u g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 159 Figure 3.3.3. Box and Dot Density Plot of Pote ntial Hazard Quotients for Dissolved Metals in Samples of Deck Washdown Water (Note: Replacement values for non-detects are circled. Also, as discussed in footnotes 24 and 25 , EPA suspects

po sitive interfence may have resulted in elevated measur ed concentrations for a limited number of deck wash samples analyzed for dissolved arse nic and dissolved selenium). A

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## Figure 3.3.4. Box and Dot Density Plot of Pote ntial Haza rd Quotients for Total Metals in Samples of Deck Washdown Water (Note: Replacement values for non-detects are circled. Also, as discussed in footnotes 24 and 25 , EPA suspects

po sitive interfence may have resulted in elevated measur ed concentrations for a limited number of deck wash samples analyzed for total arsenic and dissolved selenium).



## 160Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.3.2 Classical Po llutants

Deck washdown water samples from 32 vessels were analyzed for 14 classical pollutants (see Table 3.3.6). The classical pol lutants include measurements that are physical properties (temperature, conductivity, salin ity, turbidity, TSS), oxygen consumption (BOD, COD), oil and grease (HEM and SGT-HEM), as well as chemical concentrations (pH, sulfide, DO, and TRC).

Measured values of the physical properti es of the discharge (conductivity, dissolved oxygen, pH, temperature, salinity) are unremarkable and appear to reflect conditions at the time (seasonality) and location (geographical) of sampling. For instance, conductivity and salinity in deck washdown water appear to reflect the type of source water used (ambient or potable service/city 26 

## water), as shown by the measured values of these two parameters. Half the fishing vessels appear to have used ambient saltwater during normal operations (six of 11 vessels), while the remaining fishing boats and nearly all othe r vessel types (tugs, tow/salvage, tour, supply boats) used a freshwater source (aboard the vessel or pierside). Levels of pH were generally about neutral (between 7 and 8), with the only exceptions being two tugboats where the pH was 9.1 and 9.8 (relatively high). Temperature of the deck washdown water ranged from 7.5 to 32 o 

## C and varied according to month (season) sampled and geographic location (warmer water samples
in southern United States and co lder in mid-Atlantic and nort hern states). Dissolved oxygen (DO) in deck washdown samples was sufficientl y saturated (50 percent plus; DO ranged from 5.5 to 10.5 mg/L) in all samples, except for low DO concentrations from three fishing vessels participating in the north Pacific fish ery, which ranged from 1.6 to 1.9 mg/L.

Figure 3.3.5 illustrates the variabil ity of the values measured for the classical pollutants
in deck washdown water. Turbid ity (measure of water clarity) a nd TSS are clearly related and range from 4.1 to 460 NTU and 31 to 530 mg/L, respectively. Measured values above the median concentrations were dominated by the tug, tow/salvage, supply, fire, and water taxi boats for both parameters, while measured values below the median were largely from the fishing boats (with only a few exceptions). EPA notes that the majority of deck washdown samples from fishing vessels were taken while the vessel was s horeside, and do not reflect constituents of deck washdown while the vessel is engaged in fishin g operations. Potable water measured during the study was low in turbidity (0 to 16 NTU) and T SS (0 mg/L), as was ambient (harbor) water, except for waters sampled in the Gulf Coast (L ouisiana). Ambient turbidity and TSS were as high as 186 NTU and 98 mg/L, respec tively, in a sample collected fr om one harbor in Louisiana.

Of the remaining parameters, BOD, COD, a nd TOC have quite high concentrations (see Figure 3.3.5). While the measured values for thes e parameters in deck washdown water samples were generally evenly distributed for the differe nt vessel types across th e entire concentration

26 

### Service water here means the vessel potable water supply. For study vessels, vessel service water generally originates from municipal water supply rather than produced on board. When deck washdown is performed pierside most vessels used city water as their source water. Many fishing vessels and at least one tugboat use ambient water as their water source when performing d eck washdown offshore or underway.



## 161Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## range, a select few vessels were clear standouts: three tugboats, a fishing (shrimping) vessel, and the supply boat. The concentrations of all three param eters were highly variable and span two orders of magnitude. In contrast, measured su lfide concentrations from deck washdown water samples collected from two fishing boats and a tow/salvage boat were all relatively low, but, when compared to the most stringent NRWQ C of 0.002 mg/L, had PHQs ranging from 2.5 to 8.5 (moderate exceedance - data not shown).

PHQs were calculated for three additional classical pollutants for which benchmarks were available and are shown in Figure 3.3.6. As the figure shows, the TRC concentrations
where TRC was detected above the reporting limit of 0.10 mg/L greatly exceeded the benchmark (most stringent NRWQC of 0.0075 mg/L , the saltwater chronic aquatic life criterion) by factors that ranged from 23 (tow/salvage vessel) to 106 (exceedance by 2 orders of magnitude – a fishing vessel). These concentr ations (ranging from 0.17 to 0.80 mg/L) were measured in deck washdown water samples collected from three (of the 11) fishing vessels, the two tour boats, a tugboat, and the tow/salvage boat. It is worth poin ting out that in one inst ance (i.e., for a tugboat with a high TRC concentration of 0.39 mg/L), th e measured TRC concentration in the source (potable) water was 0.70 mg/L. It is also worth noting that only one of 11 respondents (a fishing vessel) indicated using chlorine bleach while wa shing decks, and this particular vessel had a
measured TRC concentration in the deck wa shdown sample of 0.38 mg/L and a PHQ of 51.

TSS in most of the deck washdown water samples collected exceeded the secondary
treatment effluent limitation benchmark of 30 mg/L. However, 27 of 32 PHQs calculated for these samples were below 10 (Figure 3.3.6), and a ll five TSS samples with PHQs>10 (max PHQ = 17.7) were associated with tugboats. As discus sed above, in the one potable water sample for which TSS was measured, TSS was not detected.

BOD was measured in 22 deck washdown wa ter samples that exceeded EPA’s secondary treatment effluent limit of 30 mg/L (Figure 3.3.6 ). As indicated above, the vessels with the highest level of exceedance (PHQs > 5) were associated with three tugboats, a fishing (shrimping) vessel, and the supply boat.

EPA compared HEM and SGT-HEM concentrations measured in deck washdown samples to the existing international and U.S. regulatory limit of 15 ppm (15 mg/L) for oil and grease discharge. HEM and SGT-HEM were det ected in all of the deck washdown water samples, with concentrations ranging from 1.2 to a very high 133 mg/L for HEM and 0.91 to a comparably high 84 mg/L for SGT-HEM. Based on the regulatory limit of 15 mg/L, PHQs exceeded one in only six of 29 vessels sampled for HEM and two in the 29 vessels sampled for SGT-HEM. The highest PHQs for both paramete rs corresponded with the supply boat and a tugboat, with PHQs of 4.7 and 8.9 for HEM a nd 1.2 and 5.6 for SGT-HEM, respectively. Note, oil and grease were not detected in the two potable water samples collected in this sampling

program.

162Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 163 To summarize, just under a third of the vesse ls sampled had concentrations of TRC in deck washdown samples above the reporting limit of 0.10 mg/L. Of these seven samples, the measured TRC concentrations (as high as 0.80 mg /L) that exceeded the screening benchmark were not associated with any one particular cla ss of vessel. For TSS, however, one vessel type (tugboats) had the highest number of exceedances. The elevated TSS in deck washdown water samples from tugboats may be caused by a less frequent washdown on these vessels compared with vessels such as fishing vesse ls. Just over two-thirds of vesse ls (22 out of 32) exceeded the most stringent screening benchmark for BOD; however, as in the case with TRC, no one particular class of vessels had a higher number of exceedances than other classes.

Oil and grease are generally not of concern for this type of discharg e, nor are any of the other physical parameters that were measured (conductivity, dissolved oxygen, pH, temperature, salinity). TOC was detected in al l samples ranging from 3.6 to a very high 350 mg/L (one of the tugboats with high HEM). Organic carbon strongly complexes metals in both freshwater and saltwater matrices, and like the competing ca tions such as calcium and magnesium, renders dissolved metals less bioavailable and less likely to be rapidly available fo r biological organisms.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.3.6. Results of Deck Washdown Water Sample Analyses for Classical Pollutants1AnalyteUnitsNo.samplesNo.detectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Biochemical Oxygen Demand(BOD)mg/L323094110564.7149237083030Chemical Oxygen Demand(COD)mg/L323210039016024529057012001800NAConductivitymS/cm26261007.71.00.240.370.50133047NADissolved Oxygenmg/L26261007.27.71.61.86.38.99.711NAHexane Extractable Material(HEM)mg/L292690142.81.7123913015pHSU30301007.77.67.07.07.27.98.59.8NASalinityppt24241004.90.600.100.200.238.02128NASilica Gel Treated HEM(SGT-HEM)mg/L2922767.01.70.453.8138415Sulfidemg/L32670.0110.0110.0170.0170.017NATemperatureC313110021217.59.013293132NATotal Organic Carbon (TOC)mg/L252510044243.65.07.15296350NATotal Residual Chlorinemg/L317230.120.370.800.0075Total Suspended Solids(TSS)mg/L323210017012027315925047053030TurbidityNTU31311001501104.13658190380463NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.164Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 165 Figure 3.3.5. Box and Dot Density Plot of Classi cal Pollutants Measured in Samples of Deck Washdown Water 

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## 166Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.3.3 Pathogen Indicators (Microbiol ogicals)

Selected deck washdown water samples we re analyzed for the pathogen indicator
bacteria E. coli , enterococci, and fecal coliform. Sampli ng for pathogens was limited to fishing vessels since EPA could not identify likely poten tial sources of pathogens in deck washdown discharges on other vessel types. EPA targeted se lect fishing vessels to attain the best crossrepresentation possible based on available funding and proximity to qualified subcontractor laboratories to meet sample hold times (< 6 hours). The types of fishing vessels sampled included three shrimping (trawler) boats in Louisiana, two ground fi shery trawlers in Massachusetts, and a gillne tter boat in Alaska. All vessels indi cated that their decks are washed frequently throughout the day (after or between catches, after unloa ding, etc.), and while pierside and underway (nearshore and farshore). Tabl e 3.3.7 summarizes the analytical results. Concentrations were determined for each pathogen using the same ( E. coli , enterococci) or comparable methods (fecal coliform).

Figure 3.3.7 shows the variability of the values measured for the pathogens in deck washdown water samples from the various fish ing vessels. Measured concentrations of E. coli range from 20 MPN/100 ml for one of the shri mping trawlers to 8,336 MPN/100 ml for one of the ground fishery trawlers in Massachusetts. It should be noted, however , that the water the ground fishery trawler used for desk washing wa s ambient (harbor) water receiving stormwater
and combined sewer overflow from a stor m event. The measured concentration of E. coli in the
ambient water at that locati on was 24,200 MPN/100 ml. Excluding th is outlier, the concentration
of E. coli from only one vessel (shrimper; concentr ation = 650 MPN/100 ml) exceeded EPA’s most stringent freshwater bathing NRWQC of 1 26 MPN/100 ml by more than a factor of five (PHQ = 5.1), as illustrated in Figure 3.3.8. EPA collected multiple samples from another shrimping vessel in Louisiana to measure E. coli in prefishing deck washdown water, postfishing water, without catch rinse water, and w ith catch rinse water. For this vessel, E. coli concentrations ranged from a low of 10 (prefi shing sample) to a high of only 50 MPN/100 ml (without catch rinse). Th e concentrations of E. coli were largely unaffected by either the addition of catch to the vessel (as E. coli concentrations in prefishi ng and postfishing deck washdown samples were similar) or the process of rinsing the catch while on deck.

The enterococci values measured in a deck washdown water samples ranged from 1.5 to 1,300 MPN/100 ml, and follow the same general pattern as E. coli (Figure 3.3.7). Excluding the previously described example of the trawler in Massachusetts, which was directly influenced by high levels of enterococci in the ambient water resulting from storm-related combined sewage overflow (5,100 MPN/100 ml), the deck washdow n water samples from two vessels (both shrimpers; concentrations = 637 and 914 MPN/ 100 ml, respectively) exceeded EPA’s most stringent bathing NRWQC for enterococci of 33 MPN/100 ml (freshwate r) and 35 MPN/100 ml (saltwater) by factors of n early 20 and 30 respectively (F igure 3.3.8). In contrast to E. coli

, however, analysis of th e multiple samples collected for enteroco cci in prefishing deck washdown

167Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 168 water (540 MPN/100 ml), postfishing water (8 MPN/100 ml), wit hout catch rinse (1,200 MPN/100 ml), and with catch ri nse (801 MPN/100 ml) for the sh rimping vessel in Louisiana indicate that their deck washing process appeared to reduce the pr esence of the pathogen in deck washdown discharge.

The concentrations of fecal coliform bact eria measured in a deck washdown water samples are all substantial (ra nging from 91 to 600 CFU/100 ml 27 

## ), except for the very low concentration of 0.75 CFU/100 ml for the gilln etting vessel in Alaska (Figure 3.3.7). The associated PHQs for fecal coliform range from 0.05 (gillnetter) to 43 (one of the shrimping boats), as illustrated in Figure 3.3.8. The PHQs fo r this pathogen are based on the NRWQC of 14
MPN/100 ml for shellfish harves ting. As with enterococci

, the multiple samples measured for fecal coliform bacteria in prefishing deck wa shdown water (0 CFU/100 ml), postfishing water (6 CFU/100 ml), without catch rinse (1,630 CFU/10 0 ml), and with catch rinse (620 CFU/100 ml) for the shrimping vessel indicate th at their deck washing process di d not increase (and seemed to reduce) the presence of this pathogen in d eck washdown discharge. The single potable water sample taken while onboard a shrimping vessel pi erside in Louisiana was free of all pathogens.

The data collected for this study show that , while the three groups of pathogens are present in deck washdown discharge samples from commercial fi shing vessels, concentrations are variable, and the source of the water used for deck washdown can greatly influence the background bacteria levels. Of the three pat hogen groups, fecal coliform are present at concentrations exceeding EPA’s most stringent criteria more often than enterococci and E. coli

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### Excluding the outlier value of 8,050 CFU/ml from the ground fishery trawler in Maine influenced by the storm

event.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.3.7. Results of Deck Washdown WaterSample Analyses for Pathogen Indicators1Analyte2Units3No.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM4E. Coliby MPNMPN/100 ml551001900160202062450083008300130Enterococciby MPNMPN/100 ml551005806401.51.52711001300130033Fecal Coliform by MFCFU/100 ml6610016005600.750.756825008100810014Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reportinglimit for calculating average concentrations. The remaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) MPN = Most Probable Number; MF = Membrane Filtration.(3) CFU = Colony Forming Units.(4) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.169Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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## Figure 3.3.7 Box and Dot Density Plot of Path ogen Indicator Concentrations Measured in Samples of Deck Washd own Water (Note: Corresponding units are MPN/100 ml for E. coli and enterococci, and CFU/10 0 ml for fecal coliform).



## 170Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## E

. C o

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# Pathogen Indicators 0.1 1.0 10.0 100.0

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## Figure 3.3.8. Box and Dot Density Plot of Pote ntial Hazard Quotients for Pathogens in Samples of Deck Wash down Water

171Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.3.4 Nutrients

Deck washdown discharge was also characteri zed for nutrient levels . Nutrient pollution, including nitrogen, phosphorus, and nume rous micronutrients, is a component of certain vessel discharges and a major source of water quality degradation throughout the United States (USGS, 1999). Deck washdown discharges from all vessel types were expected to contain potentially high levels of phosphorus because of the wide-spread use of detergents for deck cleansing. Deck washdown discharges from commercial fishing vessels were also e xpected to contain potentially elevated ammonia concentrations for the same reason, as well as from biological wastes from
fish and shellfish catch. In addition to total phosphorus and total ammonia (as nitrogen), deck washdown water samples were also analyzed for nitrate/nitrite nitrogen (inorganic nitrogen) and TKN, the sum of organic nitrogen (including toxic ammonia nitrogen ) (see Table 3.3.8).

Concentrations of nitrate/nitrite nitrogen in deckwash discharge samples range from 0.025 to 6.5 mg/L (see Figure 3.3.9). An interesti ng note is that the deck washdown water samples for commercial fishing vessels of all types did not exceed 0.50 mg/L while all other vessels exceeded this value. The five highest ni trate/nitrite concentratio ns (ranging from 2.5 to 6.5 mg/L) were analyzed in samples from three tu gs and two tow/salvage vessels. It is important to note, however, that most samples of deck washdown on fishing vessels were collected onboard fishing vessels pierside and not when fi shing activity was occurr ing. In the two cases where deck washdown samples were collected wh ere fishing activities were taking place, the samples were collected towards the end of the deck washdown activity and may not have captured potentially higher levels of n itrate/nitrite from biological wastes.

The concentrations determined for TKN (sum of organic nitrogen) show the concentration range spans two or ders of magnitude, from 0.05 to 40 mg/L (see Figure 3.3.9). In contrast to the nitrate/nitrite samples, the T KN concentrations from all vessels were evenly
distributed across the entire co ncentration range. The two highes t TKN concentrations (by more than a factor of two) correspond to a trolling vessel and a tugboa t, with TKN concentrations of 28 and 40 mg/L, respectively.

Ammonia is the only nutrient form for which there are currently numeric NRWQC established to protect against its toxic effects. Only five of 31 ve ssels contained ammonia in deck washdown water samples slightly above (1.2 to 1.8 mg/L ammonia as nitrogen) the most stringent 2006 NRWQC of 1.2 mg/L, the freshwater chronic aquatic life criterion for total ammonia as nitrogen (see Figure 3.3.10). Thes e values correspond with deck washdown water samples collected from two tow/salvage boats, tw o fishing vessels, and the recreational vessel.

The benchmark for total phosphorus of 0.1 mg/L from the 1986 EPA Gold Book was exceeded in samples collected from all but one of the 31 vessels. The highest total phosphorus concentration of 22 mg/L from a tugboat exceeded the benchmark by a factor of 220 (see Figure

172Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 173 3.3.10). This concentration was 6.5 times higher then the next highest measured concentration of 3.4 mg/L from a trolling vessel. The deck wa shdown water samples for phosphorus from all vessels were generally evenly distribute d across the entire co ncentration range.

Total ammonia in ambient and service water ranged from below detection to 0.93 mg/L and from below detection to 0.73 mg/L, respectiv ely (all below the most stringent 2006 NRWQC of 1.24 mg/L). Total phosphorus in ambient and se rvice water ranged from below detection to 2.0 mg/L and from below detection to 0.52 mg/L, respectively (compared to 0.1 mg/L from the 1976 EPA Red Book).

In summary, out of the four nutrient para meters, only total phosphorus is likely a potential concern from deck wa shdown effluent. Twelve of the 19 respondents confirmed using standard liquid detergents aboard their vessels for deck washi ng, the expected source of total phosphorus in deck washdown discharges. Howeve r, ambient and domestic service water are also likely sources of phosphorus in a meaningful percentage of instances.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.3.8. Results of Deck Washdown Water Sample Analyses for Nutrients1AnalyteUnitsNo.samplesNo.detectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Ammonia As Nitrogen (NH3-N)mg/L31311000.530.320.0580.0740.100.811.51.81.2Nitrate/Nitrite (NO3/NO2-N)mg/L3227841.41.50.161.92.76.5NATotal Kjeldahl Nitrogen (TKN)mg/L3130976.03.61.41.86.61140NATotal Phosphorusmg/L31311001.70.790.0600.150.441.62.9220.10Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculated PHQs.174Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 175 Figure 3.3.9. Box and Dot Density Plot of Nutrie nt Concentrations Measured in Samples of Deck Washdown Water (Note: NH3-N=Ammonia as Nitrogen, NO 3/NO2-N= Nitrate/Nitrite Nitrogen, TKN=Total Kjeldahl Nitrogen, and Total Phosph (truncated)=Total Phosphorus). 

## NH 3

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# Nutrients 0.1 1.0 10.0

C o n c e n t r a t i o n ( m g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## NH 3

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## Figure 3.3.10. Box and Dot Density Plot of Pote ntial Haza rd Quotients for Nutrients in Samples of Deck Washdown Water (Note: NH3-N=Ammonia as Nitrogen, NO 3/NO2-N= Nitrate/Nitrite Nitrogen, TKN=Total Kjeldahl Nitrogen, and Total Phosph (truncated)=Total Phosphorus).



## 176Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 177 3.2.3.5 Long-Chain Nonylphenols

Deck washdown water samples from 29 ve ssels were analyzed for 27 long-chain alkylphenol ethoxylates: 16 NPEOs and 5 OPEOs (see Table 3.3.9). The NPEOs with the longest ethoxylate chains (i.e., less degr aded products (NP18EO through NP10EO)) were detected in slightly under a third of the vessels (nine of 29), with con centrations increas ing as ethoxylate chain is reduced (i.e., concentrations increa sing from NP18EO to NP10EO because the longerchain products found in commercial formulations are quickly degraded). The OPEO with the longest ethoxylate chain (OP12EO) was also detected in about a th ird of the vessels (see Table 3.3.9). As with NPEOs, the OPEO concentrations generally increase as the ethoxylate chain is reduced, except that no OPEOs with ethoxylate chains smaller than OP7EO were detected (similar to the situation in packing gland effluent; see Section 3.2.2.5 ).

Of the several vessels where NPEOs were detected in the longer (NP18EO through NP10EO) ethoxylated com pounds, only th ree of those vessels also ha d detectable concentrations
of NPEOs of the shortest chain (NP3EO), albeit at very low c oncentrations ranging from 0.80 to 29 μg/L. These were tow/salvage vessels, one of which confirmed using liquid detergent (Palmolive TM ) for deck washing (NP3EO concentration of 29 μg/L in deck washdown sample). A tugboat had the only measured concentration of OP8EO in its deck washdown water sample at a concentration of 19 μg/L.

Total NPEO concentrations could be cal culated from summed concentrations of individual chain lengths for five of the 29 vesse ls: three tow/salvage vess els and two tour boats (see Figure 3.3.11). The concentrations of total NPEOs ranged from 30 to 8,330 μg/L.

As discussed in previous subsections (see Sections 3.2.1.7 (bilgewater) and 3.2.2.5 (packing gl and effluents)), while there are no NRWQC for the sum of individual ethoxylate chains of NPEOs or OPEOs, these compounds will ultimately degrade to NP in fresh and salt water over time under all conditions. The NRWQC fo r NP in salt water based on chronic toxicity to aquatic organisms is 1.7 μg/L. EPA is uncer tain as to exactly how much NP might be generated from the degradation of NPEO and OP EO isomers under a given harbor scenario and water quality condition (see Section 1.6.6 of this re port). However, neither total NPEO or OPEO, nor any of the different isomers, were detected in ambient water at the locations where the vessels were sampled. Service wate r (generally city tapwater pier side) was not analyzed for longor short- chain nonylphenol a nd octylphenol ethoxylates.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.3.9. Results of Deck Washdown Water Sample Analyses for Long-Chain Nonylphenols1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Total Nonylphenol Polyethoxylatesμg/L2951754014008300NANonylphenol octodecaethoxylate (NP18EO)μg/L2912411.50.155.021NANonylphenol heptadecaethoxylate (NP17EO)μg/L299313.40.211341NANonylphenol hexadecaethoxylate (NP16EO)μg/L2910347.40.892787NANonylphenol pendecaethoxylate (NP15EO)μg/L29931140.9155160NANonylphenol tetradecaethoxylate (NP14EO)μg/L29931251.875290NANonylphenol tridecaethoxylate (NP13EO)μg/L29931442.9180480NANonylphenol dodecaethoxylate (NP12EO)μg/L29828644.5260760NANonylphenol undecaethoxylate (NP11EO)μg/L29931866.13501100NANonylphenol decaethoxylate (NP10EO)μg/L29931916.93501300NANonylphenol nonaethoxylate (NP9EO)μg/L29828883.13301300NANonylphenol octaethoxylate (NP8EO)μg/L29828753.22801100NANonylphenol heptaethoxylate (NP7EO)μg/L29724610.99220950NANonylphenol hexaethoxylate (NP6EO)μg/L2962134140440NANonylphenol pentaethoxylate (NP5EO)μg/L296211940270NANonylphenol tetraethoxylate (NP4EO)μg/L29414112.6120NANonylphenol triethoxylate (NP3EO)μg/L293104.90.8030NAOctylphenol dodecaethoxylate (OP12EO)μg/L298281.40.982.48.8NAOctylphenol undecaethoxylate (OP11EO)μg/L2926.91.87.8NAOctylphenol decaethoxylate (OP10EO)μg/L294143.61.82.1NAOctylphenol nonaethoxylate (OP9EO)μg/L295173.81.39.6NAOctylphenol octaethoxylate (OP8EO)μg/L2913.41019NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.178Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 0 2 4 6 8 10 12 14 16 18 20 22 24 

# Nonylphenols 0.01 0.10 1.00 10.00 100.00 1000.00

C o n c e n t r a t io n ( u g / L )



## Figure 3.3.11. Box and Dot Density Plot of No nylphenol Concentrations Measured in Samples of Deck Washd own Water Nonylphenol parameters are identified as follows: (1) Total Nonylphenol Polyethoxylates (2) Nonylphenol octodecaethoxylate (NP18EO) (3) Nonylphenol heptadecaethoxylate (NP17EO) (4) Nonylphenol hexadecaethoxylate (NP16EO) (5) Nonylphenol pendecaethoxylate (NP15EO) (6) Nonylphenol tetradecaethoxylate (NP14EO) (7) Nonylphenol tridecaethoxylate (NP13EO) (8) Nonylphenol dodecaethoxylate (NP12EO) (9) Nonylphenol undecaethoxylate (NP11EO) (10) Nonylphenol decaethoxylate (NP10EO) (11) Nonylphenol nonaethoxylate (NP9EO) (12) Nonylphenol octaethoxylate (NP8EO) (13) Nonylphenol heptaethoxylate (NP7EO) (14) Nonylphenol hexaethoxylate (NP6EO) (15) Nonylphenol pentaethoxylate (NP5EO) (16) Nonylphenol tetraethoxylate (NP4EO) (17) Nonylphenol triethoxylate (NP3EO) (18) Octylphenol dodecaethoxylate (OP12EO) (19) Octylphenol undecaethoxylate (OP11EO) (20) Octylphenol decaethoxylate (OP10EO) (21) Octylphenol nonaethoxylate (OP9EO) (22) Octylphenol octaethoxylate (OP8EO)



## 179Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.3.6 Volatile and Semivolat ile Organic Chemicals

VOCs and SVOCs were not targeted for deck washdown water sample collection in this study becau se these compounds were not expected to be found in common deck washdown on
most vessels 28 

## . In two cases during scheduled cleanings of the decks of two tow/salvage vessels, however, there was a noticeable oily sheen and wh ere fuel was spilled at the fueling location while samplers were onboard the vessels. Sample s of deck washdown water were taken in these instances and analyzed for VOCs and SVOCs (see Table 3.3.10).

Of the 70 VOCs that were analyzed for in the two deck washdown samples, only 12 were detected in one or more of the two samples. Of these 12 VOCs, only acetone, chloroform, and toluene were detected in both samples. In one sample from the vessel with the oily sheen; acetone was detected at 20 μg/L. Figure 3.3.12 cont ains all the samples that were detected, the other five samples were detected with very low values. Benzene, ethylbenzene, and xylene (compounds associated with fuel oil spills) we re detected in one of the two samples at surprisingly low levels. The PHQ of 13 for the be nzene sample that was below detection levels was an artifact of the relatively high reporti ng limit of 25μg/L compared to the screening benchmark of 2.2 μg/L. PHQs for only two VOCs, dibromochloromethane and bromodichloromethane exceeded the benchmark (s ee Figure 3.3.13), which were artifacts of the reporting limits which were as high as 25μg/L compared to the screening benchmarks of 0.4 μg/L and 0.55 μg/L, respectively. Both these were fo rmerly used as flame retardants and as an
intermediate in chem ical manufacturing.

Similarly, of the 62 SVOCs that were analy zed for in the two d eck washdown samples, only three were detected in one or more of the two samples: bis(2-ethylhexyl) phthalate, caprolactam, and di-n-butyl phthalate (data not s hown due to so few analytes detected). Levels
detected in the latter two SVOCs are unremarka ble. The concentration of bis(2-ethylhexyl) phthalate in the one sample where it was detect ed (i.e., the tow/salvage vessel with the oily sheen), however, was sufficiently high (6.7 μg/L) such that the associated PHQ, based on the most conservative screening benchmark of 1.2 μg/L (human health criteria), was 5.6 (data not shown). As previously noted, bis( 2-ethylhexyl) phthalate is a ma nufactured chemical that is commonly added to plastics to make them flexib le. Phthalates in general are known to interfere with reproductive health and liver and kidney f unction in both animals and humans (Sekizawa et

28 

### It is worth noting that solvents in cleaning agents may be used for certain activities such as above-water-line hull cleaning. Samples associated with above -water-line hull cleaning were not collect ed during this study because none of the vessels engaged in such an activity while EPA’s sampling crew was aboard the vessel. During a survey collected while onboard the vessels, however, 11 of 16 respondents confirmed that they do perform above-water-line hull cleaning occasionally on their vessels.



## 180Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 181 al., 2003; DiGangi et al., 2002). Bi s(2-ethylhexyl) phthalate was not detected in the associated ambient water sample collected at the site corr esponding with the two to w/salvage vessels, but di-n-butyl phthalate was (ambient concentration of 1.1 μg/L).

Di-n-butyl phthalate was the only SVOC detect ed in ambient water samples collected in association with the deck washdown samples coll ected in the study. No VOCs were detected in ambient samples.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.3.10. Results of Deck WashdownWaterSample Analyses for VOCs and SVOCs1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2VOCs1,2,4-Trimethylbenzeneμg/L2150130.300.300.300.30NA1,3,5-Trimethylbenzeneμg/L2150130.0900.0900.0900.090NAAcetoneμg/L2210013205.55.55.5202020NABenzeneμg/L2150130.30.30.30.32.2Bromodichloromethaneμg/L2150131.21.21.21.20.55Chloroformμg/L221001.31.51.01.01.01.51.51.55.7Dibromochloromethaneμg/L2150130.70.700.700.700.4Ethylbenzeneμg/L2150130.100.100.100.10530m-,p-Xylene (sum of isomers)μg/L2150250.400.400.400.40NAO-Xyleneμg/L2150250.200.200.200.20NATolueneμg/L221000.650.700.600.600.600.700.700.701300SVOCsBis(2-ethylhexyl) phthalateμg/L21504.76.76.76.76.71.2Caprolactamμg/L2210079100565656100100100NADi-n-butyl phthalateμg/L21502.52.42.42.42.42000Naphthaleneμg/L2150130.400.400.400.40NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.182Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 183 Figure 3.3.12. Box and Dot Density Plot of Vo latile Organic Chemical Concentrations Measured in Samples of Deck Washdown Water
VOCs are identified as follows: (1) 1,2,4-Trimethylbenzene (2) 1,3,5-Trimethylbenzene (3) Acetone (4) Benzene (5) Bromodichloromethane (6) Chloroform (7) Dibromochloromethane (8) Ethylbenzene (9) m-,p-Xylene (sum of isomers) (10) O-Xylene (11) Toluene 

# 0 2 4 6 8 10 12 VOCs 0.1 1.0 10.0

C o n c e n t r a t io n ( u g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 184 Figure 3.3.13. Box and Dot Density Plot of Po tential Hazard Quotients for VOCs in Samples of Deck Washdown Water VOCs are identified as follows (replacemen t values for non-detects are circled): (1) 1,2,4-Trimethylbenzene (2) 1,3,5-Trimethylbenzene (3) Acetone (4) Benzene (5) Bromodichloromethane (6) Chloroform (7) Dibromochloromethane (8) Ethylbenzene (9) m-,p-Xylene (sum of isomers) (10) O-Xylene (11) Toluene 

# 0 2 4 6 8 10 12 VOCs 0.0001 0.0010 0.0100 0.1000 1.0000 10.0000

P o t e n t i a l H a z a r d Q

u o t ie n tChapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.3.7 Summary of the Characterizati on of Deck Washdown Water

Table 3.3.11 summarizes the spec ific analytes within deck washdown and runoff water that may have the potential to pose risk to human health or the environment. EPA’s interpretation of a realized risk likely posed by these analyt es, relative to pollutant loadings, background
ambient and source water contaminant levels and ch aracteristics, and othe r relevant information useful for this assessment, is presented in Chapter 5.

Metals were the class of po llutants found most frequently and at concentrations that exceeded national water quality criteria in samples of deck washdown discharge. Several dissolved metals were measured at PHQs>10, re lative to the most stringent benchmarks. Among the dissolved metals, copper was the most pr evalent, and was measured at PHQ>10 in tow/salvage, fire, taxi, tour, a nd supply vessels. Dissolved cadmium was rarely detected, but had the highest exceedance, in a tow/salvage vessel. Dissolved lead exceeded NRWQC benchmarks in five of six salvage vessels, three of nine tugboa ts, one of two tour vessels, the one fire vessel, and the one supply vessel. Dissolved zinc ex ceeded NRWQC benchmarks in five of six tow/salvage vessels, as well as in tug, tour, fire, and supply ve ssels. Among the total metals,
arsenic and aluminum were the mo st prevalent, particularly in deck washdown discharges of tow/salvage boats (both metals), tugboats (alumi num), and fishing and fire vessels (arsenic).
Total iron exceedances were also common, with the highest PHQs for total iron occurring in tugboats and tow/salvage vesse ls. Finally, total antimony and manganese exceedances were relatively rare, with PHQs in those instances as sociated mainly with the nonfishing vessels. In general, metal discharges were higher in the i ndustrial nonfishing vessels compared to fishing
vessels.

Among the conventional pollutants, TRC was th e most prevalent, with regard to high concentrations and frequency of exceedance of the discharge. The highe st PQHs for TRC were observed in three of the 11 fishing vessels, th e two tour boats, a tow/ salvage vessel, and a tugboat. TSS and turbidity were the next most important classical pollutants, with high
occurrences distributed across all vessel cla sses, but particularly tugboats. The highest exceedances of BOD were found in three tugboats, one shrimp vessel, and the supply boat. COD
and TOC concentrations were similar to BOD c oncentrations. Oil and grease and sulfide were high in only a select few samples (in tugboat, tow/salvage boat, and the supply boat).

Samples for pathogens were taken from onl y fishing vessels, with fecal coliform and enterococci potentially having the highest concentr ations. Levels were high in all vessels except for the gillnetting vessel in Alas ka. Differences in pathogen loads could be related to location or method of fishing (gillnetting vs. trawling). Pathogen loads in deck wash declined after washing
in all cases.

Total phosphorus was the only nutrient of pot ential concern, with high levels found in almost all samples, presumably due to the use of detergents in the deck wash practices. Long185Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 186 chain nonylphenol polyethoxylates of the smallest chain (i.e., NP3EO, most degraded form) were found in only three of the tow/ salvage vessels, and total nonylphe nol polyethoxylates were found at high concentrations in two tour vessels. Finally, a modera tely high PHQ of 5.6 for bis(2- ethylhexyl) phthalate was found in the discharge of a tow/salvag e vessel with a noticeably oily
sheen.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment187Table 3.3.11. Characterization of Deck Washdown and Runoff Waterand Summary of Analytes that May Have the Potentialto Pose RiskAnalytes that May Have the Potential Risk to Pose Risk in Deck Washdown and Runoff Water and Vessel Sources1,2,3,4,5Vessel Type(no. vessels) Microbi ologicals Volatile Organic Compounds Semivolatile Organic Compounds Metals (dissolved) Metals (total) Oil and Grease Sulfide Short-Chain Alkylphenol Ethoxylates and NP Long-Chain Alkylphenol Ethoxylates Nutrients BOD, COD, and TOC Total Suspended Solids Other Physical/Chemical ParametersFishing (11)FecalcoliformEnterococciE. coliCu,ZnAl,As,FexTP,NH3-NBOD,COD,TOCxTRC,DOTugboats (9)Cu,Pb,ZnAl,As,Fe,MnxTP(includingone veryhigh PHQ=220)BOD,COD,TOCxTRC,turbidityTow/Salvage(6)Bis(2-ethylhexyl)phthalateCu,Cd,Cr,Pb,Ni,Zn,Al,As,Fe,SbxxTP,NH3-NBOD,COD,TOCxTRC,turbidityTour (2)Cu,Pb,ZnAl,AsxTPBOD,COD,TOCxTRCWater Taxi (1)CuAl,As,Fe,MnxFire (1)Cu,Cr,PbAs,Al,Fe,SbTPBOD,COD,TOCxturbiditySupply (1)Cu,Cd,Pb,Ni,ZnAl, As,Fe,Mn,SbxTPBOD,COD,TOCxTRC,turbidityRecreational(1)Cu,NiAl,AsTPBOD,COD,TOCxturbidityNotes:(1) Analytes are generallyboldedwhen a large proportion of the samples have concentrations exceeding the NRWQC (e.g., 25 to 50 percent), when several of the samples have PHQs > 10 (e.g.,two or three of five), when a few samples result in PHQsgreatly exceeding the screening benchmark (i.e., 100s to 1,000s), or,in the case of oil and grease and for nonylphenol, when one or moresamples exceed an existing regulatory limit by morethan a factor of 2. See text in Section3.1.3for a definition of PHQs and Table 3.1 for screening benchmarks used to calculate these values.(2) EPA notes that the conclusion of potential risk is drawn froma small sample size, in somecases a single vessel, for certain discharges sampled from some vessel classes. EPAincluded these results in the tables to provide a concise summary of the data collected in the study, but strongly cautions thereader that these conclusions, where there are only a fewsamples from a given vessel class, should be considered preliminary and might not necessarily represent pollutant concentrations from these discharges from other vessels in thisclass. (3) All dissolved metals identified as possible risksare potentially influenced by thedissolved metal concentrations measured in source water (generally city tap water; used byall vessel types), particularly dissolved Cu and Zn.(4) All total metals identified as possible risks are influenced by total metal concentrations measured in surrounding ambient water (relevant only for vessels where ambient water is used for deckwashdown (i.e., many fishing vessels performing deck washdown whileoffshore, certain tug boats (as indicated in vessel survey)).(5) Elevated total phosphorus concentrations in deck washdown samples likely influenced by ambient and source water concentrations.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.4 Fish Hold and Fish Hold Cleaning Effluent (Refrigerated Seaw ater and Ice Slurry)

Refrigerated seawater and ice/ice slurry are the two commonly used methods for preserving fish in the fish hold of many fi shing vessels. EPA noted that some vessels (e.g., large shrimping vessels in the Gulf of Mexico) use dry freezers to preserve their catches; however, these vessels do not produce significant amounts of effluent from the hold that comes into contact with seafood pr oduct and that is later discharged. Lobster and crab boats have seawater flow-through tanks used to keep lobsters and crabs alive. Both the freezers and flow-through tanks might contain residual seafood material that sometimes is discharged when the vessels clean their holds.

The analytes and parameters detected in fish hold effluent come from the vessel, ambient water and potable/service water. A dditionally, many of the constituents can come from the seafood product itself. If the s eafood (e.g., fish, shrimp) are not frozen, but preserved in refrigerated seawater or ice sl urry, small quantities of organic material from the fish (e.g., lipids, protein) will be released as the fish degrade, thereby increasing the concentration of those constituents in the discharge. Furthermore, different volumes of blood, mucus, and other matter can drain fr om the seafood into the hold, depending on
how the fish is butchered or cleaned on deck. For example, salmon, when caught via gillnets on gillnetting vessels, are cut at the gills and bled and then placed into the refrigerated sea water tanks/on ice before bei ng cleaned (resulting in their internal organs and some blood leaking into the water). In c ontrast, salmon caught on trollers are cleaned while the fishing vessel is still at sea and the internal organs are discharged into the surrounding waters. Hence, on the salmon trolle rs, the organs and most of the residual
blood are not in contact with re frigerated water/ice, and cons equently, lower quantities of these materials are discharged when th e vessel empties its hold at the dock.

The volume of fish hold water generate d by a fishing vessel depends on the size of the vessel and the method used for keeping the product fresh. Vessels such as small salmon trollers or long-liners that frequent Alaska wate rs have around 1,500 gallons of fish hold storage. Assuming a hold is occupied by approximately 50 percent fish and 35 to 40 percent ice when the vessel off-loads at the seafood processing facility, the ice, which is thrown overboard daily after the fi sh are unloaded, would result in a fish hold discharge of between 500 and 600 gallons for these types of fi shing vessels every three to seven days (70 to 200 gpd).

188Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Collecting Fish Hold Ice from a Long Liner

Fish Hold Ice from a Trawler

Mid-size fishing vessels, such as gill ne tters, and purse seiners found in Alaska, and shrimp boats in the Gulf of Mexico, have fish hold volumes of between 3,000 and 5,000 gallons. Assuming a hold contains betwee n 35 and 40 percent of ice/water slurry, a

189Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## vessel discharges between 1,000 and 2,000 gallons of fish hold water every two to three days (333 to 1,000 gpd).

Larger fishing vessels such as off-s hore trawlers found off the coast of New England and tenders found in Alaska can have refrigerated seawater holding tanks or ice hold tanks with capacities as large as 15,000 gallons. Assumi ng these fish hold tanks contain 30 to 40 percent refrig erated seawater or ice afte r the seafood is unloaded, the fish hold discharge would be between 4,500 and 6,000 gallons. These vessels are expected to unload seafood a nd discharge the fish hold wate r every three to five days (900 to 2,000 gpd).

Two Examples of Full Fish Hold Tanks on a Tender Vessel

190Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## EPA collected effluent samples from 31 commercial fishing vessels for this study.
Sa mples were collected from the fish holds that were in use on 26 of these vessels. EPA generally collected single grab samples fr om these vessels while the vessels were dockside. These samples were usually collect ed while the effluent was being discharged, but they were occasionally collected directly from the fish hold. EPA analyzed samples for both total and dissolved metals, classica l pollutants, pathogen s, and nutrients. EPA also analyzed three samples fr om fish holds for nonylphenols.

The fish hold tank is cleaned after the cat ch has been off-loaded at the seafood processing facility, so the frequency of fish hold clean ing depends on the type and amount of fish being caught. For example, o ff-shore trawlers in New England might only clean the fish hold tank every th ree to five days when they return to the fish processing facility. Small fishing vessels such as salmon trollers and long-liners in Alaska off-load the catch every three to seve n days. Fish tenders and purse seiners with refrigerated seawater tanks might clean the tanks every coup le of days when they return to the fish processing facility.

On small fishing boats such as trollers and long-liners, and mid-size fishing boats such as gill netters, fish holds are typically cleaned using a ga rden hose at a flow rate of between 10 and 12 gpm. Fish hold cleaning is co mpleted in 15 minutes or less, resulting in a discharge of between 150 and 200 gallons per day. Larger vessels such as off-shore trawlers found in New England and large tende rs in Alaska also use a garden hose to wash down the fish hold tanks; however, clean ing these tanks requi res approximately 30
minutes. EPA estimated the volume of fish hold cleaning water discharge for these vessels ranges between 300 and 400 gallons per cleaning (60 to 200 gpd depending on frequency).

EPA was able to collect samples of the fish hold cleaning water discharge from nine vessels. These samples were analyzed for the same constituents as fish hold effluent plus nonylphenols. Nonylphenols are suspected pollutants associated with cleaning products.

3.2.4.1 Metals

Fish Hold Effluent

Samples of refrigerated cooling water a nd ice slurry from 26 fish holds were analyzed for dissolved and total concentratio ns of 22 metals. The analytical results are summarized in Table 3.4.1 (total metals data ) and Table 3.4.2 (dissolved metals data) for the 19 metals that were detected in one or more fish hold effluent samples. Figures 3.4.1 and 3.4.2 present these same results for to tal and dissolved metals, respectively,

191Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## normalized by the lowes t NRWQC where appli cable. The following metals were detected in all fish hold water samples:

 Total aluminum

 Dissolved and total barium

 Dissolved and total calcium

 Dissolved and total cobalt

 Dissolved and total iron

 Dissolved and total potassium

 Dissolved and total sodium

 Dissolved and total vanadium

 Dissolved and total zinc

Concentrations of a number of other metals were measured for 50 percent or more of the samples analyzed:

 Dissolved aluminum

 Total arsenic

 Dissolved and total copper

 Dissolved and total magnesium

 Dissolved and total manganese

 Dissolved and total potassium

 Total silver.

Several metals for which EPA tested had concentrations that were notable. These metals include dissolved and total arsenic, and dissolved copper, selenium, and zinc (see Figures 3.4.1 and 3.4.2). A small percentage of the samples contained all the metals which EPA regularly analyzes; however, metals such as lead, nickel, and selenium were, with a few notable exceptions, in concentratio ns below PHQs at the point of discharge (see Figures 3.4.3 and 3.4.4). EPA analyzed for a nd detected dissolved and total barium, cobalt, iron, potassium, silver, sodium, and vanadium in only two samples. All of the detected concentrations in the two samples were low, except for iron. EPA also analyzed for antimony, beryllium, and thallium in thes e two samples and did not detect any of
these metals.

The concentrations of many of the meta ls that were detected in fish hold discharges are not unexpected as fish holds generally have numerous exposed metal surfaces. In addition, the pumps used to a dd water to the hold might also add low concentrations of metals. Finally, metallic fishing equipment, deck surfaces, and other
materials sometimes come in contact with th e fish or water that runs into the hold.

Some metal concentrations, particularly mineral salts, appear to be primarily a result of background concentrations in th e ambient water. For example, aluminum,

192Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## barium, calcium , iron, magnesium, sodium, a nd potassium appear to be primarily influenced by background concentrations . Other metals that had measurable concentrations (e.g., arsenic, c opper, manganese, and zinc) app ear to result largely from mechanically refrigerated water used to c ool the sea water to preserve seafood catch, adding ice to do the same, or possibly, from the seafood catch itself, or from any
combination of the three.

Several metals were detected in at least one sample of fish hol d effluent with PHQ values of greater than 1 (see Figures 3.4.3 and 3.4.4). For total metals, this included aluminum, arsenic, copper, iron, and ma nganese. However, as discussed above, aluminum concentrations appear to be prim arily influenced by ambient water background concentrations. Total copper c oncentrations exceeded the total copper benchmark based on human health (for consumption of water and aquatic organisms) of 1,300 μg/L by a small fraction in two samples (Table 3.4.1). Th ese total concentrations, however, could pose potential risk to the aquatic environmen t because the human health criteria of 1,300 μg/L is significantly higher than the 3.1 μg/L benchmark used for dissolved copper based
on the saltwater chronic ambient water quality criterion for th e protection of aquatic life. When high levels of particulate copper are di scharged, some of the particulate copper will likely convert to dissolved copper and be made bioavailable to aquatic life. EPA collected only two samples for analysis of total iron, one of which had a PHQ value of five and the other eight.

Another metal with high PHQ values is total arsenic. The PHQ values for total arsenic ranged from between more th an 100 to more than 20,000 (Figure 3.4.3) 29 

## . One reason for these extreme PHQ values is th e exceptionally low screening benchmark of 0.018 μg/L for total arsenic. Nonetheless, concentrations of total ar senic in the upper end ranges of these measurements are a possibl e environmental concern. These discharges may have the potential to cause or contribute to exceedances of water quality standards, particularly in areas where multiple fishing vessels discharge their holds into the same waters within the same time period.

Several dissolved metals, including arse nic, cadmium, copper, iron, nickel, and selenium, also had PHQs above 1 (see Figur e 3.4.4). Dissolved arsenic samples resulted in PHQs of approximately 9-10 for two di scharges; one was from a shrimping vessel
from the Gulf Coast and the other from a ground fishery vessel in New England, while a third boat ground fishery vessel in New Engl and had a PHQ value of just over 2. There was also only one sample which had a PHQ va lue for cadmium of approximately 5. Only

29 

### While EPA suspects the highest concentration of to tal arsenic (and total selenium) from a shrimping vessel might be slightly elevated due to positive interf erence, measured concentrations of arsenic in fish hold effluent from other similar vesse ls were absent positive interference and nearly as high. Therefore, EPA believes the measured concentrations of total arsenic (and to a lesser extent selenium) from the shimping vessel to reasonably represent true effluent concentrations for the discharge.



## 193Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 194 four of the 26 values exceeded a PHQ value of 1 for dissolved nickel, and none exceeded a value of 2. Dissolved selenium had 6 samples exceed a PHQ value of 1 (the highest value of which was approximately 12). Disso lved zinc had numerous PHQ values of greater than 1, but none great er than 10. Dissolved copper had numerous samples that exceeded the PHQ value of 1, with more than 25 percent of these samples having a PHQ value of greater than 10.

The high dissolved arsenic concentrations were observed exclusively from three vessels; a shrimping boat (345 μg/L) 30 

## and two ground fisher y trawlers (74 and 310 μg/L). Ambient water concentrations indicate that the arsenic likely did not come from the surrounding water, although dissolved arseni c was measured at a substantial level of 26 μg/L in the ambient water where the shrimping vessel was sampled. Another possible explanation is entrainment of arsenic contamin ated sediments on nets. Each of the vessels with high arsenic values (trawl ers and shrimp boats) use nets that drag the ocean floor. When nets are retrieved and emptied on the d eck of the vessel, entrained sediments from the ocean floor could migrate into the fish holds along with the fish and shrimp. One other possible source includes organic arsenic compounds that are primarily found in organisms living in the sea. Based on the limited data collected, EPA cannot identify the specific source(s) of the high dissolved arsenic values at this time.

In summary, some samples of dissolved copper in fish hold effluent discharges were well above the PHQ screening benc hmark of 3.1 μg/L based on the 2006 NRWQC saltwater chronic aquatic life criterion. Many of these concentr ations resulted in PHQs of greater than 10, with some up wards of 200. The three elevated concentrations of dissolved arsenic could potentially pose an environmental concern, pa rticularly if these
arsenic concentrations are co mmon in these vessel discharges. Finally, concentrations of total arsenic are also high relative to the benchmark, resulting in high PHQ values and may have the potential to pose risks to human health if discharged into drinking water sources, though almost all fishing vessels opera te in marine or estuarine environments that are not used for drinking water.

30 

### While EPA suspects the highest concentration of dissolved arsenic (and dissolved selenium) from a shrimping vessel might be slightly elevated due to positive interference from major seawater cations, measured concentrations of arsenic in fish hold effluent from other similar vessels were nearly as high, but absent positive interference. Ther efore, EPA believes the measured co ncentrations of dissolved arsenic (and to a lesser extent selenium) from the shimping vessel to reasonably represent true effluent concentrations for the discharge.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.4.1. Results of Fish Hold Effluent Sample Analyses for Total Metals1Total MetalUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Heavy and Other MetalsAluminumμg/L2626100827840891804209001800240087Arsenicμg/L261662404.8132103800.018Bariumμg/L22100981108383831101101101000Cadmiumμg/L263120.991.93.3NAChromiumμg/L267274.32.61935NACobaltμg/L221003.74.42.92.92.94.44.44.4NACopperμg/L262492190405.81214071017001300Ironμg/L2210020002500160016001600250025002500300Leadμg/L269357.15.63142NAManganeseμg/L261558246.617130140100Nickelμg/L265197.71730610Seleniumμg/L2672712132990170Silverμg/L21502.42.72.72.72.7NAVanadiumμg/L221009.2108.18.18.1101010NAZincμg/L2626100340230274610045094017007400Cationic MetalsCalciumμg/L26261001500001900001900300015000270000300000310000NAMagnesiumμg/L2625964500005800001800140008400009800001100000NAPotassiumμg/L22100330000480000190000190000190000480000480000480000NASodiumμg/L2210012000001900000370000370000370000190000019000001900000NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.195Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment196Table 3.4.2. Results of Fish Hold EffluentSample Analyses for Dissolved Metals1Dissolved MetalUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Heavy and Other MetalsAluminumμg/L26249249067020608509701000NAArsenicμg/L261038315.715035036Bariumμg/L221006484444444848484NACadmiumμg/L26140.771.40.25Chromiumμg/L263121.95.87.911Cobaltμg/L221001.82.01.61.61.62.02.02.0NACopperμg/L26238896156.0383909203.1Ironμg/L22100350360340340340360360360NALeadμg/L263122.34.48.02.5Manganeseμg/L26197322112880110NANickelμg/L264156.113178.2Seleniumμg/L266239.22.520615.0Silverμg/L221001.31.51.01.01.01.51.51.51.9Vanadiumμg/L221003.43.53.23.23.23.53.53.5NAZincμg/L262610018012024315524045079081Cationic MetalsCalciumμg/L2626100160000180000120019009000290000300000310000NAMagnesiumμg/L262596480000560000770110009200009900001100000NAPotassiumμg/L22100330000470000180000180000180000470000470000470000NASodiumμg/L2210012000002000000360000360000360000200000020000002000000NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 197 Figure 3.4.1. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Fish Hold Effluent Al u

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## 198 Figure 3.4.2. Box and Dot Density Plot of Dissolved Metals Concentrations Measured in Samples of Fish Hold Effluent Al u

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## 199 Figure 3.4.3. Box and Dot Density Plot of Potential Hazard Quotients for Total Metals in Samples of Fish Hold Effluent ( Note: Replacement values for non-detects are circled. Al so, as discussed in the text above, total arsenic is a potential concern; however, the exceptionally high PH Q values are due in part to the low human health value for total arsenic used as a benchmark). Al u

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## Figure 3.4.4. Box and Dot Density Plot of Po tential Hazard Quotients for Dissolved Metals in Samples of F ish Hold Effluent (Note: Replacement values for non-detects are circled).



## 200Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 201 Fish Hold Cleaning Effluent

EPA expected effluent from the cleaning of fish holds to be fundamentally similar to fish hold effluent with two exceptions: 1) many vessels used a soap or disinfectant, which would not be expected to be present in the hold, and 2) cleaning fish holds brings in either potable water from the local municipa lity via a pierside hose (service water) or ambient water pumped from the surrounding waters. Table 3.4.3 presents summary
statistics for fish hold clea ning effluent. Figures 3.4.6 and 3.4.7 show the detected results
for total and dissolved metal concentrat ions, respectively, and Figures 3.4.8 and 3.4.9 shows the PHQ values for total and disso lved concentrations, respectively, where applicable.

Generally, average and maximum total and dissolved metals concentrations for fish hold cleaning were slightly lower than for fish hold effluent. These lower values could be due to any number of reasons: less contact time with the vessel for fish hold cleaning effluent, differences in source water (mechanically refriger ated and ice versus city tap water), less contact time (or none at all) with the seafood product or its residuals,

etc.

The lower concentrations of metals for fish hold cleaning effluent resulted in lower overall PHQ values for both total and dissolved forms, as well as a lower percentage of samples that exceed a PHQ of 1. Not surprisingly, the metals (dissolved copper, dissolved and total arsenic) identifie d as having high PHQs fo r fish hold effluent also exhibited higher PHQ values in fish hold cleaning effluent. Likewise, dissolved copper occurs in fish hold cleaning effluent at concentrations mostly above a PHQ value of one, and dissolved arsenic was found in two samples with PHQ values above one.
Dissolved zinc was also found in several samples with PHQ values above one, the maximum being a PHQ value just below 10 (Figure 3.4.8).Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.4.3. Results of Fish Hold Cleaning Effluent Sample Analyses for Metals1MetalUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Heavy and Other MetalsAluminum, Dissolvedμg/L99100780880747476095010001000NAAluminum, Totalμg/L99100110093085085086015001700170087Arsenic, Dissolvedμg/L9556225.338979736Arsenic, Totalμg/L9556358.7641501500.018Cadmium, Totalμg/L91111.03.03.0NAChromium, Dissolvedμg/L91111.53.43.411Chromium, Totalμg/L93334.65.42323NACopper, Dissolvedμg/L988934128.6321801803.1Copper, Totalμg/L9910057256.46.411612902901300Lead, Dissolvedμg/L91112.78.78.72.5Lead, Totalμg/L944419377979NAManganese, Dissolvedμg/L944421396464NAManganese, Totalμg/L9556334.861110110100Selenium, Dissolvedμg/L91116.014145.0Selenium, Totalμg/L92227.47.01818170Zinc, Dissolvedμg/L9889190531942064064081Zinc, Totalμg/L988947014017890180018007400Cationic MetalsCalcium, Dissolvedμg/L991002500002700001100011000240000300000320000320000NACalcium, Totalμg/L991002600002800001300013000260000310000320000320000NAMagnesium, Dissolvedμg/L99100790000860000120001200075000099000010000001000000NAMagnesium, Totalμg/L991007800008800001300013000710000100000010000001000000NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.202Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 203 Figure 3.4.5. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Fish Hold Cleaning Effluent A

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## 204 Figure 3.4.6. Box and Dot Density Plot of Dissolved Metals Concentrations Measured in Samples of Fish Hold Cleaning Effluent 

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## 205Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 206 Figure 3.4.8. Box and Dot Density Plot of Po tential Hazard Quotients for Dissolved Metals in Samples of Fish Hold Cleaning Effluent (Note: Replacement values for non-detects are circled). 

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## 3.2.4.2 Classical Po llutants

Table 3.4.4 presents analyti cal results for 14 classica l pollutants detected in samples from fish hold effluent (all classical pollutants an alyzed for in the study were detected). These detected result s are also shown in Figure 3.4.9.

Except for dissolved oxygen, other physic al parameters measured (conductivity, pH, salinity, and temperature) did not have resu lts that were likely to result in any impact on receiving water quality. Dissolved oxygen con centrations were low in several samples of fish hold effluent: hypoxic (< 2 mg/L) in three cases and marginal (<5 mg/L) in 19 additional cases. These low oxygen cond itions may be driven by the high BOD concentrations found in many of the fish holds. Effluent with low dissolved oxygen
concentrations were also noted in the fish hol d cleaning effluent, with six of nine samples (67 percent) having concentrations of less than 5 mg/L (see Table 3.4.5 and Figure 3.4.10).

EPA found BOD and COD to be highly elev ated in fish hold effluent (Table 3.4.4). BOD was measured in several samples in concentrations in the thousands of mg/L. High levels of BOD are almost certa inly caused by the decay of the organic
material associated with th e seafood product. As shown in Figure 3.4.9, the majority of these concentrations are generally higher than those of raw sewage (which can range up to a few hundred mg/L), and almost all are higher than a wastewat er treatment plant’s secondary treatment limit of 30 mg/L for B OD. The median value for BOD discharge was approximately 471 mg/L, indicating that BOD discharge from fish holds are abnormally elevated (see Figure 3.4.11) . The highest BOD value of 5,130 mg/L approximates the concentra tions found in sewage sl udge (Metcalf and Eddy, 1979).

These high levels of BOD in discharges could potentially pose environmental problems in certain circumstances. For example, high BOD concentrations in fish hold effluents are potentially ubiqu itous, and discharges could re sult in impacts to receiving waters where there are numerous fishing vesse ls, poor flushing, or high levels of existing hypoxic (low oxygen) stress in the water body. In stratified waters with hypoxic or anoxic (no oxygen) conditions, the risk associat ed with elevated BOD is most likely to occur in deeper waters under a thermoclin e or picnocline. When using refrigerated seawater systems, fish hold effluent ma y be as saline (or more saline) than the surrounding water. Where it is also cooler than the surrounding wa ter, the fish hold effluent would be more likely to sink to the bottom of the st ratified water under the warmer water. This may deliver the BOD load to the deeper layers of the water body where oxygen levels are likely to be lower in eutrophic waters. In c ontrast, where ice is used to cool fish in the fish hold, the BOD lo ad may be more likely to stay in the surface layers since fresh water is less dense than salt water. Thus, a low salinity fish hold

207Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## effluent discharge ma y prevent the BOD loadi ng from having as significant an impact to aquatic organisms in the receiving waters.

The considerable variability in BOD concen trations from the 26 fish hold effluent samples may be due to how fish are kept. Th e average concentration of BOD is lowest for the lobster tank compared with the other fi sh hold types, which is logical since lobster tanks have continuously circul ating ambient water with live seafood inside. Hence, the water is constantly being refreshed, while the seafood product gene rally has not begun the process of degrading or bl eeding into the tank. There c ould be other differences in BOD concentrations based upon whet her fish are kept on top of i ce, in ice water slurry, or in refrigerated seawater. New England trawle rs and Gulf Coast shrimp boats had several vessels with exceptionally high BOD concentrations.

Whereas BOD measures oxygen demand fr om biodegradable material, COD measures oxygen demand for both biodegr adable material and nonbiodegradable oxidizable material. Like BOD, COD discharge is elevated in fish hold effluent and fish hold cleaning effluent (Tables 3.4.4 a nd 3.4.5). Occasionally, these values are exceptionally high, which could potentially cau se stress on a water body where there are many discharges from fish holds and where th ere may be low circulation or flushing or existing hypoxic or anoxic stress in the water body.

Oil and grease as measured by HEM and SGT-HEM are generally discharged in low concentrations from fish hold effluent, w ith the vast majority of samples from both
fish hold effluent and fish hold cleaning effluent ha ving HEM and SGT-HEM being discharged in quantities below 5 mg/L. Howe ver, there are a few discharges where the concentrations exceed 15 mg/L. The highest of these values for either fish hold or fish hold cleaning effluent (the HEM concentrati on was approximately 28 mg/L - slightly less than twice the regulatory limit of 15 mg/L) are from the samples taken during a fish hold cleaning event while onboard a New England ground fishing vessel. These values demonstrate that while oil and grease discharg es from fish holds sometimes occasionally occur at elevated concentrations, they were ge nerally not observed at concentrations that are of particular concern.

The concentrations of the classical pollu tants EPA measured that are associated with sediment or cloudiness (i.e., TSS a nd turbidity) were roughly equivalent to concentrations observed in raw sewage efflue nt, but considerably lower than stormwater
runoff from construction sites or highly urbanized streams. T SS was elevated in both fish hold effluent and fish hold cleaning effluent; however, concen trations were generally not sufficiently elevated to alone exceed water quality standards. Just under 90 percent of samples exceed the secondary treatment con centration of 30 mg/L for TSS (the value used to establish the PHQ benchmark), with a maximum concentration of 1,100 mg/L in

208Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 209 a fish hold effluent sample. As with BOD, T SS appears to be more diluted in fish hold cleaning effluent than in fish hold effluent. While it did no t test for volatile suspended solids (VSS) in this sampling program, EPA as sumed that a significant percentage of the TSS concentration is directly caused by orga nic material related to the seafood product. Similar to TSS, turbidity concentrations were elevated in both fish hold effluent and fish hold cleaning effluent, and slight ly more concentrated in fish hold effluent than in fish hold cleaning effluent.

The concentrations of sulfide in fish hol d and fish hold cleani ng effluent were low in most samples, with most values falli ng below a reporting limit value of 0.01 mg/L. Sulfide was detected in only seven of 25 samples where the parameter was tested, and in only four of seven fish hold cleaning sample s. However, a few samples had significantly elevated sulfide concentrations, includi ng a maximum fish hold concentration of 0.16 mg/L (PHQ value of 80) from fish hold disc harges, and a maximum fish hold cleaning value of 0.48 mg/L (PHQ value of 240). These hi gh sulfide values cannot be attributed to high background concentrations. A relatively hi gher percentage of detectable sulfide concentrations were noted in New England gr ound fishery trawlers compared with other areas (seven out of the 11 de tections). EPA is unable to determine why the New England fishery vessels have higher concentrations of sulfide compared with vessels using other fishing platforms or from other areas; however , one possible explanation is that the New England fishery vessels are at sea for seven to 10 days, whereas Alaskan fishing vessels are off loaded once every one to two days.

TRC was detected with some prevalence (roughly a third to two thirds of the samples for fish hold and fish hold cleani ng effluent, respectiv ely), with maximum concentrations of 0.3 mg/L (fish hold e ffluent) and 1.51 mg/L (fish hold cleaning effluent). PHQs for the fish hold and fish cl eaning effluent ranged from one to 40 and one to 200, respectively (data not shown). Such high concentrations might be expected considering the source water (e.g., bag ice for ke eping catch cold in fish holds) or use of chlorine bleach for cleaning and disinfection (f ish hold cleaning effluent). In both cases,
effluent volume is low relative to receivi ng waters for this volatile compound, and as such, EPA does not expect significant risk to human health or the environment.

TOC was detected in all of the 25 of the fish hold effluent samples for which it was tested and all nine fish hold cleaning sa mples. Concentrations ranged from a low of 1.8 mg/L to an extreme high of 2,200 mg/L (see Table 3.4.4). Background concentrations of TOC (i.e., from mechanically refrigerated water or ice) ar e much lower (in the range of 2 to 19 mg/L) and do not appear to be a sign ificant cause of the high TOC loads in the effluent. TOC levels are likely elevated by decay and residuals from the seafood product.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.4.4. Results of Fish Hold EffluentSample Analyses for Classical Pollutants1ParameterUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Biochemical Oxygen Demand(BOD)mg/L262492840440251408303100510030Chemical Oxygen Demand (COD)mg/L2626100150094052340660190026008700NAConductivitymS/cm262610025300.200.353.3434661NADissolved Oxygenmg/L26261004.33.91.72.02.85.78.29.2NAHexane Extractable Material (HEM)mg/L2618693.21.52.96.41615pHSU26261007.06.86.06.36.57.57.88.3NASalinityppt262610013170.100.471.4252828NASilica Gel Treated HEM (SGT-HEM)mg/L2615583.40.982.23.74.415Sulfidemg/L257280.0170.0110.0450.160.0020TemperatureC26261007.06.9-0.160.0983.09.51626NATotal Organic Carbon (TOC)mg/L25251002901401.88.3482609702200NATotal Residual Chlorinemg/L2610380.0960.130.220.300.0075Total Suspended Solids (TSS)mg/L2626100210130102971190690110030TurbidityNTU262610096639.01625120310450NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.210Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment211Table 3.4.5. Results of Fish HoldCleaning Effluent Analyses for Classical Pollutants1ParameterUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Biochemical Oxygen Demand (BOD)mg/L96674703007701800180030Chemical Oxygen Demand (COD)mg/L991001100960490490530160024002400NAConductivitymS/cm8810035412.62.627454646NADissolved Oxygenmg/L991005.62.91.41.41.69.61515NAHexane Extractable Material (HEM)mg/L96675.41.44.2282815pHSU991007.67.66.96.97.28.18.68.6NASalinityppt9910048241.31.31927260260NASilica Gel Treated HEM (SGT-HEM)mg/L94444.92.8121215Sulfidemg/L740570.100.0190.170.480.480.0020TemperatureC991009.28.24.74.75.7121515NATotal Organic Carbon (TOC)mg/L99100210741.91.95.1430730730NATotal Residual Chlorinemg/L96670.290.110.291.51.50.0075Total Suspended Solids (TSS)mg/L991001908416162640046046030TurbidityNTU99100100590.200.201.0210330330NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



### BO D

(

m

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OD (

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O (

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(p p t) Su l f

.

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) TO C

(

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SS (

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)



# Classical Pollutants 0.01 0.10 1.00 10.00 100.00 1000.00

C o n c e n t r a t io n o r A m o u n t



## Figure 3.4.9. Box and Dot Density Plot of Cl assical Pollutant Co ncentrations/Values Measured in Samples of Fish Hold Effluent

212Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



### BO D

(

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OD (

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(

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(p p t) Su l f

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# Classical Pollutants 0.01 0.10 1.00 10.00 100.00 1000.00

C o n c e n t r a t io n o r A m o u n t



## Figure 3.4.10. Box and Dot Density Plot of Classical Pollutant Concentrations/Values Measured in Sample s of Fish Hold Cleaning Effluent

213Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



# BOD Concentrations in Wastewater Effluent

0 1000 2000 3000 4000 5000



### Discharge TypeBOD Concentrations (mg/l)

Raw Sewage Secondary Treatment Limit (Limit for Treated Sewage) Fish Hold
Effluent Cleaning of
Fish Hold

R aw Sewage Data Sources: Orford and Matusky (1959). Henry (1996). Medium value from Metcalf and Eddy (1979).



## Figure 3.4.11. Comparison Betwee n the BO D Secondary Treatment Limit from Sewage Treatment Facilities (30 mg/L), Average BOD Raw Sewage Concentrations, and BOD Concentrations from Fish Hold Effl uent and Fish Hold Cleaning Effluent

214Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.4.3 Pathogen Indicators (Microbiologicals)

Sampling pathogen indicators from fish hol ds presented logistical challenges for the EPA sampling team. Many fishing vessels were sampled in locations remote from laboratories and the holding times of tests for these three pathogens (< 6 hours) prevented EPA from analyzing these samples from many of the sampling events. Nonetheless, EPA
was able to test for E. coli and enterococci in seven fish hold effluent samples and for fecal coliform in 11 fish hold effluent samples. The results are summarized in Table 3.4.6 (upper half of table) and s hown graphically in Figure 3.4.12.

What are Combined Sewer Overflows (CSOs) and Sanitary Sewer Overflows (SSOs)?

Combined sewer systems are sewers that are designed to collect rainwater runoff, domestic sewage, and industrial wastewater in the same pipe. Most of the time, combined sewer systems transport all of their wastewater to a sewage treatme nt plant, where it is treated and then discharged to a water body. During periods of heavy rainfall or snowmelt, however, the wastewater volume in a combined sewer system can exceed the capacity of the sewer system or treatment plant. For this reason, combined sewer systems are designed to overflow occasionally and discharg e excess wastewater directly to nearby streams, rivers, or other wa ter bodies. These overflows, called combined sewer overflows (CSOs), contain not only stormwater but also untreated human and industrial waste, toxic materials, and debris.

Properly designed, operated, and maintained sanitary sewer systems are meant to collect and transport a ll of the sewage that flows into them to a publicly owned treatment works (POTW). However, occasional unintentional discharges of raw sewage from municipal sanitary sewers occur in almost every system. These types of discharges are called sanitary sewer overflows (SSOs). SSOs have a variety of causes, including but not limited to severe weather, improper system operation and maintenance, and vandalism. EPA estimates that there are at least 40,000 SSOs each year. The untreated sewage from these overflows can contaminate our waters, causing serious water quality problems. 

## Of these fish hold effluent samples, EPA detected bacteria concentrations above the most stringent screening benc hmarks for one (of the seven) E. coli samples, four (of the seven) enterococci samples, and three (o f the 11) fecal coliform samples. However, EPA strongly suspects that all of these exceedances were due primarily or exclusively due to background concentrations. For example, the fish hold effluent from a fishing vessel sampled in Gloucester, Massachusetts , exceeded all three stringent screening
benchmarks for E. coli , enterococci, and fecal coliform. However, ambient water concentrations collected earlier in the day ex ceeded the concentrations in the later sample taken from the fish hold. The likely source of the pathogenic bacteria in this case was a combined sewer overflow (CSO) a few hundred feet above the loca tion of the fishing vessel. The fishing
vessel used ambient
water to wash off its
deck while unloading cargo (see section
3.2.3.3 ). Some of this water likely made its way into
the fish hold before

EPA sam pled the
fish hold effluent again at the later time period; hence, in this case, EPA strongly doubts that
the vessel was the
source of the extremely high pathogen levels.

215Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 216 EPA encountered a similar situation wh ile sampling a commercial fishing vessel in New Bedford, Massachusetts. The samples from the fish hold exceeded water quality criteria for enterococci (127 MPN/ 100 ml ) and fecal coliform (125,000 CFU/ 100 ml). However, this vessel was sampled immediatel y adjacent to an SSO that contained raw fish waste and human sewage: the ambient wa ter had enterococci concentrations of 4,342
MPN/ 100 ml and fecal coliform concentratio ns of 6,500 CFU/ 100 ml. This vessel also used ambient water to hose off its deck, intr oducing the pathogenic bacteria to the fish hold. Note that for fecal coliform, this latter vessel’s fish hold efflue nt did appear to add to the high fecal coliform count in the sample.

None of the concentrations of the thr ee pathogens exceeded the most stringent NRWQC set for the pathogens in cases where the ambient concentrations were also below the stringent NRWQC. Although the results were based on this limited number of samples, EPA believes it is unlikely that th ere is an onboard source of these pathogenic
bacteria in the fish hold.

EPA was able to test the effluent from th ree separate fish holds from three vessels while they were being cleaned (see Table 3.4.6, lo wer half of table). Two of the fish hold cleaning effluent samples were from those vessels discussed above, where ambient water pathogen concentrations were impacted by the discharge from a CSO and an SSO. The third sample was from a vessel sampled in Sitk a, Alaska. Similar to the fish hold effluent results from Massachusetts, EPA found that th e concentrations of the effluent from the fish hold cleaning exceeded the NRWQC in one out of the three samples for E. coli , two out of the three samples for enterococci, and two out of three samples for fecal coliform. All the samples exceeding the most stringent screening benchmarks for the pathogens
were from the vessels located in Massachuset ts. Pathogen concentrations were below the detection limit for all three pathogens for the fish hold cleaning effl uent from the vessel in Sitka. In all cases, bac kground concentrations in the ambi ent water exceeded the fish hold cleaning effluent. Similar to what EPA observed with the fish hold effluent data, pathogen contamination in fish hold cleaning effluent from fi shing vessels is not a likely source of pathogen contamina tion to receiving waters. In stead, EPA suspects that the pathogen contamination in these effluents mi ght come from the vessel pumping ambient water with high levels of bacteria onboard.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.4.6. Results of Fish Hold and Fish Hold Cleaning Effluent Sample Analyses for Pathogen Indicators1Analyte2Units3No.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM4Fish HoldE. coliby MPNMPN/100 ml7686834110110310310130Enterococci by MPNMPN/100 ml7571380412502200220033Fecal Coliform by MFCFU/100 ml11655110001027010000013000014Fish Hold CleaningE. Coliby MPNMPN/100 ml326720052550550550130Enterococci by MPNMPN/100 ml3267100015028002800280033Fecal Coliform by MFCFU/100 ml3267190025053005300530014Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reportinglimit for calculating average concentrations. The remaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) MPN = Most Probable Number; MF = Membrane Filtration.(3) CFU = Colony Forming Units.(4) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.217Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 218 Figure 3.4.12. Box and Dot Density Plot of Measured Pathogen Concentrations in Samples of Fish Hold Effluent (Note: All values were subtantially influenced by background concentrations in the ambient water, and of the 25 sample results presented (seven results for E. coli , seven for enterococci, and 11 for fecal coliform), only two of the samples exceeded their background concentrations by more than 20 CFU/MPN 100 ml).



# 100000

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# Pathogen Indicators 10 100 1000 10000

C o u n t p e r 1 0 0 m LChapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.4.4 Nutrients

Sam ples of fish hold effluent and fish hold cleaning were analyzed for four nutrients or nutrient-related pa rameters: ammonia nitrogen, nitrate/nitrite, TKN, and total phosphorus (see Table 3.4.7). The corresponding nutrient concentrations detected in fish hold and fish hold cleaning effluent samples are show n in Figures 3.4.13 and 3.4.14, respectively.

Concentrations of total ammonia nitroge n (NH3-N), nitrate/nitrite nitrogen (NO3/NO2-N), TKN, and total phosphorus roughly compare to values of untreated raw sewage (see values in Table 3.4.8). The fi sh hold effluent had average ammonia concentrations of approximately 12 mg/L and the fish hold cleaning effluent had average concentrations of 16 mg/L, which compares roughly to weak sewage as reported by Metcalf and Eddy (1979) (see Table 3.4.8). Howeve r, there were several discharges in
which the ammonia concentration substantiall y exceeded these concentrations, and these discharges could potentia lly result in acute toxic effects in the receiving water at and near the point of discharge (see Figure 3.4.13). These high values increase the average considerably (the median values for fish hold and fish hold cleani ng effluent are 2.1 and 4.8 mg/L, respectively). Most of the ammonia concentrations in samples collected from both fish hold and fish hold cleaning efflue nt exceed the PHQ screening benchmark of 1.2 mg/L based on the freshwater chronic aquatic life criterion of 1.2 mg N/L, with the highest concentration resulting in a PHQ value of over 130.

In contrast, average nitrate concentrati ons were near zero for both fish hold effluent (maximum concentration of 0.39 mg/L) and fish hold cleaning effluent (maximum concentration of ma x 0.53 mg/L). These concentra tions are similar to those expected in raw sewage efflue nt no matter the strength of the sewage effluent (see Table 3.4.8). However, the average total phosphorus co ncentrations of 13 mg/L for the fish hold effluent and 8.5 mg/L for fish hold cleaning e ffluent were similar to concentrations in medium to strong raw sewage (see Tables 3.4.7 and 3.4.8).

TKN values averaged 110 mg/L for fish hold effluent and 59 mg/L for fish hold cleaning effluent. These TKN results 31 

## can be roughly compared with total nitrogen results from Metcalf and Eddy (1979), showing that the nitrogen discharges are roughly equivalent to strong sewage.

Protein, free amino acids, and nucleotides from fish and fish by-products are all potential sources of nitrogen. Inorganic phos phorus in the form of phosphate is a key

31 

### TKN includes ammonia (NH3) and ammonium (NH4+), and organic nitrogen values. Total nitrogen includes ammonia (NH3) and ammonium (NH4+), organic nitrogen, and nitrate and nitrite values. Raw sewage tends to have very low nitrate and nitrite values.



## 219Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 220 element in DNA, RNA, and adenosine triphos phate (ATP) – key components present in the tissue and blood of any animal.

As shown in Figures 3.4.14 and 3.4.15, there is considerable va riation exceeding two orders of magnitude in the concentrations of three of the four nutrient and nutrientrelated parameters. EPA observe d that nutrient concentrations showed some relationship to the geographical location where the ve ssels operated. As shown in Figure 3.4.15, concentrations of ammonia, TKN, and TP fr om the Gulf Coast shrimp boats and the New England ground fishery trawlers appear to be higher than t hose from the fishing vessels sampled in Alaska or the New England lobste r tank. In addition, compared to the lobster tank, whose water source is pr imarily flow-through water, a ll fishing vessel platforms appear to add nutrients to the effluent.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.4.7. Results of Fish Hold (upper half) and Fish Hold Cleaning Effluent (lower half) Sample Analyses for Nutrients1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Fish HoldAmmonia As Nitrogen (NH3-N)mg/L262596122.10.641.16.7321601.2Nitrate/Nitrite (NO3/NO2-N)mg/L2618690.100.0920.110.270.39NATotal Kjeldahl Nitrogen (TKN)mg/L262596110753.519160340540NATotal Phosphorusmg/L262596139.70.433.21728760.10Fish Hold CleaningAmmonia As Nitrogen (NH3-N)mg/L9778164.80.0341897971.2Nitrate/Nitrite (NO3/NO2-N)mg/L98890.240.270.0700.350.530.53NATotal Kjeldahl Nitrogen (TKN)mg/L96675940140170170NATotal Phosphorusmg/L97788.5110.0251720200.10Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.Table 3.4.8. Raw Sewage Concentrations of NutrientsConcentration (expressed as mg/L)ConstituentStrong SewageMedium SewageWeak SewageAmmonia as N502512Nitrate as N000TotalNitrogen854020Total Phosphorus1584Source: Metcalf and Eddy, 1979.221Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 222 Figure 3.4.13. Box and Dot Density Plot of Nutrient Concentrations Measured in Samples of Fish Hold Effluent (Note: High maximum concentrations for certain samples for ammonia (160 mg N/L), total phosphorus (76 mg/L), and TKN (338 mg/L) are evident). 

## N

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O

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/

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N T P



# Nutrients 0.1 1.0 10.0 100.0

C o n c e n t r a t io n ( m g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 223 Figure 3.4.14. Box and Dot Density Plot of Nutrient Concentrations Measured in Samples of Fish Hold Cleaning Effluent (Note: For all parameters except ammonia, nutrient concentrations tend to be lower for fish hold cleaning effluent). 

## N H3 -N

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O3 /

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2 - N T K

N T P



# Nutrients 0.1 1.0 10.0 100.0

C o n c e n t r a t io n ( m g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Nutrient Concentrations by Fishing Platform/Type

0.01 0.1

1 10 100 1000Concentration (mg/l)

Ammonia As Nitrogen Total Kjeldahl Nitrogen Total Phosphorus

Gillnetter Lobster
Tank Longliner Purse
Seiner Shrimp
Trawler Tende r N .E.
Trawler Troller



## Figure 3.4.15. Comparison of Concentrat ions of Ammonia, TKN, and Total Phosphorus in Different Fishing Vessel Pl atfo rms to those in the Lobster Tank (which has a live catch and continuously circulating water)

224Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 225 3.2.4.5 Nonylphenols

EPA analyzed three fish hold samples for nonylphenols. Short-chain nonylphenol ethoxylates (e.g., NP2EO, NP1EO) and NP were not detected in any of these samples. EPA expected this result because detergents should not be present when seafood catch is stored in the vessel’s fish hold compartm ent except for residual amounts from poor rinsing after cleaning.

As expected, several long chain nonylphenol and octylphenol ethoxylates (NPEOs and OPEOs, respectively)) were detected in the fish hold cl eaning samples collected from eight vessels (see Table 3.4.9). As with d eck washdown water, the NPEOs with the longest ethoxylate chains were detected in approximately a third of the vessels, with concentrations increasing as ethoxylate chain is reduced (i.e., concentrations increasing from NP18EO to NP10EO). Of the vessels where long ethoxalate chain NPEOs were detected, only one of the three vessels ha d detectable concentrations of NPEOs representing the shortest ch ains (NP3EO through NP5EO); m easured concentrations were low in the range of 12 to 32 μg/L, respectiv ely. The OPEO with the longest ethoxylate chain (OP12EO) was detected in only one ve ssel, as were the lower ethoxylate chain OPEOs. For OPEOs, the concentrations show ed the same general trend as the NPEOs
with concentrations incr easing as ethoxylate chai n is reduced, although the
concentrations of the shorte r chain OPEOs were much lower than the shorter chain
NPEOs.

Total NPEO concentrations (from samp les containing all 16 NPEO isomers) could be calculated for only two of the eight vessels whose fish hold cleaning effluent was sampled. The concentrations of total NPEOs ranged from 56 (a ground fishery trawler in Massachusetts) to 4,540 μg/L (another ground fishery trawler in Massachusetts). These results ar e shown graphically in Figure 3.4.16.

While there is no NRWQC for the sum of NPEOs or OPEOs, as indicated in previous subsections, these compounds can degr ade to NP in fresh and salt water (the saltwater chronic aquatic lif e criterion for NP is only 1.7 μg/L). EPA did not collect samples of background levels for analysis of total NPEOs, OPEOs, and NP from ambient

or source water.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.4.9. Results of Fish Hold Cleaning Effluent Sample Analyses for Long-chain Nonylphenols1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Total Nonylphenol Polyethoxylatesμg/L82256204245004500NANonylphenol octodecaethoxylate (NP18EO)μg/L84501.60.150.271212NANonylphenol heptadecaethoxylate (NP17EO)μg/L83383.10.492323NANonylphenol hexadecaethoxylate (NP16EO)μg/L83386.91.15151NANonylphenol pendecaethoxylate (NP15EO)μg/L8338142.1100100NANonylphenol tetradecaethoxylate (NP14EO)μg/L8225252.9180180NANonylphenol tridecaethoxylate (NP13EO)μg/L8225393.9290290NANonylphenol dodecaethoxylate (NP12EO)μg/L8225565.5420420NANonylphenol undecaethoxylate (NP11EO)μg/L8225756.4560560NANonylphenol decaethoxylate (NP10EO)μg/L8225755.9550550NANonylphenol nonaethoxylate (NP9EO)μg/L8225734.7530530NANonylphenol octaethoxylate (NP8EO)μg/L8225744.3540540NANonylphenol heptaethoxylate (NP7EO)μg/L8225663.1470470NANonylphenol hexaethoxylate (NP6EO)μg/L8225511.9360360NANonylphenol pentaethoxylate (NP5EO)μg/L811332220220NANonylphenol tetraethoxylate (NP4EO)μg/L811321140140NANonylphenol triethoxylate (NP3EO)μg/L8113127979NAOctylphenol dodecaethoxylate (OP12EO)μg/L81132.81111NAOctylphenol undecaethoxylate (OP11EO)μg/L81132.71515NAOctylphenol decaethoxylate (OP10EO)μg/L81134.52020NAOctylphenol nonaethoxylate (OP9EO)μg/L81134.92323NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.226Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 227 Figure 3.4.16. Box and Dot Density Plot of No nylphenol Concentrations Measured in Samples of Fish Hold Cleaning Effluent Nonylphenol parameters are identified as follows (nonylphenol and octylphenol ethoxylates in fish hold effluent were not detected): (1) Total Nonylphenol Polyethoxylates (2) Nonylphenol octodecaethoxylate (NP18EO) (3) Nonylphenol heptadecaethoxylate (NP17EO) (4) Nonylphenol hexadecaethoxylate (NP16EO) (5) Nonylphenol pendecaethoxylate (NP15EO) (6) Nonylphenol tetradecaethoxylate (NP14EO) (7) Nonylphenol tridecaethoxylate (NP13EO), (8) Nonylphenol dodecaethoxylate (NP12EO) (9) Nonylphenol undecaethoxylate (NP11EO) (10) Nonylphenol decaethoxylate (NP10EO) (11) Nonylphenol nonaethoxylate (NP9EO) (12) Nonylphenol octaethoxylate (NP8EO) (13) Nonylphenol heptaethoxylate (NP7EO) (14) Nonylphenol hexaethoxylate (NP6EO) (15) Nonylphenol pentaethoxylate (NP5EO) (16) Nonylphenol tetraethoxylate (NP4EO) (17) Nonylphenol triethoxylate (NP3EO) (18) Octylphenol dodecaethoxylate (OP12EO) (19) Octylphenol undecaethoxylate (OP11EO) (20) Octylphenol decaethoxylate (OP10EO) (21) Octylphenol nonaethoxylate (OP9EO) 

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## 3.2.4.6 Regional variation in Fish Hold Effluent Discharges

Based on public comm ents received on EPA’ s draft version of this report, EPA conducted a regional analysis of vessel fish hol d discharges. EPA was able to conduct this analysis because there were 26 different hold disc harges sampled. However, of the 26 fish hold discharges sampled, twenty were from Alaska, four were from New England, and only two were from the Gulf. A sample size of two is the abso lute minimum number that can be used for any statistical comparisons, and cauti on must be exercised before dr awing any general conclusions
on the effects of fish hold discha rge for an entire ge ographic region based on only two samples. Additionally, there is limited variation in the pl atforms sampled at New England and Gulf Coast
locations. EPA cautions these results must be co nsidered preliminary in nature and cannot be
considered conclusive. The limitations of this analysis are also disc ussed in the following paragraphs.

The potential regional
differences in concentrations of fish hold discharges were examined for seven analytes (Total Copper, Total Zinc, Total Arsenic, Ammonia, Total Kjeldahl Nitrogen, Total Phosphorus, and Biological Oxygen Demand).
Concentrations of each of these analytes were compared for the three regions in which vessels with fish hold discharge were sampled (Alaska, Gulf Coast, and New England). Mean analyte concentrations with corresponding standard deviations are shown for each of the regions in Table 3.4.10. Based on this preliminary analysis, mean concentrations of all seven analytes were lower in the fish hold discharges from fishing vessels in Alaska compared to the concentrations discharged from fishing vessels in the Gulf Coast and New England. A preliminary statistical analysis (Welch’s t-tests accounting for unequal variance and unequal sample sizes – see accompanying text box for details) comparing each of these Regional Comparison of Fish Hold Discharge Concentrations

A preliminary analysis was performed to assess the effects of geographic region on seven selected analytes listed in Table 3.4.10. Vessels were grouped into three broad geographic regions, and concentration differences between groups were evaluated using 

## Welch’s t-tests accounting for unequal sample size and uneven variance. Prior to analysis, all concentrations were log transformed to stabilize sample variance. EPA performed t-test analyses with and without subtracting background analyte concentrations. The results were fundamentally similar.For each analyte, three comparisons were made (AlaskaGulf, Alaska-New England, Gulf-New England), at a Bonferroni adjusted significanc e level of .017 (.05/3), to account for the effect of multiple comparisons.

Two additional analyses were performed to examine whether the observed regional differences could be explained by differences in fishing method (nets vs. no nets), or fish hold cooling method (ice vs. refrigerated seawater vs. both). These analyses also consisted of


## Welch’s t-tests for unequal sample size and unequal sample variance, and were conducted using log transformed concentrations after subtracting ambient concentration with appropriate Bonferroni adjusted significance levels to account for the effect of multiple comparisons.



## 228Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## groups suggests that regional di fferences in the fish hold disc harge concentrations for these seven analytes mi ght be present, as concentratio ns from the two Gulf Coast vessels (shrimpers) were statistically significantly higher than concentr ations from the twenty Alaska vessels for six of the seven analytes teste d. The one exception was total arsenic, which did not differ significantly between any of the three regions.

Although these results s uggest the possibility of regiona l differences, they may also simply be a statistical artifact of: 1) a population of vessels that were both small in number and highly unevenly distributed across re gions, 2) vessel type, 3) fish hold cooling method, 4) fishery type, or 5) some combina tion of the above. Both of the Gulf Coast vessels were shrimp trawlers, and three of the four New England vessels were ground fishery trawlers. Trawling vessels may
also fish closer to the bottom of the water colu mn, and could be expected to accumulate more organic matter along with their catch, which coul d potentially explain th e higher concentrations of the analytes examined in this analysis. A fourth New England sample was taken from a lobster tank which consistently circulated ambient water. The twenty Alaska vessels consisted of five purse seiners, three gillnetters, three longlin ers, three tender vessels, and six trollers. The purse seiners and gillnetters spread nets, which may tend to pull fish or other material from closer to the bottom of the water column (though th is is less likely in many deep waters off of Alaska). A second analysis was performed to determine whether the regional differences
observed were an artifact of the distribution of vessel type; specifically, whether the vessel fishing method employed nets (trawlers, purse sein ers, gillnetters), or some other method (lobster vessel, longliners, trollers). Wh en the vessels were analyzed in two groups, those that do not use nets versus those that use nets, concentrations of total ammonia were statistically significantly higher, and concentrations of total arsenic and total copper were marginally (0.10<P<0.05) statistically significantly higher in vessels that use nets, perhap s because these vessels tend to
fish closer to the bottom of the water column. It should be noted that both of the Gulf vessels and three of the four New England vessels we re vessel types that employed nets, which may have influenced the results. When the same analysis was performed using only the Alaska vessels, only ammonia was marginal ly statistically significantly hi gher in the vessels that fish with nets, while zinc concentrations were statis tically significantly higher in vessels that fish without nets. Again, small sample caveats apply to these and all other analyses described in this
section.

Finally, the effects of fish hold cooling method on fish hol d discharge concentrations were examined. Of the twenty six vessels sa mpled, thirteen vessels used ice, ten used refrigerated water, two used both ice and refrigerated seawat er, and one used recirculating ambient water. When vessels were examined as a function of cooling method, there were no statistically significant differences between any of the groups. This analysis was repeated for the subset of vessels from Alaska, and aside from (0.1<P<0.05) statistically significantly higher
ammonia concentrations in Alaska vessels that ch illed fish holds using refrigeration versus those that used ice, there were no statistically significan t differences in fish hol d discharges that could

229Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 230 be explained by fish hold cooling method. Howeve r, this result cannot be separated from the effects of fishing method (nets vs. no nets), as seve n of seven vessels that cooled fish holds with refrigerated seawater also fished with nets, while nine of ten ve ssels that cooled with ice used fishing methods that di d not involve nets.

Although results of this analysis suggest differences in fi sh hold discharge concentrations are more pronounced between regions than between fishing method or fi sh hold cooling method, these results should be considered preliminary, and additional informati on will be required to draw any substantive conclusions regarding inte r-region differences. Both the Gulf Coast and New England regions are represented by a small number of sample vessels. Not only is the Gulf Coast region represented by th e minimum number of vessels with which to perform any statistical comparisons, the two vessels are sim ilar with regard to vessel type and fish hold cooling method; therefore it cannot be assu med that the two sampled discharges are representative of the entire Gulf Coast fishery. While these anal yses suggest the possibility of regional differences, the presence of true regi onal differences would require the sampling of a larger number of vessels from the Gulf and New England regions encompassing a broader, more evenly distributed number of ve ssels to account for the effects of vessel and discharge (ice or refrigerated water) type, as well as additio nal sampling of ambient receiving waters.

Table 3.4.10. Means (and Standard Deviations) for Selected Analyte Concentrations, by Geographic Region. Units for All Analytes Expressed as μg/L, Except for BOD (mg/L).

Mean Analyte Concentration Above Ambient (1 s.d.) Region Total Cu Total Zn Total As Ammonia TKN Total P BOD Vessel Type (no.)

Alaska 53.7 253 4.79 2.72 75.4 8.40 416 Gillnetter (3) (69.0) (223) (3.69) (2.74) (64.4) (6.35) (336) Longliner (3) Purse Seiner (5) Tender Vessel (3) Troller (6)

Gulf Coast 1640 446 186 19.0 397 24.7 3250 Shrimp Trawler (2) (30.7) (75.5) (233) (1.39) (201) (8.73) (499)

New England 112 706 132 55.2 165 26.0 1720 Lobster Tank (1) (146) (773) (170) (74.2) (245) ( 33.7) (2370) Ground Fishery Trawler (3) *As discussed in the text above, there are substantial limitati ons to this regional analysis wh ich mean these results are preli minary in nature. Additional information is needed before making firm conclusions.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.4.7 Summary of the Characterization of Fish Hold Effluent and Fish Hold Cleaning Effluent

Table 3.4.11 summarizes the spec ific analytes within fish hold and fish hold cleaning
effluent water that m ay have the potential to pose risk to human health or the environment. EPA’s interpretation of a realized risk likely posed by these analytes, relative to pollutant loadings, background ambient and s ource water contaminant levels a nd characteristics, and other
relevant information useful for this assessment, is presented in Chapter 5.

Total iron was sampled for in only two ve ssels, but PHQs were between 5 and 10. Concentrations of dissolved copper exceeded NR WQC standards in all effluents sampled, with PHQs>10 in four of the vessels sampled.

The concentrations of certain total and disso lved metals, as well as many of the other pollutants, measured in fish hold and fish hold cl eaning effluent were elev ated. Concentrations of total arsenic were detected in 16 of 26 samples, and when detected were measured at levels greatly exceeding its respective screening benc hmark (i.e., NRWQC), resulting in PHQs of well over 100. Likewise, total copper concentrations , while only exceeding the NRWQC for human health of 1,300 μg/L in a few samples, were hi gh in these few instances and might pose potential acute toxicity risk to aquatic life 32 

## . To a large degree, total aluminum, iron, and manganese concentrations could be explained by the re spective metal concentra tions in the surrounding waters. Arsenic and copper, however, most lik ely originated from th e fish hold effluent. Concentrations of dissolved copper exceeded NR WQC standards in all effluents sampled, with PHQs well above 10 in four of the vessels samp led. Samples with concentrations of dissolved arsenic resulting in PHQs above 10 were limite d to just two fishing vessels (a shrimper 33 

## and a ground fishing trawler) with a third vessel having a PHQ of approximately 2. Approximately 2/3
of the concentrations of dissolv ed zinc in fish hold effluent exceeded NRWQC benchmarks, but
no concentrations of dissolved zinc exceeded a PHQ of 10, and most concentrations were below a PHQ of 3. Dissolved selenium was measured above reporting limits in only six discharges with PHQs>1 in all samples, and PHQs between 5 and 10 for two samples (including a shrimping
vessel 33 

## ). Total and dissolved metals concentrations were qualitatively similar in fish hold cleaning effluents, but, in genera l, concentrations in cleaning effluent were lower than in corresponding fish hold effluents.

Several classical pollu tants found in fish hold and fish hold cleaning effluent may have the potential to pose risk. A classical pollutant f ound in fish hold and fish hold cleaning effluent

32 

### As discussed earlier in this chapter, total copper concentrations could pose potential risk to the aquatic environment because the human health cr iteria of 1,300 μg/L is significantly higher than the 3.1 μg/L benchmark used for dissolved copper based on the saltwater chronic am bient water quality criterion for the protection of aquatic life. When high levels of particulate copper are discharg ed, some of the particulate copper will likely convert to dissolved copper and be made bioavailable to aquatic life.

33 

### See discussion in footnotes 29 and 30 and Section 3.2.4.1.



## 231Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 232 that poses one of the greatest potential risks to receiving waters is BOD, which was found at elevated concentrations in all sampled ve ssels and, in many instances, was higher than concentrations found in raw sewage (see Fi g. 3.4.12). Concentrations of COD and TOC
correlated with BOD concentrations and were sim ilarly elevated in all fishing vessels. The high BOD in these samples likely contributed to the pervasively low dissolved oxygen levels in these samples. TSS and turbidity in fish hold and fish hold cleaning effluent are also equivalent to levels found in raw sewage, and concentrations of sulfide, particularly in samples from the New England ground fishery trawlers, exceeded the low PHQ screening benc hmark (0.002 mg/L) for this classical pollutant.

The other pollutants of potential concern in fi sh hold and fish hold cl eaning effluent were
the nutrient and nutrient-related parameters, particularly NH3-N, TKN, and TP, all of which
were measured at concentrations similar to co mparable concentrations typically measured in strong (raw) sewage samples. Again, mean concen trations of BOD, COD, TOC, NH3-N, TKN, and TP were highest in shri mping and trawling vessels.

Aside from a select few samples, the high pa thogen concentrations found in fish hold and fish hold cleaning samples likely did not stem fr om the effluent itself, but rather, from the excessively high concentrations measured in ambient background water contaminating the fish holds from the deck washdown process.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.4.11. Characterization of Fish HoldEffluent and Fish Hold Cleaning Effluent and Summary of Analytes that MayHave the Potential to Pose RiskAnalytes that May Have the Potential to Pose Risk in Fish Hold and Fish Hold Cleaning Effluent1Vessel Type (no. vessels) Microbi ologicals Volatile Organic Compounds Semivolatile Organic Compounds Metals (dissolved) Metals (total) Oil and Grease Sulfide Short-Chain Alkylphenol Ethoxylates and NP Long-Chain Alkylphenol Ethoxylates Nutrie nts BOD, COD, and TOC

Total Suspended Solids Other Physical/Chemical ParametersFishing Vessels (31)enterococci,Fecal coliformAs,Cu, ZnAl,As,(Cu)2,FexNH3-NTKNTPBODCODTOCxDO,TRC,turbidity(1) Analytes are generallyboldedwhen a large proportion of the samples have concentrations exceeding the NRWQC (e.g., 25 to 50 percent), when several of the samples have PHQs > 10 (e.g.,two or three of five), when a few samples result in PHQs greatly exceeding the screening benchmark(i.e., 100s to 1,000s), in the case of oil and grease and for nonylphenol, when one or moresamples exceed an existing regulatory limit by more than a factorof 2, or when concentrationsof analytes are sufficiently high that they may have the potential to pose risks to local water bodies.See text in Section3.1.3for a definition of PHQs and Table 3.1 for screening benchmarks used to calculate these values.(2)Only a few PHQs near or slightly exceeding 1, but concentrations (in excess of 1,000 μg/L) potentially acutely toxic to aquatic life, particularly to organisms living in the benthos.233Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.5 Graywater

EPA sampled graywater from eight vessels: fi ve tugboats, a shrimper, a water taxi and a recreational powerboat. The samples included gray water from sinks, dishwashers, and showers, as well as graywater samples from several mi xed or unspecified sources. Graywater samples were analyzed for a range of pollutants incl uding pathogen indicators, classical pollutants, nonylphenols, metals, and nutrients. The analyt ical results were intended to provide representative graywater pollutant concentratio ns over the range of normal vessel operations.

Graywater volumes vary considerably dependi ng on the class of ve ssel and its intendeduse, vessel size, the number of crew and passengers onboard, and the types of graywatergenerating activities onboard (e.g., galleys, sinks, showers, wash machines). Based on observations made during the sampling program a nd from discussions with crew members, EPA estimated that tugboats, some of which provide living quarters for three to five crew members, generate approximately 130 gpd of graywater. Wa ter taxis, which carry a significantly larger number of crew and passengers, but with fe wer graywater-generating activities, generate approximately 75 gpd of graywater. Graywater generation on commercial fishing boats might range from a few gpd to hundreds of gpd, depending on the length of the trip and the size of the crew. Due to the highly variable graywater generation volumes po ssible within vessel classes,
EPA was unable to further define graywater generation rates.

The Sink and Shower F acilities of a Tugboat

234Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 235 3.2.5.1 Pathogen Indicators (Microbiologicals)

Graywater is generated from personal bath ing, food preparation, and dish and clothes washing, so EPA expected that this vessel discharge category could contain high levels of pathogens. The analytical data fo r the pathogen indicator bacteria E. coli , enterococci and fecal coliform confirm this expectation as the levels of pathogens measured in graywater were by far the highest values measured in any of the vesse l discharges. However, it should also be noted that for each of the pathogen indicators, a wide range of values were measured in the graywater samples. EPA also noted that source water (gener ally municipal water tr ansferred onto the vessel (service water)) does not appear to account for any of the pathogen concentrations.

The analytical results for pathogen indicators in the ei ght graywater samples are summarized in Table 3.5.1 and displayed in Figure 3.5.1. For each of these parameters, the highest levels (660,000 MPN/100 mL for E. coli , 240,000 MPN/100 mL for enterococci, and 570,000 CFU/100 mL for fecal coliform) were measur ed in the mixed graywater sample from a tugboat. For comparison, EPA measured average levels of 292,000 MPN/100 mL for E. coli

, 8,920 MPN/100 mL for enterococci

, and 36,000,000 CFU/100 mL for fecal coliform in untreated graywater, as reported in the 2008 Cruise Sh ip Discharge Assessment Report (USEPA, 2008). Typical fecal coliform concentrations in untreated domestic wa stewater are 10,000 to 100,000
MPN/100 mL 34 

## . The second highest concentration, of E. coli, was measured in a mixed (dish/shower) graywater sample, while the second highest concentrations, for enterococci and fecal coliform, were measured in a dishwashi ng sample. Samples of graywater from sinks and showers tended to have lower levels of the pa thogen indicators. Pathoge n indicators were not detected in graywater samples from th e sink of one vessel, a water taxi.

Figure 3.5.2 presents in box/sca tter plots the PHQs for the three pathogen indicators in graywater. As this figure shows, the majority of the values measured for each of the pathogen indicators exceeded the water qua lity screening benchmarks, by up to four orders of magnitude (or more, in the case of fecal coliform).

34 

### Note, as indicated above in Table 3.1 and elsewhere, units of MPN/100 ml for fecal coliform approximate similar units of CFU/100 ml; therefore, the two units of expression are appropriate for comparison here.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.5.1. Results of Graywater Sample Analyses for Pathogen Indicators1AnalyteUnits2No.samplesNo.detectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM3E. ColiMPN/100 ml878811000016000180120000660000660000130EnterococciMPN/100 ml878840000500705700024000024000033Fecal ColiformCFU/100 ml87882000002700007445000057000057000014Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reportinglimit for calculating average concentrations. The remaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) MPN = Most Probable Number; CFU = Colony Forming Units.(3) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.236Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 237 Figure 3.5.1. Box and Dot Density Plot of Path ogen Indicator Values Measured in Samples of Graywater 

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## 238 Figure 3.5.2. Box and Dot Density Plot of Po tential Hazard Quotients for Pathogen Indicators Measured in Samples of Graywater (Note: Replacement values for non-detects are circled). 

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## 3.2.5.2 Classical Pollutants

Graywater samples were analyzed for 14 cl assical pollutants (see Table 3.5.2). Figure 3.5.3 illustrates the variability of the concentrations/values measur ed for the classical pollutants in graywater. There was no one vessel or graywate r source that tended to have the highest level of a majority of the cl assical pollutants, unlike the case for the pathogen indicators. The highest concentrations of oil and greas e (100 mg/L HEM and 35.3 mg/L SGT-HEM) were measured in the sample of mixed dish/shower graywater on one tugboat; EPA speculates that the source of the oil and grease are primarily oils from cooki ng and other food sources discharged with the sink water. The highest levels of TSS (99 mg/L) and turbidity (128 NTU) were measured in the dishwashing graywater from a second tugboat. Th e highest sulfide concentration (1.45 mg/L) was measured in a shower graywater sample from a third tugboat. The highest measured concentrations of BOD (1200 mg/L), COD (4,04 0 mg/L), and TOC (440 mg/L) were measured in the sample of shower graywate r from the recreational powerboat.

Many of the classical pollutants that were elev ated in the graywater samples likely reflect the washing and bathing activities that generate graywater discharges. For example, sulfide 35 

## is a parameter that is commonly elevated in water di stribution systems, esp ecially on the hot water
side. Sulfur-reducing bacteria, which use sulfur as an energy source, are the primary producers of large quantities of hydrogen sulfide. Sulfur-reduc ing bacteria can live in plumbing systems and hot water heaters. A second example is the hi gh concentration of BOD measured in graywater samples (mentioned above), which reflects th e BOD generated onboard the vessels sampled and not from the service water used by that vessel.

Figure 3.5.4 presents the PHQs for classical pol lutants in graywater in box/scatter plots. As this figure shows, the PHQ threshold of 1 was exceeded for sulfide, TRC (detected in only one sample (0.11 mg/L) above the reporting lim it of 0.0075 mg/L for a PHQ of 15), BOD, oil and grease (measured as HEM), and TSS. The highest PHQs were calculated for sulfide at 367 and BOD at 40. All of the graywater samples exceed ed the 30 mg/L benchmark for BOD, and all
five of the detected concentrations of sulfide exceeded the 0.002 mg/L benchmark.

The source of water used on the sampled vessels was, in all cases, potable freshwater bunkered in port (service water). Therefore, EPA did not consider it appropriate to compare the

35 Although sulfide ( S 2- ) is the analyte, hydrogen sulfide (H 2 S) is the nonpriority pollutant for which a NRWQC has been established. Sulfides are commonly found as either hydrogen sulfide or hydrosulfide (HS - ). EPA conservatively assumes that all of the sulfide is in the form of hydrogen sulfide (H 2 S) is the form that is toxic to fish. However, the proportion of each depends on the pH of the water. At pH 9 about 99 percent of the sulfide is in the form of HS - ; at pH 7 the sulfide is equally divided between HS - and H 2 S; and at pH 5 about 99 percent of the sulfide is present as H 2 S. Unless heavily polluted, freshwater rivers typically tend to have a pH which ranges from about 4.5 to about 7, marine environment s have an average pH of around 8.1 (seawater is more basic freshwater), while estuaries may have a pH between that of freshwater and seawater (approximately 5 to 8) dependent upon salini ty and other factors. Hence, the use of sulfide ( S 2- ) as the analyte to detect for the presence of hydrogen sulfide (H 2 S) is more conservative in marine and estuarine environm ents than in freshwater ones, but is a reasonable analyte to use due to variation found in different aquatic ecosystems.



## 239Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 240 concentrations of classical pollutants in graywa ter to ambient water body concentrations; rather, EPA compared the concentrations of classical pollutants to those found in the service water. None of the conventional parameters discussed here were consistently detect ed in service water.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.5.2. Results of Graywater SampleAnalyses for Classical Pollutants1AnalyteUnitsNo.samplesNo.detectedDetectedproportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Biochemical Oxygen Demand(BOD)mg/L8810043026099991108501200120030Chemical Oxygen Demand(COD)mg/L881001000440180180270170040004000NAConductivitymS/cm771000.430.410.220.220.300.500.790.79NADissolved Oxygenmg/L771007.47.16.06.06.38.31010NAHexane Extractable Material(HEM)mg/L8810039299.49.4146810010015pHSU881007.47.26.16.16.78.58.78.7NASalinityppt661000.250.200.100.100.180.400.400.40NASilica Gel Treated HEM (SGTHEM)mg/L86758.11.50.339.4353515Sulfidemg/L85630.110.0170.00.0350.730.730.0020TemperatureC881002727212124293636NATotal Organic Carbon (TOC)mg/L7710014083272766160440440NATotal Residual Chlorinemg/L86750.120.0200.110.110.0075Total Suspended Solids (TSS)mg/L88100525814143769818130TurbidityNTU881007489404045110110110NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.241Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 242 Figure 3.5.3. Box and Dot Density Plot of Cl assical Pollutant Co ncentrations/Values Measured in Samples of Graywater BOD (

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## 243 Figure 3.5.4. Box and Dot Density Plot of Po tential Hazard Quotients for Classical Pollutants in Samples of Graywater (Note: Replacement values for non-detects are circled). BOD (

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## 244 3.2.5.3 Nonylphenols

Long- and short-chain nonylphenol and octylp henol ethoxylates and NP were expected in graywater discharges given their use in soaps for hand and body washing and in liquid detergents for dish washing. EPA anticipated that the long- chain alkylphenol ethoxylates would be present in all graywater samples where detergents we re used for cleaning, while the short-chain ethoxylates (and possibly NP) would be present if detergents were used for cleaning and there was a graywater holding tank that provided the ad ditional residence time necessary for biological activity to degrade the NPEOs and OPEOs.

Graywater samples were analyzed for 34 long- and short-chain nonylphenol and octylphenol ethoxylates, includi ng 28 NPEOs and OPEOs, bisphe nol A, and total nonylphenol (NP). Of these parameters, 25 were detected in one or more samples (see Table 3.5.3). Average
concentrations for NP18EO-NP3EO and OP12E O-OP6EO ranged from approximately 0.1 to 10 μg/L. The average concentrations of total nonylph enol polyethoxylates (sum of NPEO isomers) and total octylphenol polyethoxylates (sum of OPEO isomers) were 66 and 63 μg/L, respectively. All of the NPEOs were detected in the graywater sample from the sink of one of the tugboats and the graywater sampled from the s hower on the recreational powerboat. All of the OPEOs were detected in the graywater sampled from the shower on the recreational powerboat.
NPEOs and OPEOs were also occasi onally detected in graywater samples from three of the other
vessels.

EPA did not calculate any PHQs for the nonyl phenol parameters measured in graywater. The only screening benchmark available was the saltwater chronic NRWQC for NP (1.7 μg/L). There were no analytical results for NP to compare to this scr eening benchmark, and no NRWQC exist for the other nonylphenol parameters (individual or total long- and short-chain NPEOs and OPEOs). None of the long- or short- chain nonylphenol or octy lphenol ethoxylates or
NP were detected in the ambien t water surrounding these vessels.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.5.3. Results of Graywater Sample Analyses for Nonylphenols (only long-chain NPEOs and OPEOs were detected)1AnalyteUnitsNo.samplesNo.detectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Total Nonylphenol Polyethoxylatesμg/L822566155353NANonylphenol octodecaethoxylate (NP18EO)μg/L82250.0840.0230.0410.041NANonylphenol heptadecaethoxylate (NP17EO)μg/L83380.310.121.01.0NANonylphenol hexadecaethoxylate (NP16EO)μg/L83380.590.231.61.6NANonylphenol pendecaethoxylate (NP15EO)μg/L83381.10.492.42.4NANonylphenol tetradecaethoxylate (NP14EO)μg/L83382.20.955.85.8NANonylphenol tridecaethoxylate (NP13EO)μg/L83383.51.99.39.3NANonylphenol dodecaethoxylate (NP12EO)μg/L83385.43.21414NANonylphenol undecaethoxylate (NP11EO)μg/L83387.04.71616NANonylphenol decaethoxylate (NP10EO)μg/L82256.72.06.96.9NANonylphenol nonaethoxylate (NP9EO)μg/L82257.32.57.37.3NANonylphenol octaethoxylate (NP8EO)μg/L82257.91.57.67.6NANonylphenol heptaethoxylate (NP7EO)μg/L81137.86.56.5NANonylphenol hexaethoxylate (NP6EO)μg/L81137.35.55.5NANonylphenol pentaethoxylate (NP5EO)μg/L82255.81.63.73.7NANonylphenol tetraethoxylate (NP4EO)μg/L82254.71.12.72.7NANonylphenol triethoxylate (NP3EO)μg/L81132.80.990.99NATotal Octylphenol Polyethoxylatesμg/L8113633737NAOctylphenol dodecaethoxylate (OP12EO)μg/L84501.50.223.33.53.5NAOctylphenol undecaethoxylate (OP11EO)μg/L82252.03.15.25.2NAOctylphenol decaethoxylate (OP10EO)μg/L82253.54.17.27.2NAOctylphenol nonaethoxylate (OP9EO)μg/L81133.37.87.8NAOctylphenol octaethoxylate (OP8EO)μg/L81137.67.37.3NAOctylphenol heptaethoxylate (OP7EO)μg/L8113106.36.3NAOctylphenol hexaethoxylate (OP6EO)μg/L8113104.14.1NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.245Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.5.4 Metals

Graywater samples were analyzed for dissolved (filtered) and total concentrations of metals. The analytical results are summarized in Table 3.5.4 for the dissolved metals and Table
3.5.5 for the total metals that were detected in at least one graywater sample. The following metals were detected in all of the graywater samples:

 Dissolved and total aluminum

 Total barium

 Dissolved and total calcium

 Dissolved and total copper

 Dissolved and total manganese

 Dissolved and total potassium

 Dissolved and total sodium

 Dissolved and total zinc.

Concentrations of other metals were measured in 50 percent or more of the graywater samples:

 Dissolved barium

 Total chromium

 Total iron

 Total lead

 Dissolved and total magnesium

 Dissolved and total nickel

 Dissolved and total selenium

 Total vanadium.

Figures 3.5.5 and 3.5.6 present the ranges of c oncentrations measured for dissolved and total metals in the graywater samples. The plots show that dissolved and total metals concentrations range over five orders of magnitude. Calciu m, magnesium, potassium and sodium, which are the major cations present in se awater, were the dissolved metals measured at the highest concentrations. Disso lved aluminum, copper, and zi nc were also measured at relatively high concentrations (g reater than 100 μg/L) in most graywater samples. For these dissolved metals, service water samples co ntained up to 80 percent of the graywater concentration for aluminum, up to 100 percent for copper, and up to 170 percent for zinc. Although the comparison of service water and gray water concentrations suggests that service water might be the source of these metals in some of the graywater samples, this was not always the case. In fact, servic e water concentrations tended to be low in the samples that corresponded to the highest metals concentrations in graywater.

246Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 247 Total concentrations for each metal were ge nerally similar to or somewhat higher than
the dissolved concentrations. Aside from the ma jor seawater cations, concentrations of total metals in the graywater samples were highest for aluminum (912 μg/L), copper (440 μg/L), iron (458 μg/L), and zinc (3,470 μg/L). For these to tal metals, EPA found that service water samples contained up to 74 percent of the graywater co ncentration for aluminum , up to 115 percent for copper, up to 175 percent for iron, and up to 32 percent for zinc. As was the case for dissolved metals, comparing the service water and graywate r concentrations suggest s that service water might be the source of these total metals in some, but not all, of the graywater samples.

To quantify the relationship between dissolv ed and total metals concentrations, EPA calculated the average dissolved fraction (f d 

## ) of each metal in the graywater samples. The metals in graywater discharges with the highest average dissolved fractions (f d 

## > 90 percent) included arsenic, calcium, magnesium, nickel, potassium, and sodium. For all of the other metals where dissolved fractions could be calculated (alu minum, barium, chromium, copper, iron, lead, manganese, selenium, vanadium, and zinc), the av erage values were in the intermediate (90 percent > f d 

## > 50 percent) range.

The plots in Figures 3.5.7 and 3.5.8 display the distribution of PHQs based on the screening benchmark for each of the dissolved an d total metals. For dissolved metals, copper and zinc concentrations consistently exceed th e screening benchmarks; the maximum PHQs for copper and zinc were 90 and 18.5, respectively. For to tal metals, the measured concentrations of aluminum consistently exceeded the screening benchmarks. PHQs for total aluminum varied from 0.6 to 10.5. The PHQs based on measured con centrations of total arsenic were 160 and 110 (arsenic was detected in only two of eight graywater samples, one of which may have an
elevated measured concentration due to positive interference(see discussion on page 74 for more information); these high values reflect the ve ry low NRWQC (0.018 μg/L; hum an health for the consumption of water + organism) for this carcinogen.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.5.4. Results of Graywater SampleAnalyses for Dissolved Metals1AnalyteUnitsNo.samplesNo.detectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Heavy and Other MetalsAluminumμg/L77100190160242486300460460NAArsenicμg/L82251.91.14.54.536Bariumμg/L32672627454545NAChromiumμg/L82251.41.42.22.211Copperμg/L8810055175.35.37.6602802803.1Ironμg/L313383150150150NALeadμg/L84502.51.14.26.06.02.5Manganeseμg/L88100178.84.74.76.4354242NANickelμg/L84505.52.1709.89.88.2Seleniumμg/L81133.51.41.45.0Thalliumμg/L31330.801.41.41.4NAVanadiumμg/L31330.731.21.21.2NAZincμg/L881004002407070806101500150081Cationic MetalsCalciumμg/L8810034000330001800180025000360008100081000NAMagnesiumμg/L87889400110006600130001800018000NAPotassiumμg/L3310055005700410041004100670067006700NASodiumμg/L331007900048000310003100031000160000160000160000NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.248Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment249Table 3.5.5. Results of Graywater Sample Analyses for Total Metals1AnalyteUnitsNo.samplesNo.detectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Heavy and Other MetalsAluminumμg/L88100380420505019054091091087Arsenicμg/L82252.01.52.932.90.018Bariumμg/L3310029287.47.47.45151511000Cadmiumμg/L81130.822.02.0NAChromiumμg/L84502.52.24.24.94.9NACopperμg/L88100100711010141404404401300Ironμg/L3267220150460460460300Leadμg/L85637.61.75.84343NAManganeseμg/L8810022137.37.38.9415151100Nickelμg/L84505.92.68.61010610Seleniumμg/L81133.81.71.7170Vanadiumμg/L32671.71.92.62.62.6NAZincμg/L8810089027054541302000350035007400Cationic MetalsCalciumμg/L8810035000360001900190026000370008200082000NAMagnesiumμg/L87889700110006500130001800018000NAPotassiumμg/L331005500640034003400340660066006600NASodiumμg/L331008100047000360003600036000160000160000160000NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.(3) EPA suspects that this measuredconcentrationmay be elevated due topositive interference, see Section3.1.3.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 250 Figure 3.5.5. Box and Dot Density Plot of Di ssolved Metals Concentrations Measured in Samples of Graywater A

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## 251 Figure 3.5.6. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Graywater A

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## 252 Figure 3.5.7. Box and Dot Density Plot of Pote ntial Hazard Quotients for Dissolved Metals in Samples of Graywater (Note: Replacement values for non-detects are circled). 

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## 253 Figure 3.5.8. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Graywater (Note: Replacement values for non-detects are circled). 

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## 254 3.2.5.5 Nutrients

Graywater samples were analyzed for four nutrient and nutrient-related parameters: ammonia nitrogen, nitrate/nitrite, TKN, and total phosphorus (see Table 3.5.6). The nutrient concentrations measured in graywater samples are displayed in Figure 3.5.9. The highest nutrient concentrations measured in graywater were: 4.5 mg/L (ammonia nitrogen), 2.4 mg/L (nitrate/nitrite), 45 mg/L (TKN), and 3.4 mg/L (total phosphorus); all of these values were measured in a single sample of shower gray water from a tugboat. A likely source of the phosphorus in graywater could be phosphate de tergents, although both phosphorus and nitrogen parameters also reflect food and possibly other wastes. Of these maximum nutrient concentrations, only TKN was high enough to fall with in the range of concen trations typical of untreated domestic wastewater (20 to 85 mg/L ; Metcalf and Eddy, 1979). Although each of these nutrients was occasionally detected in service water, only nitrat e/nitrite was present in service water at concentrations high enough to be comparable with those in graywater.

Figure 3.5.10 presents the PHQs calculated for the nutrients. As shown in this figure, total phosphorus PHQs ranged from 4.2 to 34 because concentrations in gr aywater consistently exceeded the screening benchmark. Graywater samp les from three tugboats also had PHQs of greater than 1 because the concentrations for ammonia nitrogen exceeded the screening
benchmark.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.5.6. Results of Graywater Sample Analyses for Nutrients1AnalyteUnitsNo.samplesNo.detectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2Ammonia As Nitrogen (NH3-N)mg/L881001.30.750.190.190.221.84.54.51.2Nitrate/Nitrite (NO3/NO2-N)mg/L87881.61.90.902.32.42.4NATotal Kjeldahl Nitrogen (TKN)mg/L88100106.72.22.23.87.74545NATotal Phosphorusmg/L881001.41.20.420.420.622.23.43.40.10Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.255Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 256 Figure 3.5.9. Box and Dot Density Plot of Nutrie nt Concentrations Measured in Samples of Graywater 

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## 257 Figure 3.5.10. Box and Dot Density Plot of Pote ntial Hazard Quotients for Nutrients in Samples of Graywater 

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## 3.2.5.6 Summary of the Characterization of Graywater Effluent Analyses

Table 3.5.7 summarizes the specific analytes in graywater effluent that may have the potential to pose risk to human health or the environment. EPA’ s interpretation of the realized risk that may be posed by these analytes, rela tive to pollutant loadings, background ambient and
source water contaminant levels and characteristic s, and other relevant information useful for this assessment, is presented in Chapter 5.

Pathogens were found at higher concentrations in graywater effluent than in any other type of pollutant. The highest concentrations of all three pathogen groups (fecal coliforms,
enterococci

, and E. coli ) were found in the effluent of one of the five tugboats sampled, but were found at high concentrations in all five samp led tugboats. For all eight vessels sampled, the majority of PHQs for all three pathogen groups were greater than 1 (PHQs for all fecal coliform samples were greater than 10), and, in ma ny cases, were between 100 and 10,000. The fecal
coliform concentrations most often exceeded the water quality benchmarks, followed by E. coli and enterococci concentrations, in that order. Pathogens were not detected in the one water taxi.

BOD was the pollutant with the next highest concentrations that exceeded water quality benchmarks, with PHQs>1 in all eight vessels and PHQ values exceeding 9 for five of the vessels. The highest BOD concentrations were found from the recreational powerboat (PHQ = 40). Concentrations of COD and TOC were positively correlated to BOD concentrations and were found at high levels in all ei ght vessels. Sulfide was detected in five of the eight vessels and
exceeded benchmark concentrations in all five instances (PHQs of up to 367). Sulfides were detected in graywater from all vessels sampled, a nd elevated in the five tugboat discharges, with PHQs ranging from 5-367. TSS and oil and grease (m easured as HEM) concentrations were also slightly elevated, particularly in tugboats. The highest HEM concentration (100 mg/L) was observed in the graywater discharge from a t ugboat. SGT-HEM was detected in six of eight vessels, but only one sample had a PHQ greater than 2.

Total nonylphenol polyethoxylates (sum of isomers from NP3EO to NP18EO) were notable only in one tugboat and the recreational boat. Total NPEO s was highest in the graywater sample collected from the recreational power boat. No short-chain alkylphenol ethoxylates (NP1EO,NP2EO or OP1EO or OP2EO) or bisphenol A were detected in any of the graywater samples. Likewise, no NP was detected, so no comparisons could be made to the screening
benchmark.

Among the nutrients sampled, total phosphorus concentrations exceeded the benchmark of 0.10 mg/L in all vessels sampled, with PHQs ranging from 4.2 to 34.

Concentrations of dissolved copper and zi nc regularly exceeded NRWQC benchmarks, with a maximum PHQ of 90 for dissolved coppe r and 18 for dissolved zinc. The median
concentration for dissolved al uminum was 160 μg/L, though no benchmark exists. Service water

258Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 259 concentrations of dissolved alum inum, copper, and zinc were mode rately influential, but only in the graywater samples with the lowest measured concentrations. Total arsenic was detected in the shrimping 36 

## and recreational vessel where concentrations exceeded NRWQC benchmarks (PHQ values were 111 and 161, respectively). Total aluminum concentrations exceeded NRWQC benchmarks in seven of the eight vessels, with one vessel exceeding a PHQ of 10.

36 

### See Section 3.2.5.4and footnote 3 in Table 3.5.5.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.5.7. Characterization of Graywater Effluent and Summary of Analytes thatMay Have the Potential to Pose Risk(1) Analytes are generallyboldedwhen a large proportion of the samples have concentrations exceeding the NRWQC (e.g., 25 to 50 percent), when several of the samples have PHQs > 10 (e.g.,two or three of five), when a few samples result in PHQs greatly exceeding the screening benchmark(i.e., 100s to 1,000s), in the case of oil and grease and for nonylphenol, when one or moresamples exceed an existing regulatory limit by more than a factorof 2, or when concentrationsof analytes are sufficiently high that they may have the potential topose risks to local water bodies.See text in Section3.1.3for a definition of PHQs and Table 3.1 for screening benchmarks used to calculate these values.Analytes that May Have the Potential to Pose Risk in Graywater Effluent and Vessel Sources1,2Vessel Type (no. vessels) Microbi ologicals Volatile Organic Compounds Semivolatile Organic Compounds Metals (dissolved) Metals ( total) Oil and Grease Sulfide Short-Chain Alkylphenol Ethoxylates or NPs Long-Chain Alkylphenol Ethoxylates Nutrients BOD, COD, and TOC

Total Suspended Solids Other Physical/Chemical ParametersTugboat (5)fecal coliformenterococciE. coliAl,Cu,ZnAlxxxTP,NH3-NBODCODTOCxShrimping Vessel (1)fecal coliformenterococciE. coliCu,ZnAs, AlTPBODCODTOCWater Taxi (1)Cu,ZnAlTPBODCODTOCTRCRecreational (1)fecal coliformenterocociE. coliCu, ZnAs, AlxxTPBODCODTOC(2) EPA notes that the conclusion of potential risk is drawn froma small sample size, in somecases a single vessel, for certain discharges sampled from some vessel classes. EPA included theseresults in the tables to provide a concise summary of the datacollected in the study, but strongly cautions the reader that these conclusions, where there are onlya few samples from a given vesselclass, should be considered preliminary and might not necessarily represent pollutantconcentrations from these discharges fromother vessels in this class.260Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.6 Engine Effluent

Vessel engines are primarily used for two pur poses: propulsion and el ectrical generation. Engines used for vessel propulsion can be either outboard or inboard engines. Vessels that require significant lighting or have electrical equipment such as appliances and/or electric motors are likely equipped with engines used for electrical generation.

Engine cooling systems include direct cooli ng, indirect cooling, and keel cooling. Direct and indirect cooling systems discharge wastew ater, while keel cooling systems are zero discharge. Some engines with dir ect and indirect cooling systems al so use water to cool and quiet their exhaust, referred to as engine wet exhaus t. These engines inject spent cooling water from the engine into the exhaust stream, so that the co oling water directly cont acts the engine exhaust. Possible constituents of concern in engine effluent include the following: thermal loading; metals from the discharge contacting the exhaust syst em, from erosion of moving engine components (e.g., pistons), or from trace constituents of th e fuel; and oil and grease and organic compounds as constituents of fuel or possible products of incomplete fuel combustion.

The volume of engine cooling water discharged depends on th e type of engine and power level of operation. Vessels with outboard propulsion engines disc harge between 1 and 2 gpm of raw cooling water per engine based on observa tions made during the sampling program. The cooling water discharge rate from inboard marine diesel engines varies based on power levels, but typically averages around 20 gpm when engines operate between 1,500 and 2,000 rpm (Sherwood Pumps, 2009). Marine di esel generator sets require 5 to 6 gpm of cooling water for smaller units (9.5 kW) (Cummins, 2008), and up to 20 and 25 gpm of cooling water for larger marine generator sets (80 kW) (Cummins, 2004). Daily discharge rates for these engines are a function of daily operating time.

261Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Collecting the Engine Effluent of a Water Taxi at Idle

Collecting the Engine Effluent of a Tow and Salvage Vessel at Full Speed

For this study, EPA collected engine cooling water discharge samples from a variety of vessel classes with different engine types, as summarized in Table 3.6.1. Note that two of the sampled vessels are recreational vessels and ar e not study vessels. In addition, both of the sampled research vessels and four of the six sampled tow/salvage vessels (those with outboard propulsion engines) were manufact ured for pleasure and therefor e are also recreational vessels and not study vessels. EPA sampled engine effl uent from these vessels because all of the sampled engines can be installed on either recreational or nonrecrea tional vessels and are representative of engines on study vessels.

262Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Samp les were analyzed for classical pollutant s, metals (dissolved and total), SVOCs, and VOCs. Engine discharge samples were typically co llected from the discharge port using a sample transfer jar attached to a pole. The contents of the sample tr ansfer jar were pour ed into a lined utility bucket. If the engines were operated at multiple engine levels (e.g., idle, half power, full power), then equal portions of sample were collected from each power level and composited for a single laboratory analysis. Ten of the 13 samp led vessels with inboard propulsion engines and all six sampled vessels with outboard propulsion e ngines were operated at multiple power levels. Similarly, if a vessel operated more than one engine, then equal portions of sample were collected from each engine and composited for a single laboratory analysis. However, samples for analysis of oil and grease and VOCs are not appropriate to composite. For these analytes, samples were collected and analy zed separately for each engine power level or were collected from only one of the multiple engines.

Table 3.6.1. Sampled Engine Characteristics

Fuel Type Cooling Type Engine Wet Exhaust? Number of Vessels Sampled Vessel Types

Inboard Propulsion Engines

Diesel Direct Yes 3 Water Taxi (2), Fishing

Diesel Indirect Yes 5 Tour Boat (2), Water Taxi, Tow/Salvage, Fire

Boat

Diesel Unknown Yes 3 Tour Boat, Water Taxi, Recreational

Diesel Unknown Unknown 1 Fishing

Gasoline Indirect Yes 1 Recreational
Outboard Propulsion Engines

Gasoline Direct Yes 5 Tow/Salvage (4), Research

Gasoline Unknown Yes 1 Research

Generator Engines

Diesel Direct Yes 1 Tour Boat

Diesel Indirect Yes 1 Fire Boat

Diesel Unknown Unknown 2 Fishing, Tour Boat

Unknown Indirect Yes 1 Water Taxi



## EPA also observed a number of vessels, part icularly tug boats a nd larger commercial fishing vessels, that use keel -cooled propulsion and generator e ngines. The vessels were not sampled as these closed-loop cooling systems do not have a discharge. Approximately two-thirds
of the 61 vessels visited had k eel cooled engine systems.

An additional source of relevant engine effluent data is EPA’s sampling program for the Uniform National Discharge Standards (UNDS ) rulemaking. In 2006, EPA sampled propulsion engine wet exhaust discharges from two small Ar med Forces vessels with inboard diesel engines with engine wet exhaust: a 36-foot landing craf t personnel large (LCPL) and a 7-meter rigid inflatable boat (RIB) (USEPA , 2008b). This sampling program was specifically designed to

263Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## characterize engine wet exhaust discharges by po wer level. W hile these Armed Forces vessels are not study vessels, the engine s used on these vessels are comp arable to those used on study vessels. Samples from both vessels were analy zed for eight classical pollutants and 92 volatile and semivolatile compounds. Samples from the LCPL were also analyzed for seven total metals. Grab samples of the engine discharge were collect ed from sample taps installed into the exhaust lines of the vessels. Three replicate engine disc harge samples were collected at each of five different engine power levels: 0 percent (idle), 25 percent, 50 percent, 75 percent, and 100 percent (full power). Three rep licate background seawater samples were also collected. Sampling was conducted in the open ocean.

3.2.6.1 Inboard Propulsion Engines

For this study, EPA collected cooling water discharge samples from inboard propulsion engines on 13 vessels: four water taxis, three tour boats, two fishing vessels, one tow/salvage vessel, one fire boat, and two recreational ve ssels (Table 3.6.1). Thes e engines included both direct and indirect cooling disc harges from both gasoline- and diesel-fueled engines. For the UNDS program, EPA sampled engi ne wet exhaust from inboar d propulsion engines on two personnel craft. Results for each class of polluta nt are presented and discussed in the following
subsections.

The Inboard Propulsion Engine of a Fire Boat

264Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.6.1.1 Classical Po llutants

Table 3.6.2 presents analytical results for 11 classical polluta nts detected in samples of discharges from inboard propulsi on engines. All of the classical pollutants analyzed for were
detected and the detected results are shown in Figure 3.6.1. Engine cooling water discharge differs from all other discharges in that the wa ter used in the engines is drawn from surrounding waters and immediately discharged to the same waters. For this reason, EPA analyzed the sample results to determine which pollutant concentr ations were contributed primarily by engine operations and which were contributed primar ily by background ambient concentrations (see footnotes on Table 3.6.2 and Figure 3.6.1). The re mainder of this subsection discusses those pollutants found to be contributed primarily by engine operations.

Temperature increases in engi ne effluent above background were generally less than 5°C. However, on three vessels operated at higher po wer levels (recreational vessel, tow/salvage vessel, and fire boat), temperatur e increases were greater than 20° C. EPA’s findings were similar for the UNDS sampling program, with temperature increases ranging from less than 3°C at idle to a maximum of 27°C at full power.

Oil and grease (measured as HEM) was detect ed in the majority of engine effluent samples; however, detected concentrations were low (most were less than 5 mg/L). All sample results were well below the 33 CFR § 151.10 and MA RPOL prohibition of the discharge of oil and oily mixtures with an oil content greater than 15 ppm into seaw ater from vessels. HEM values exceeded 5 mg/L in only th ree grab samples, and all three were collected during engine operation at relatively high power levels. Fo r the UNDS sampling program, HEM was not detected in any engine effluent samples, regardless of power level ( ≤ 4 mg/L).

Sulfide was detected in only two of 11 samples at concentrations of 0.013 and 0.016 mg/L. These measured concentrations are six to eight times greater than the most conservative PHQ screening benchmark of 0.002 mg/L. Sulfide mi ght be present as a trace constituent in the fuel, as a product of incomplete combustion, or due to formation within the biofilm in the cooling system piping. For the UNDS sampling progr am, sulfide was not detected in any engine wet exhaust samples.

For this study, TSS concentrations in effl uent discharge samples were contributed primarily by background ambient c oncentrations (i.e., sample concentrations ranged from <5 to 17 mg/L while ambient water concentrations ranged from 7.8 to 20 mg/L). For the UNDS sampling program, TSS was not de tected in any of the sample s from the LCPL; however, TSS was present in the RIB discharge samples at co ncentrations ranging from 6 to 14 mg/L, which were statistically greater than background for some power levels. UNDS TSS results correspond with the field observations for samples from th e RIB at the highest pow er levels (i.e., the samples were observed to be cloudy and contained settleable material s (resembling soot)). In this

265Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 266 study, EPA observed that some effluent engi ne samples were also cloudy and contained settleable materials at higher power levels.

TRC was detected in only one engine effluent sample collected from a fishing vessel at a concentration of 0.17 mg/L. Fish hold effluent from this vessel, containing TRC at a concentration of 0.27 mg/L, was di scharged into the water surr ounding the vessel just prior to collection of engine effluent samples; the propuls ion engine on this vessel utilizes the ambient water for cooling. EPA believes that the TRC valu e for the engine effluent sample was likely influenced by the fish hold effluent discharge.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.2. Results of Inboard Propulsion EngineSample Analyses for Classical Pollutants1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion (%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.Conductivity2mS/cm106100116.10.220.220.22174444Dissolved Oxygen3mg/L1061006.87.41.72.04.09.31314Hexane ExtractableMaterial (HEM)mg/L128663.02.23.85.45.7pH2SU13131006.96.66.26.26.47.47.98.0Salinity2ppt10101006.93.30.100.100.109.92828Silica Gel Treated HEM(SGT-HEM)mg/L127584.02.63.64.34.4Sulfidemg/L112180.00620.0130.013TemperatureC131310022216.59.917263639Total Residual Chlorine2mg/L1317.70.0480.100.17Total Suspended Solids(TSS)3mg/L118731113161717Turbidity3NTU131310032291.22.718456980Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Sample concentrations were almost completely accounted for (≥90 percent) by background concentrations in ambient water.(3) Sample concentrations were predominantly accounted for (≥50 percent and <90 percent) by background concentrations in ambient water.267Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 268 Figure 3.6.1. Box and Dot Density Plot of Clas sical Pollutant Values Measured in Samples of Inboard Propulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. 

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# 10.00Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.6.1.2 Metals

Inboard propulsion engine effluent samples were analyzed for 22 dissolved and total

m etals. Table 3.6.3 presents analytical results for the 16 metals that were detected in one or more engine effluent samples. The detected resu lts are also shown in Figures 3.6.2 and 3.6.3 for dissolved and total metals, resp ectively. Figures 3.6.4 and 3.6.5 disp lay the distribution of PHQs based on the screening benchmark for each of the dissolved and total meta ls. EPA analyzed the sample results to determine which metals were contributed primarily by engine operations and which were contributed primarily by background ambient concentrations. The remainder of this
subsection discusses those metals found to be contributed primarily by engine operations.

For most metals, concentrations for the dissolv ed and total forms were similar, indicating that engine operations contribute metals in dissolved rather that particulate form. Two exceptions were iron and lead. A comparison of dissolved and total iron concentrations indicates that almost all iron was present in particulat e form. One possible source of par ticulate iron in e ngine effluent
is rust. Lead was detected in e ngine effluent samples from only four of the 13 vessels sampled (three water taxis and a tow/sa lvage vessel). Total lead concentrations (maximum measured
concentration = 9.6 μ g/L) exceeded dissolved lead concentrations by three to four times.

Dissolved and total copper we re detected in almost all engine effluent samples at concentrations ranging from 3 to 53 μ g/L and 5 to 66 μ g/L, respectively. Dissolved copper
concentrations exceeded the P HQ screening benchmark of 3.1 μ g/L (saltwater chronic criterion) by one to 17 times (see Figure 3.6.4). In contrast , none of the total c opper concentrations exceeded the PHQ screening benchmark of 1,300 μ g/L (human heath for consumption of water and aquatic organisms (see Figure 3.6.5)).

Dissolved and total zinc were also detected in a majority of engine effluent samples. Detected concentrations ranged from 12 to 120 μ g/L and 11 to 95 μ g/L for dissolved and total zinc, respectively (see Figures 3.6.2 and 3.6.3). However, only the two highest detected dissolved zinc concentrations (83 and 120 μ g/L) exceeded the PHQ screening benchmark of 81

μ g/L (saltwater chronic criterion). None of the detected total zinc concentrations exceeded the PHQ screening benchmark of 7,400 μ g/L (human heath for consumption of water and aquatic organisms).

Dissolved and total nickel were detected in approximately half of the engine effluent samples, and dissolved and total chromium and lead were each detected in fewer than half of the engine effluent samples. Detect ed concentrations were generally within five times the reporting limit and none exceeded the screening benchmarks for these analytes (see Figures 3.6.4 and 3.6.5). Note, however, that lead is a persistent bioaccumulative and toxic chemical (PBT) and the long-term mass loading is more importan t than the discharg e concentrations.

269Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 270 Dissolved manganese was detected in 11 of 13 engine effluent samples. Manganese was predominantly in particulate form in bac kground ambient water; therefore, EPA assumed dissolved manganese concentrations in engine effluent samples to be contributed by engine operations. NRWQCs or other P HQ screening benchmarks have not been determined for dissolved manganese.

Dissolved iron and dissolved and total vanadium were each detected in no more than three engine effluent samples at measured concentrations clos e to the reporting limit. NRWQCs or other PHQ screening benchmarks have not been determined for these analytes at this time.

Finally, the concentrations in engine effluent discharges that exceeded the PHQ screening
benchmark concentrations for dissolved selenium , total aluminum, and total arsenic were caused by high background concentrations in ambi ent water (which exceeded benchmark concentrations) and not by engine operations. Moreover, in the case of dissolved and total arsenic and selenium, measured concentrations above their respective re porting limits (three different water taxis and the recreational vessel) may be substantially elevated due to positive interference (see Section 3.1.3 ). After subtracting the contri bution of ambie nt water (also potentially elevated due to positive interference) , none of the detected concentrations exceeded their PHQ screening benchmarks.

Comparing study sampling results with the metals data from the engine wet exhaust sampling conducted for the UNDS program affirm s EPA’s sampling results. For the UNDS program, EPA determined that five of the seve n total metals analyzed for were present at concentrations statistically gr eater than background: cadmium , chromium, copper, lead, and nickel. Total mercury was not detected in any sa mples, and total arsenic concentrations did not exceed background concentrations. Table 3.6.4 compares the metals results from this study and the UNDS program.

EPA notes that there were some important differences between the UNDS sampling and the sampling conducted in this study to cons ider when comparing the results. The UNDS program used a different analytical method, as well as a different methodology to calculate mean concentrations. Also, background meta ls concentrations in harbors for this study are greater than those in the open ocean for the UNDS program.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.3. Results of Inboard PropulsionEngine Sample Analyses for Metals1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.Heavy and Other MetalsAluminum, Dissolved2μg/L1312922001003.823180880940Aluminum, Total2μg/L13131003403005961120410920940Arsenic, Dissolved3,4μg/L134314.28.71214Arsenic, Total3,4μg/L136464.58.71315Barium, Dissolved2μg/L771003532232329346363Barium, Total2μg/L771003634242428356363Chromium,Dissolvedμg/L133231.20.751.92.1Chromium,Totalμg/L133231.30.952.42.6Copper, Dissolvedμg/L131292166.61.65.5235153Copper, Totalμg/L131185189.35.6256266Iron,Dissolvedμg/L711464150150Iron, Total3μg/L7686250250150310520520Lead,Dissolvedμg/L133231.50.602.12.3Lead,Totalμg/L134313.04.18.59.6Manganese,Dissolvedμg/L131185434430558291Manganese, Total2μg/L1311855553407495100Nickel, Dissolvedμg/L137544.42.54.34.95.3Nickel, Total2μg/L137544.63.14.35.55.6Selenium, Dissolved2,4μg/L1343111213234Selenium, Total3,4μg/L1343111213132Vanadium,Dissolvedμg/L73430.901.41.71.7Vanadium,Totalμg/L72291.41.11.61.6Zinc,Dissolvedμg/L13969382374110120Zinc,Totalμg/L131185382911758995Cationic MetalsCalcium, Dissolved2μg/L1313100800003700024000240002600062000310000310000271Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment272Table 3.6.3. Results of Inboard PropulsionEngine Sample Analyses for Metals1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.Calcium, Total2μg/L1313100810003700026000260002900062000310000310000Magnesium, Dissolved2μg/L13131002000001200052005200590016000010000001100000Magnesium, Total2μg/L13131002000001200058005900650016000010000001100000Potassium, Dissolved2μg/L771003200039000400040004100580006300063400Potassium, Total2μg/L771003200039000370037003800580006500065000Sodium, Dissolved3μg/L77100770000860000360003600040000160000016000001600000Sodium,Total3μg/L77100860000860000350003500039000160000020000002000000Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Sample concentrations were almost completely accounted for (≥90 percent) by background concentrations in ambient water.(3) Sample concentrations were predominantly accounted for (≥50 percent and <90 percent) by background concentrations in ambient water.(4) Values well above their respective reporting limits are suspected of being elevated due to positive interference. (See discussion in Section3.1.3).Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## Table 3.6.4. Comparison of Metals Results fo r EPA P.L. 110-299 a nd UNDS Engine Wet Exhaust Sampling

Mean Inboard Propulsion Engine Effluent Concentration (μg/L) Metal EPA P.L. 110-299 Sampling UNDS Engine Wet Exhaust Sampling
Arsenic, Total 4.5 2.2
Cadmium, Total Not Detected (Reporting Limit = 1) 0.024
Chromium, Total 1.3 0.33
Copper, Total 18 24

Lead, Total 3.0 0.2

Nickel, Total 4.6 6.8



## 273Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 274 Figure 3.6.2. Box and Dot Density Plot of Diss olved Metals Concentrations Measured in Samples of Inboard Pro pulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Values well above their respective reporting limits for dissolved arsenic and selenium are suspected of being elevated due to positive interference). 

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## 275 Figure 3.6.3. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Inboard Pro pulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Values well above their respec tive reporting limits for total arsenic and selenium are suspected of being substantially elevated due to positive interference). 

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## 276 Figure 3.6.4. Box and Dot Density Plot of Pote ntial Hazard Quotients for Dissolved Metals in Samples of Inboard Propulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Replacement values for non-detects are circled. Al so, values well above their respective reporting limits for dissolved arsenic and selenium are suspected of being elevated due to positive interference). 

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u o t ie n tChapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 277 Figure 3.6.5. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Inboard Pro pulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Replacement values for non-detects are circled. Al so, values well above their respective reporting limits for total arsenic and selenium are suspected of being elevated due to positive interference). 

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P o t e n t ia l H a z a r d Q

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# 10.00Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.6.1.3 Semivolatile Organic Compounds

Inboard propulsion engine effluent samp les were analyzed for 76 SVOCs for the sampling conducted as part of the P.L. 110-299 st udy. Table 3.6.5 presents an alytical results for
the 31 SVOCs that were detected in one or more engine effluent samples. The detected results are also shown in Figures 3.6.6 and 3.6.7 for analyt e concentrations and for PHQs based on the lowest NRWQC or other PHQ screening benc hmark where applicable, respectively. EPA analyzed the sample results to determine whic h SVOCs were contributed primarily by engine operations and which were contributed primar ily by background ambien t concentrations. All were found to be contributed primarily by engine operations.

Many of the detected SVOCs can be classified among the following pollutant classes: polycyclic aromatic hydrocarbons or PAHs (14 analytes), straight-chain hydrocarbons (five analytes), phenol and methyl phenols (five analytes), and pht halates (two analytes). These
include all of the SVOCs detected most fre quently and at the hi ghest concentrations.

PAHs are present in fuel in small amounts and may be formed as products of incomplete
combustion. EPA has identified seven PAHs as probable human carcinogens, six of which were detected in engine effluent collected from a recreational vessel with a gasoline engine dewinterized immediately prior to sampli ng (see details below): benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyre ne, chrysene, and indeno(1,2,3- cd)pyrene. Most of these compounds exceed a PHQ of 1,000 as shown in Figure 3.6.7.

Phthalates are plasticizers (chemicals added to plastics to make them flexible) and are commonly detected in environmental samples (A TSDR, 2002). Bis(2-ethylhexyl) phthalate was detected at concentration just a bove the screening benchmark of 1.2 μ g/L (human heath for consumption of water and aquatic organisms).

Phenol and methyl phenols are present in pe troleum products and may also be generated as products of incomplete combustion. Discharges of phenol and methyl phenols are assumed to not cause any environmental impacts as detect ed concentrations did not exceed the PHQ screening benchmarks for thes e analytes. Straight-chain (a lkane) hydrocarbons are also components of fuel; none of the st raight-chain hydrocarbons detected in engine effluent have a NRWQC or other PHQ screening benchm ark, and they are not PBT chemicals

It is important to note that 11 of the detected SVOCs we re found only in one sample
collected from a recreational ve ssel (recreational vessels are no t study vessels). These included all six of the detected PAHs that are probabl e human carcinogens, as well as four additional PAHs. Engine effluent from this recreational vessel also contributed the maximum detected concentrations for six additional analytes, including several additional PAHs as well as four of the five detected phenol/methyl phenols. (Maximum sample concentrations for 2,4- dimethylphenol, straight-chain hydrocarbons, and phthalates were contributed by other vessels.)

278Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 279 This recreational vessel was the only sampled vessel th at used gasoline as fuel rather than diesel; however, the lack of replication pr ecludes any determination as to wh ether fuel type is a critical factor for engine effluent characteristics. In addition, the engines on this vessel were dewinterized immediately prior to sampling. The lack of engine operatio n for several months prior to sampling could have contributed to engine effluent characteristics.

Comparing study sampling results with the resu lts from the engine wet exhaust sampling conducted for the UNDS program reveals some si milarities. For the LCPL, phenol and bis(2- ethylhexyl)phthalate were the only detected S VOCs; however, the presence of bis(2-ethyhexyl) phthalate in LCPL effluent may be due to labo ratory contamination and so data for the purpose of comparison are not shown in this report. Fo r the RIB, phenol was the only detected SVOC. EPA determined that phenol was present at conc entrations statistically greater than background. Table 3.6.6 compares the phenol results from this study to those from the UNDS program. Note that the UNDS program used a different me thodology to calculate mean concentrations.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.5. Results of Inboard PropulsionEngine Sample Analyses for SVOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.1,2-Diethyl-Cyclobutaneμg/L11100101,6-Dimethylμg/L11100351-Methylnaphthaleneμg/L2210013243.23.23.22424242,4-Dimethylphenolμg/L124333.72.416222-Methylnaphthaleneμg/L867517130.90364646Acenaphtheneμg/L1218.32.01.52.2Acenaphthyleneμg/L123257.01.74461Anthraceneμg/L1218.33.31218Benzo(a)anthraceneμg/L1218.33.31318Benzo(a)pyreneμg/L1218.33.21116Benzo(b)fluorantheneμg/L1218.32.87.811Benzo(g,h,i)peryleneμg/L1218.32.66.99.8Benzo(k)fluorantheneμg/L1218.33.11115Bis(2-ethylhexyl)phthalateμg/L124331.71.21.820Chryseneμg/L1218.33.31218Di-n-butyl phthalateμg/L126501.71.11.63.53.8Eicosaneμg/L221001928101010282828Fluoreneμg/L124333.52.81418Heptadecaneμg/L4410029273.53.53.8678080Indeno(1,2,3-cd)μg/L1218.32.55.68.0m-Cresolμg/L412513344545Naphthaleneμg/L12108.3306.61.934160210n-Hexadecaneμg/L3310026173.13.13.1575757Nonadecaneμg/L221002738151515383838NonanoicAcidμg/L1110011o-Cresolμg/L331006.65.85.75.75.78.48.48.4280Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment281Table 3.6.5. Results of Inboard PropulsionEngine Sample Analyses for SVOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.Octadecaneμg/L2210010173.13.13.1171717p-Cresolμg/L7571261724110110Phenanthreneμg/L123256.11.33548Phenolμg/L12867273.737140170Pyreneμg/L1218.36.64057Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Sample concentrations were almost completely accounted for (≥90 percent) by background concentrations in ambient water.(3) Sample concentrations were predominantly accounted for (≥50 percent and <90 percent) by background concentrations in ambient water.Table 3.6.6. Comparison of Phenol Results for EPA P.L. 110-299 and UNDS Engine Wet Exhaust SamplingMean Inboard Propulsion Engine Effluent Concentration (μg/L)UNDS Small Boat Engine Wet Exhaust SamplingAnalyteEPA P.L. 110-299 SamplingLCPLRIBPhenol271314Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 282 Figure 3.6.6. Box and Dot Density Plot of SV OC Concentrations Measured in P.L. 110-299 Study Samples of Inboard Propulsion Engine Effluent
SVOCs are identified as follows: (1) 1,2-Diethyl-Cyclobutane (2) 1,6-dimethylnaphthalene (3) 1-methylnaphthalene (4) 2,4-Dimethylphenol (5) 2-Methylnaphthalene (6) Acenaphthene (7) Acenaphthylene (8) Anthracene (9) Benzo(a)anthracene (10) Benzo(a)pyrene (11) Benzo(b)fluoranthene (12) Benzo(g,h,i)perylene (13) Benzo(k)fluoranthene (14) Bis(2-ethylhexyl) phthalate (15) Chrysene (16) Di-n-butyl phthalate (17) Eicosane (18) Fluorene (19) Heptadecane (20) Indeno(1,2,3-cd)pyrene (21) m-Cresol (22) Naphthalene (23) n-Hexadecane (24) Nonadecane (25) Nonanoic Acid (26) o-Cresol (27) Octadecane (28) p-Cresol (29) Phenanthrene (30) Phenol (31) Pyrene 

## 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 

# SVOCs 1 10 100

C o n c e n t r a t io n ( u g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 283 Figure 3.6.7. Box and Dot Density Plot of Pote ntial Hazard Quotients for SVOCs in P.L. 110-299 Study Samples of Inboard Propulsion Engine Effluent SVOCs are identified as follows (replacement values for non-detects are circled): (1) 1,2-Diethyl-Cyclobutane (2) 1,6-dimethylnaphthalene (3) 1-methylnaphthalene (4) 2,4-Dimethylphenol (5) 2-Methylnaphthalene (6) Acenaphthene (7) Acenaphthylene (8) Anthracene (9) Benzo(a)anthracene (10) Benzo(a)pyrene (11) Benzo(b)fluoranthene (12) Benzo(g,h,i)perylene (13) Benzo(k)fluoranthene (14) Bis(2-ethylhexyl) phthalate (15) Chrysene (16) Di-n-butyl phthalate (17) Eicosane (18) Fluorene (19) Heptadecane (20) Indeno(1,2,3-cd)pyrene (21) m-Cresol (22) Naphthalene (23) n-Hexadecane (24) Nonadecane (25) Nonanoic Acid (26) o-Cresol (27) Octadecane (28) p-Cresol (29) Phenanthrene (30) Phenol (31) Pyrene 

# 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 

# SVOCs 0.0001 0.0010 0.0100 0.1000 1.0000 10.0000 100.0000 1000.0000

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## 3.2.6.1.4 Volatile Organic Compounds

Inboard propulsion engine effluent samp les were analyzed for 84 VOCs. Table 3.6.7 presents analytical results for the 38 VOCs that we re detected in one or more engine effluent

sam ples. The detected results are also shown in Figures 3.6.8 and 3.6.9 for analyte concentrations and for PHQs based on the lowe st NRWQC or other P HQ screening benchmark where applicable, respectively. EPA analyzed the sample results to determine which VOCs were contributed primarily by engine operations and which were co ntributed primarily by background
ambient concentrations. All were found to be contributed primarily by engine operations.

Approximately one-third of the detected VOC s were frequently detected in engine effluent (i.e., greater than half of the sample d vessels). Some of these compounds are volatile constituents of fuel, specifically benzene, to luene, ethylbenzene, a nd xylene. Others are trimethylbenzenes, which are natu rally present in fuel, and ket ones, which may be formed as products of incomplete combustion. Among these compounds, only benzene and toluene have an NRWQC. Approximately half of the detected be nzene concentrations (f rom water taxis, tour
boats and a recreational ve ssels) exceeded the PHQ screening benchmark of 2.2 μ g/L (human heath for consumption of water and aquatic or ganisms), including discharges from one vessel that exceeded the benchmark by a factor of more than 50 (the next highest concentration that exceeded the benchmark was by less than a factor of 4) (see Figure 3.6.9). None of the detected
toluene concentrations exceeded th e PHQ screening benchmark of 1,300 μ g/L (human health for consumption of water and aquatic organisms).

Approximately one-third of the detected VOCs were detected relatively infrequently (i.e., detected in fewer than half the sampled vesse ls). Among these compounds, only chloroform and methylene chloride have an NRWQC. However, none of the detected concentrations for these two analytes exceeded the PHQ screening benchmarks of 5.7 μ g/L (human heath for consumption of water and aquatic organisms) and 1,300 μ g/L (human heath for consumption of water and aquatic organisms), respectively.

The final third of detected VOCs were detected in engine effluent from only one or two vessels. None of these analytes have an NRWQC or are PBT chemicals, and are therefore not expected to have the poten tial to pose risk to human health or the environment.

It is important to note the maximum detect ed concentrations for 11 of the VOCs were found in samples collected from a recreational vessel (re creational vessels are not study vessels). These included benzene, toluene, ethylbenzen e, xylene, and trimethylbenzenes (maximum sample concentrations for ketones were contri buted by other vessels). As noted above, this recreational vessel was the only sampled vessel that used gasoline as fuel rather than diesel; however, this data set is too small to demonstrate whether fuel type is a cr itical factor for engine
effluent characteristics. In addi tion, the engines on this vessel were dewinterized immediately

284Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 285 prior to sampling. The lack of engine operation fo r several months prior to sampling could have contributed to engine e ffluent characteristics.

Comparing these sampling results with the re sults from the engine wet exhaust sampling conducted for the UNDS program reveals some similarities. For the LCPL, no VOCs were detected. For the RIB, 1,2,3-trimethylbenzene, and 1,3,5-trimethylbenzen e were the detected VOCs. However, EPA determined that the trimethyl benzenes were not present at concentrations statistically greater than background.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.7. Results of Inboard PropulsionEngine Sample Analyses for VOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.2MedianConc.MinimumConc.10%25%75%90%MaximumConc.2(2-Methyl-1-Propenyl)-Benzeneμg/L111.003.21,2,3,4-Tetrahydro-5-Methylnaphthaleneμg/L111.00241,2,3,4-Tetrahydro-6-Methylnaphthaleneμg/L221.0019334.64.64.63333331,2,3,4-Tetrahydroμg/L221.0012223.23.23.22222221,2,4-Trimethylbenzeneμg/L771.006.11.80.120.120.303.832321,3,5-Trimethylbenzeneμg/L750.712.10.700.927.27.21,3-Methylnaphthaleneμg/L111.004.21,7-Methylnaphthaleneμg/L111.00192,3-Dihydro-4-Methyl-1HIndeneμg/L111.00532,6-Dimethylμg/L111.00412-Butanoneμg/L771.00177.82.62.63.03240402-Ethyl-1,3,5-TrimethylBenzeneμg/L111.004.42-Ethyl-1,4-DimethylBenzeneμg/L111.00202-Hexanoneμg/L750.712.11.12.93.23.24-Isopropyltolueneμg/L730.431.81.31.41.44-Methyl-2-Pentanoneμg/L730.431.90.801.61.6Acetoneμg/L881.0058346.06.015110150150Benzeneμg/L1290.75122.30.175.484120Benzocycloheptatrieneμg/L111.0039Biphenylμg/L860.754.13.00.274.51212Chloroformμg/L1240.331.71.02.12.1Dimethocxymethaneμg/L111.0089Ethylbenzeneμg/L1260.502.30.100.831216Isopropylbenzeneμg/L730.431.91.41.51.5286Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment287Table 3.6.7. Results of Inboard PropulsionEngine Sample Analyses for VOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.2MedianConc.MinimumConc.10%25%75%90%MaximumConc.2m-,p-Xylene (sum ofisomers)μg/L771.00111.80.300.300.902.07070Methylacetateμg/L710.142.41.51.5Methyl tertiary butyl ether(MTBE)μg/L710.142.41.91.9Methylenechlorideμg/L1240.331.20.140.190.20n-Butylbenzeneμg/L730.431.81.01.11.1n-Pentadecaneμg/L221002431161616313131n-Propylbenzeneμg/L74571.50.150.402.22.2n-Tetradecaneμg/L2210020336.56.56.5333333O-Xyleneμg/L771005.51.50.200.200.651.83232sec-Butylbenzeneμg/L71142.31.41.4Styreneμg/L771006.11.30.130.130.503.43535Tolueneμg/L12867110.902.880110Trichlorofluoromethaneμg/L1218.32.11.92.7Vinylacetateμg/L71142.41.91.9Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) In some cases, the detected concentration(s) for an analytecould be lower than the replacement value (1⁄2 of the reporting limit) for a concentration that was nondetected. In anextreme (but possible) case, this couldresult in an average concentration for an analyte that is greater than the maximum detected concentration.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 288 Figure 3.6.8. Box and Dot Density Plot of Vo latile Organic Compounds Concentrations Measured in P.L. 110-299 Study Samples of Inboard Propulsion Engine Effluent
VOCs are identified as follows: (1) (2-Methyl-1-Propenyl)-
Benzene (2) 1,2,3,4-Tetrahydro-5- Methylnaphthalene (3) 1,2,3,4-Tetrahydro-6- Methylnaphthalene (4) 1,2,3,4- Tetrahydronaphthalene (5) 1,2,4-Trimethylbenzene (6) 1,3,5-Trimethylbenzene (7) 1,3-Methylnaphthalene (8) 1,7-Methylnaphthalene(9) 2,3-Dihydro-4-Methyl-1HIndene (10) 2,6-dimethylnaphthalene (11) 2-Butanone (12) 2-Ethyl-1,3,5-TrimethylBenzene(13) 2-Ethyl-1,4-DimethylBenzene (14) 2-Hexanone, (15) 4-Isopropyltoluene (16) 4-Methyl-2-Pentanone (17) Acetone (18) Benzene (19) Benzocycloheptatriene (20) Biphenyl (21) Chloroform (22) Dimethoxymethane (23) Ethylbenzene (24) Isopropylbenzene (25) m-,p-Xylene (sum of isomers) (26) Methyl acetate (27) Methyl tertiary butyl ether (MTBE) (28) Methylene chloride (29) n-Butylbenzene, (30) n-Pentadecane (31) n-Propylbenzene (32) n-Tetradecane (33) O-Xylene (34) sec-Butylbenzene (35) Styrene (36) Toluene (37) Trichlorofluoromethane (38) Vinyl acetate 

### 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 

# VOCs 0.1 1.0 10.0 100.0

C o n c e n t r a t io n ( u g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 289 Figure 3.6.9. Box and Dot Density Plot of Potent ial Hazard Quotients for Volatile Organic Compounds in P.L. 110-299 Study Samples of Inboard Propulsion Engine Effluent VOCs are identified as follows (replacemen t values for non-detects are circled): (1) (2-Methyl-1-Propenyl)-
Benzene (2) 1,2,3,4-Tetrahydro-5- Methylnaphthalene (3) 1,2,3,4-Tetrahydro-6- Methylnaphthalene (4) 1,2,3,4- Tetrahydronaphthalene (5) 1,2,4-Trimethylbenzene (6) 1,3,5-Trimethylbenzene (7) 1,3-Methylnaphthalene (8) 1,7-Methylnaphthalene(9) 2,3-Dihydro-4-Methyl-1HIndene (10) 2,6-dimethylnaphthalene (11) 2-Butanone (12) 2-Ethyl-1,3,5-TrimethylBenzene(13) 2-Ethyl-1,4-DimethylBenzene (14) 2-Hexanone (15) 4-Isopropyltoluene (16) 4-Methyl-2-Pentanone (17) Acetone (18) Benzene (19) Benzocycloheptatriene (20) Biphenyl (21) Chloroform (22) Dimethoxymethane (23) Ethylbenzene (24) Isopropylbenzene (25) m-,p-Xylene (sum of isomers) (26) Methyl acetate (27) Methyl tertiary butyl ether (MTBE) (28) Methylene chloride (29) n-Butylbenzene (30) n-Pentadecane (31) n-Propylbenzene (32) n-Tetradecane (33) O-Xylene (34) sec-Butylbenzene (35) Styrene (36) Toluene (37) Trichlorofluoromethane (38) Vinyl acetate 

### 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 

# VOCs 0.0001 0.0010 0.0100 0.1000 1.0000 10.0000

P o t e n t ia l H a z a r d Q u o t ie n tChapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.6.2 Outboard Propulsion Engines

For this study, EPA collected samples of di scharges from outboard propulsion engines on six vessels: four tow/salvage ve ssels and two research vessels (see Table 3.6.1 above). It is important to note that all six of these vessels we re confirmed by the vesse l owners/operators to be manufactured for pleasure. Vessels manufactured for pleasure are defined as recreational vessels under P.L. 110-288 and are not study vessel s. Nonetheless, EPA has included the results here assuming they are representative of vesse ls with outboard propulsi on engines, some of which may be study vessels. EPA also collected these results so that the Agency could later compare results between study vessels and recreational vessels if appropriate.

The Outboard Engine of a Tow and Salvage Vessel

3.2.6.2.1 Classical Pollutants

Outboard propulsion engine effluent samples were analyzed for 11 classical pollutants. Table 3.6.8 presents analytical resu lts for the eight classical polluta nts that were de tected in one

290Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 291 or more engine effluent samples. The dete cted results are also shown in Figure 3.6.10. EPA analyzed the sample results to determine whic h pollutants concentrations were contributed primarily by engine operations and which we re contributed primarily by background ambient concentrations (see footnotes on table and figure). The remainder of this subsection discusses those pollutants found to be contribu ted primarily by engine operations.

Temperature increases in engine effluent above background were less than 5°C for all vessels. Engine effluent temperatures were only slightly higher (appr oximately 1°C) when vessels were operated at higher power levels as compared to idling.

Oil and grease (measured as HEM) was not de tected in any of th e engine effluent samples. SGT-HEM was detected in only two of 16 grab samples at conc entrations significantly less than the reporting limit (sample concentratio ns of 0.86 mg/L and 0.94 mg/L, compared to reporting limit of 10 mg/L).Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.8. Results of Outboard Propulsion Engine Sample Analyses for Classical Pollutants1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.Conductivity3mS/cm55100167177.37.39.2222525Dissolved Oxygen2mg/L551006.26.35.75.75.96.46.46.4pH2SU661007.47.37.07.07.17.77.97.9Salinity3ppt5510011123.93.97.3141616Silica Gel Treated HEM(SGT-HEM)mg/L62334.53.63.63.6TemperatureC661002831141425313232Total Suspended Solids(TSS)3mg/L62338.1131717Turbidity2NTU6610013106.56.58.0212525Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Sample concentrations were almost completely accounted for (≥90 percent) by background concentrations in ambient water.(3) Sample concentrations were predominantly accounted for (≥50 percent and <90 percent) by background concentrations in ambient water.292Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 293 Figure 3.6.10. Box and Dot Density Plot of Classical Pollutant Values Measured in Samples of Outboard Propulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. 

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C o n c e n t r a t io n o r A m o u n tChapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 294 3.2.6.2.2 Metals

Outboard propulsion engine effluent sample s were analyzed for dissolved and total
concentrations of 22 metals. Tabl e 3.6.9 presents analytical results for the 14 metals that were detected in one or more engine effluent samples. The detected results are also shown in Figures 3.6.11 and 3.6.12 for dissolved and total metals, respectively. Figures 3.6.13 and 3.6.14 display the distribution of PHQs based on the screening benchmark for each of the dissolved and total metals. EPA analyzed the sample results to determine which metals were contributed primarily by engine operations and which were c ontributed primarily by background ambient concentrations (see footnotes on table and figures ). The remainder of this subsection discusses
those metals found to be contributed primarily by engine operations.

Dissolved and total concentrations for bot h vanadium and zinc are similar, which indicates that engine operations contribute these metals in dissolve d rather that particulate form. Dissolved zinc was detected in all engine effluent samples at concentrations two to five times the reporting limit; none of the concentrations exceed the PHQ screening benchmark (a value of 81

μ g/L based on the chronic saltwater criterion for aquatic life). Dissolved vanadium was detected in engine effluent from four of the six sample d vessels at concentratio ns close to the reporting limit (<2 times reporting limit of 1 μ g/L). Dissolved vanadium does not have an NRWQC or other PHQ screening benchmark.

Total arsenic was detected in engine effluent from five of the si x sampled vessels at
concentrations two to five times the reporting limit (reporting limit = 8 μ g/L), however, EPA suspects the measured concentrations of total (a nd dissolved) arsenic are elevated due to positive interference. Likewise, dissolved selenium was detected in a ll engine effluent samples at concentrations ranging from 2.4 to 100 μ g/L; however, EPA suspects the measured concentrations of dissolved (and total) selenium are elevated due to positive interference.

Finally, concentrations in engine effluent discharges for dissolved copper, total aluminum, total iron, and total manganese that ex ceed benchmark concentrations appear to be caused by background concentrations in ambient water and not by engine operations.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.9. Results of Outboard Propulsion Engine Sample Analyses for Metals1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.Heavy and Other MetalsAluminum, Dissolved2μg/L65837.48.25.19.71010Aluminum, Total2μg/L6610016058343438320570570Arsenic, Dissolved3,4μg/L658325328.6374141Arsenic, Total3,4μg/L658324309.9344141Barium, Dissolved2μg/L661002515131314415757Barium, Total2μg/L661002716141414436565Copper, Dissolved3μg/L661003.33.42.82.83.13.53.53.5Copper, Total3μg/L65833.63.42.43.83.93.9Iron, Total3μg/L6233200460560560Manganese, Dissolved2μg/L661006.05.41.01.01.2101818Manganese, Total3μg/L66100573529292991140140Nickel, Dissolved3μg/L661005.66.63.23.23.67.17.47.4Nickel, Total3μg/L66100117.73.33.35.6143333Selenium, Dissolved3,4μg/L6610076972.42.424110130130Selenium, Total3,4μg/L6610072941.51.522100120120Vanadium,Dissolvedμg/L62330.871.51.81.8Vanadium,Totalμg/L63501.71.21.41.51.5Zinc, Dissolved3μg/L6610011113.53.57.1141919Zinc, Totalμg/L66100118.33.53.56.4142828Cationic MetalsCalcium, Dissolved3μg/L66100130000160000430004300050000170000200000200000Calcium, Total3μg/L66100130000160000430004300051000170000190000190000Magnesium, Dissolved3μg/L661003800004800003100031000120000520000630000630000295Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment296Table 3.6.9. Results of Outboard Propulsion Engine Sample Analyses for Metals1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.Magnesium, Total3μg/L661003700004800003100031000120000520000600000600000Potassium, Dissolved3μg/L66100130000160000110001100048000190000220000220000Potassium, Total3μg/L66100130000160000110001100048000180000210000210000Sodium, Dissolved3μg/L66100290000038000002200002200001000000410000047000004700000Sodium,Total3μg/L66100290000037000002200002200001100000400000047000004700000Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Sample concentrations were almost completely accounted for (≥90 percent) by background concentrations in ambient water.(3) Sample concentrations were predominantly accounted for (≥50 percent and <90 percent) by background concentrations in ambient water.(4) Measured concentrations well above theirrespective reporting limits, are suspected of being elevated due to positive interference (See section3.1.3).Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 297 Figure 3.6.11. Box and Dot Density Plot of Diss olved Metals Concentrations Measured in Samples of Outboard Propulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Measured concentrations well above their respective reporting limits for dissolved arsenic and selenium are suspected of being elevated due to positive interference). 

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## 298 Figure 3.6.12. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Outboard Propulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Measured concentrations well above their respec tive reporting limits for total arsenic and selenium are suspected of being elevated due to positive interference). 

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## 299 Figure 3.6.13. Box and Dot Density Plot of Pote ntial Hazard Quotient s for Dissolved Metals in Samples of Outboard Propulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Replacement values for non-detects are circled. Al so, measured concentrations well above their respective reporting limits for dissolved arsenic and selenium are su spected of being elevated due to positive interference). 

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## 300 Figure 3.6.14. Box and Dot Density Plot of Pote ntial Hazard Quotient s for Total Metals in Samples of Outboard Propulsion Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Replacement values for non-detects are circled. Al so, measured concentrations well above their respective reporting limits for total arsenic and selenium are susp ected of being elevated due to positive interference). 

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## 301 3.2.6.2.3 Semivolatile Organic Compounds

Outboard propulsion engine effluent sample s were analyzed for 62 SVOCs. Table 3.6.10 presents analytical results for the seven SVOCs that were detected in one or more engine effluent samples. The detected results are also shown in Figure 3.6.15. EPA analyzed the sample results to determine which SVOCs were contributed primarily by engine operations and which were contributed primarily by background ambient con centrations. All were f ound to be contributed primarily by engine operations.

The detected SVOCs can be classified among the following pollutant classes: polycyclic aromatic hydrocarbons (PAHs) (one analyte), ph enol and methyl phenols (four analytes), phthalates (one analyte), and methylnaphthalenes (one analyte). All of these SVOCs were frequently detected in engine effluent (i.e., more than half of the sampled vessels). However, all
of the detected SVOC concentrations are well below any applicable P HQ screening benchmarks. For example, the maximum PHQ for any of the detected SVOCs was 2,4-dimethylphenol with a PHQ of approximately 0.005. Therefore, SVOCs in e ngine effluent are high ly unlikely to have the potential to pose risk to human health or the environment.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.10. Results of Outboard PropulsionEngine Sample Analyses for SVOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.2,4-Dimethylphenolμg/L61172.50.492.02.02-Methylnaphthaleneμg/L62332.41.52.82.8Di-n-butyl phthalateμg/L63502.41.22.33.53.5m-Cresolμg/L62332.61.94.24.2Naphthaleneμg/L65837.82.01.4123535p-Cresolμg/L62333.73.99.89.8Phenolμg/L62334.65.91414Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.302Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 303 Figure 3.6.15. Box and Dot Density Plot of SVOC Concentrations Measured in Samples of Outboard Propulsion Engine Effluent (Note: two analyte names were truncated: 2-Methylnaphalene and Di-n-butyl phthalate). 

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## 3.2.6.2.4 Volatile Organic Compounds

Outboard propulsion engine effluent sample s we re analyzed for 70 VOCs. Table 3.6.11 presents analytical results for the 18 VOCs that we re detected in one or more engine effluent samples. The detected results are also shown in Figures 3.6.16 and 3.6.17 for analyte concentrations and for PHQs based on the lowe st NRWQC or other P HQ screening benchmark where applicable, respectively. EPA analyzed the sample results to determine which VOCs were contributed primarily by engine operations and which were co ntributed primarily by background
ambient concentrations. All were found to be co ntributed primarily by engine operations. Some of these compounds are volatile constituents of fu el, specifically benzene, toluene, ethylbenzene, and xylene. Others are trimethylbenzenes, which are naturally present in fuel, and one is a ketone, which may be formed as a product of incomplete combustion. Among these compounds, benzene, ethylbenzene, and toluene have an NRWQC. Most of the detected benzene
concentrations exceeded the P HQ screening benchmark of 2.2 μ g/L (human heath for consumption of water and aquatic organisms), including discharges from the two research vessels that exceed the benchmark by factors of fi ve and 28. None of the detected ethylbenzene
and toluene concentrations exceeded the PHQ screening benchmarks.

The final one-third of the detected VOCs we re detected relatively infrequently (i.e., detected in fewer than half the sampled vessels). Among these compounds, only methylene chloride has an NRWQC. However, none of the detected methylene chlorine concentrations exceeded the screening benchmark.

304Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.11. Results of Outboard PropulsionEngine Sample Analyses for VOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.2MedianConc.MinimumConc.10%25%75%90%MaximumConc.21,2,4-Trimethylbenzeneμg/L66100132.30.300.300.532463631,3,5-Trimethylbenzeneμg/L65834.61.90.756.518182-Butanoneμg/L62333.83.812122-Hexanoneμg/L61172.50.562.32.34-Methyl-2-Pentanoneμg/L61172.30.351.41.4Acetoneμg/L65837.82.51.4113434Benzeneμg/L66100132.40.130.130.76246262Cyclohexaneμg/L61172.40.411.71.7Ethylbenzeneμg/L661008.22.10.900.900.92143838Isopropylbenzeneμg/L62332.41.33.83.8m-,p-Xylene (sum ofisomers)μg/L66100283.40.330.330.4352140140Methyl tertiary butyl ether(MTBE)μg/L61172.30.341.41.4Methylcyclohexaneμg/L61172.30.361.51.5Methylene chlorideμg/L65830.580.200.150.200.200.20n-Propylbenzeneμg/L64673.21.73.69.49.4O-Xyleneμg/L66100154.00.170.170.43267070Styreneμg/L65834.93.40.226.61616Tolueneμg/L66100523.80.400.400.7598260260Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) In some cases, the detected concentration(s) for an analytecould be lower than the replacement value (1⁄2 of the reporting limit) for a concentration that was nondetected. In anextreme (but possible) case, this couldresult in an average concentration for an analyte that is greater than the maximum detected concentration.305Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 306 Figure 3.6.16. Box and Dot Density Plot of Vo latile Organic Compounds Concentrations Measured in Samples of Outboard Propulsion Engine Effluent
VOCs are identified as follows: (1) 1,2,4-Trimethylbenzene (2) 1,3,5-Trimethylbenzene (3) 2-Butanone (4) 2-Hexanone (5) 4-Methyl-2-Pentanone (6) Acetone (7) Benzene (8) Cyclohexane (9) Ethylbenzene (10) Isopropylbenzene (11) m-,p-Xylene (sum of isomers) (12) Methyl tertiary butyl ether (MTBE) (13) Methylcyclohexane (14) Methylene chloride (15) n-Propylbenzene (16) O-Xylene (17) Styrene (18) Toluene 

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C o n c e n t r a t io n ( u g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 307 Figure 3.6.17. Box and Dot Density Plot of Potential Hazard Quotients for Volatile Organic Compounds in Samples of Outboa rd Propulsion Engine Effluent VOCs are identified as follows (replacemen t values for non-detects are circled): (1) 1,2,4-Trimethylbenzene (2) 1,3,5-Trimethylbenzene (3) 2-Butanone (4) 2-Hexanone (5) 4-Methyl-2-Pentanone (6) Acetone (7) Benzene (8) Cyclohexane (9) Ethylbenzene (10) Isopropylbenzene (11) m-,p-Xylene (sum of isomers) (12) Methyl tertiary butyl ether (MTBE) (13) Methylcyclohexane (14) Methylene chloride (15) n-Propylbenzene (16) O-Xylene (17) Styrene (18) Toluene 

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# 1.000Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.6.3 Generator Engines

For this s tudy, EPA collected cooling water discharge samples from engines on generator sets onboard five vessels: a fishing vessel, a fire boat, two tour boats, an d a water taxi (Table 3.6.1). These engines included both di rect and indirect cooling di scharges from both gasolineand diesel-fueled engines.

The Generator on a Fire Boat

3.2.6.3.1 Classical Pollutants

Table 3.6.12 presents analytical results for 11 classical polluta nts detected in samples of discharges from generator engines (all classica l pollutants analyzed for were detected). The
detected results are also show n in Figure 3.6.18. EPA analyzed the sample results to determine which pollutant concentrations were contributed primarily by generator engine operations and which were contributed primarily by background ambient concentr ations (see footnotes on table and figure). The remainder of this subsection di scusses those classical pollutants found to be contributed primarily by ge nerator engine operations.

Temperature increases in generator e ngine effluent above background were approximately 5°C for the fishing vessel, fire boat, and water taxi. For the two tour boats, temperature increases were 9 and 13°C.

308Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 309 Oil and grease (measured as HEM) was detected in engine effluent fr om three of the five sampled generators; however, detected concentrations were low, ranging from less than the reporting limit to just above the reporting limit (reporting limit = 5 mg/L). All sample results were well below the 33 CFR Part 151.10 prohibition of the discharge of oil and oily mixtures with an oil content greater than 15 ppm into seawater from vessels.

Sulfide was detected in only one of five samples at a concentration of 0.012 mg/L, which is slightly above the reporting limit of 0.01 mg/L. This concentrati on is six times greater than the most conservative PHQ screening benchmark

– 

## a 2006 NRWQC value of 0.002 mg/L for the protection of aquatic life. Sulfide could be presen t due to entrainment in fuel, as a product of incomplete combustion, or due to formation within the biofilm in the cooling system piping.

TRC was detected in only one generator engine effluent sample collected from a water taxi at a concentration of 0.15 mg/L. This detect ed concentration is 20 times greater than the PHQ screening benchmark of 0.0075 mg/L. There is no known source of TRC for this vessel as background concentration of the ambient water at this location was be low detection and the generator did not use service water that might contain TRC.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.12. Results of Generator Engine Sample Analyses for Classical Pollutants1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.4MedianConc.MinimumConc.10%25%75%90%MaximumConc.4Conductivity2mS/cm44100110.310.230.230.23324343Dissolved Oxygen2mg/L441005.36.21.91.92.67.78.28.2Hexane ExtractableMaterial (HEM)mg/L53602.91.14.35.85.8pH2SU551006.56.65.75. 75.97.07.07.0Salinity3ppt441006.50.200.100.100.10192525Silica Gel Treated HEM(SGT-HEM)mg/L51204.20.551.11.1Sulfidemg/L41250.00680.00900.0120.012TemperatureC551002120181819242626Total Residual Chlorinemg/L51200.0600.0750.150.15Total Suspended Solids(TSS)3mg/L43759.0122.1131313Turbidity2NTU5510027331.31.314383939Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Sample concentrations were almost completely accounted for (≥90 percent) by background concentrations in ambient water.(3) Sample concentrations were predominantly accounted for (≥50 percent and <90 percent) by background concentrations in ambient water.(4) In some cases, the detected concentration(s) for an analytecould be lower than the replacement value (1⁄2 of the reporting limit) for a concentration that was nondetected. In anextreme (but possible) case, this couldresult in an average concentration for an analyte that is greater than the maximum detected concentration.310Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 311 Figure 3.6.18. Box and Dot Density Plot of Classical Pollutant Values Measured in Samples of Generator Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. 

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## 312 3.2.6.3.2 Metals

Generator engine effluent samples were anal yzed for dissolved and total concentrations of 22 metals. Table 3.6.13 presents analytical results for the 11 me tals that were detected. The detected results are also shown in Figures 3.6.19 and 3.6.20 for dissolved and total metals, respectively. Figures 3.6.21 and 3.6.22 display the distribution of PHQs based on the screening
benchmark for each of the dissolved and total metals. EPA analyzed the sample results to determine which metals were contributed primar ily by generator engine operations and which were contributed primarily by background ambien t concentrations (see footnotes on table and figures). The remainder of this subsection di scusses those metals found to be contributed primarily by generator engine operations.

Dissolved and total metals concentrations are similar, which indicates that engine operations contribute metals in dissolved rath er that particulate form. Dissolved copper was detected in all five generator effluent sa mples at concentrations ranging from 2.4 to 13 μ g/L. Total copper was detected in two of the fi ve samples at concentrations of 2.4 and 11 μ g/L (reporting limit = 5 μ g/L). Dissolved copper concentra tions exceeded the PHQ screening
benchmark of 3.1 μ g/L (2006 NRWQC saltwater chronic aqua tic life criterion) by as much as five times. In contrast, none of the total c opper concentrations exceeded the PHQ screening benchmark of 1,300 μ g/L (human health criterion based on consumption of water and aquatic organisms).

Dissolved manganese was detected in four of the five generator engine effluent samples. Manganese was predominantly in particulate form in background ambient water; therefore, dissolved manganese concentrations in engine e ffluent samples are assumed to be contributed by engine operations. NRWQCs or other PHQ screeni ng benchmarks have not been determined for dissolved manganese.

Dissolved zinc was detected in two of the five generator engine effluent samples.
Detected concentrations were 21 to 29 μ g/L, which are substantially lower than the screening
benchmark of 81 μ g/L (2006 NRWQC saltwater chr onic aquatic lif e criterion).

Finally, concentrations in generator engine effluent discharges that exceed benchmark
concentrations for total aluminum are likel y caused or heavily influenced by higher concentrations in ambient water (which exceeded benchmark concentrations).Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.13. Results of Generator Engine Sample Analyses for Metals1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.4MedianConc.MinimumConc.10%25%75%90%MaximumConc.4Heavy and Other MetalsAluminum, Dissolved2μg/L55100280160111186540870870Aluminum, Total2μg/L55100420390120120220640890890Barium, Dissolved2μg/L1110037Barium, Total2μg/L1110037Copper, Dissolvedμg/L551006.55.62.42.43.99.51313Copper,Totalμg/L52404.26.71111Iron, Total2μg/L11100200Manganese, Dissolvedμg/L5480333616495353Manganese, Total3μg/L5480404317596363Nickel, Dissolved3μg/L51204.51.42.72.7Nickel, Total3μg/L51203.51.42.72.7Zinc,Dissolvedμg/L524013252929Zinc, Total3μg/L53601112151919Cationic MetalsCalcium, Dissolved2μg/L551008000026000230002300024000160000290000290000Calcium, Total2μg/L551008200028000270002700027000160000290000290000Magnesium, Dissolved2μg/L551001800005900520052005200440000870000870000Magnesium, Total2μg/L551001800006600590059005950450000890000890000Potassium, Dissolved2μg/L111004000Potassium, Total2μg/L111003600Sodium, Dissolved2μg/L1110037000Sodium,Total2μg/L1110036000Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Sample concentrations were almost completely accounted for (≥90 percent) by background concentrations in ambient water.(3) Sample concentrations were predominantly accounted for (≥50 percent and <90 percent) by background concentrations in ambient water.(4) In some cases, the detected concentration(s) for an analytecould be lower than the replacement value (1⁄2 of the reporting limit) for a concentration that was nondetected. In anextreme (but possible) case, this couldresult in an average concentration for an analyte that is greater than the maximum detected concentration.313Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 314 Figure 3.6.19. Box and Dot Density Plot of Diss olved Metals Concentrations Measured in Samples of Generator Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. 

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# 100Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 315 Figure 3.6.20. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Generator Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. 

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# 100Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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## Figure 3.6.21. Box and Dot Density Plot of Pote ntial Hazard Quotient s for Dissolved Metals in Samples of Genera tor Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Replacement values for non-detects are circled).



## 316Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



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## Figure 3.6.22. Box and Dot Density Plot of Pote ntial Hazard Quotient s for Total Metals in Samples of Generator Engine Effluent * Sample concentrations were al most completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. ** Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (Note: Replacement values for non-detects are circled).



## 317Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.6.3.3 Semivolatile Organic Compounds

Generator engine effluent samples were analyzed for 79 SVOCs. Tabl e 3.6.14 presents analytical results for the 26 SVOC s that were detected in one or more engine effluent samples (14 of the detected SVOCs were analyzed for and detected in only one generator effluent sample). The detected results are shown in Figures 3.6.23 and 3.6.24 for analyte concentrations and PHQs based on the lowest applicable NR WQC or other PHQ screening benchmark. EPA analyzed the sample results to determine which SVOCs were contributed primarily by generator engine operations and which we re contributed primarily by b ackground ambient concentrations. All were found to be contributed prim arily by generator engine operations.

Many of the detected SVOCs can be classified among the following pollutant classes: PAHs (five analytes), straight-chain hydrocarbon s (six analytes), phenol and methyl phenols (five analytes), and phthalates (two analytes). These include all of the SVOCs analyzed for and detected most frequently and at the highest concentrations.

PAHs are present in fuels in small amounts a nd may be formed as products of incomplete combustion. However, none of the detected PAH concentrations exceeded the screening benchmarks for these analytes, indicating that they are unlikely to have th e potential to pose risk
to human health or the environment.

Straight-chain (alkane) hydrocarbons are also components of fuel. None of these analytes has an NRWQC or other PHQ screening benchmark, and they are not PBT chemicals. Therefore, the straight-chain hydrocarbons dete cted in engine effluent are unl ikely to have the potential to pose risk to human health or the environment.

Phenol and methyl phenols are also present in petroleum products and may also be generated as products of incomplete combustion. Discharges of phenol a nd methyl phenols are assumed not to result in any environmental impacts as detected concentrati ons did not exceed the screening benchmarks for these analytes.

Phthalates are plasticizers (chemicals added to plastics to make them flexible) and are commonly detected in environmental samples (A TSDR, 2002). Bis(2-ethylhexyl) phthalate was detected at concentration just a bove the screening benchmark of 1.2 μ g/L (human heath for consumption of water and aquatic organisms).

The generator engine effluent sample fr om the fire boat contained the maximum
concentration of 12 of the detected SVOCs. These include all five of the detected PAHs, four of the five detected phenols and methyl phenols, an d both of the detected phthalates. The generator effluent sample from a tour boa t contained the maximum concentra tion of all six of the detected straight-chain hydrocarbons.

318Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.14. Results of Generator Engine Sample Analyses for SVOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.2MedianConc.MinimumConc.10%25%75%90%MaximumConc.21-methylnaphthaleneμg/L331006.75.43.83.83.81111112,4-Dimethylphenolμg/L51202.64.07.97.92-Cyclopenten1-oneμg/L221008.5133.93.93.91313132-Hydroxy-Benzaldehydeμg/L2210011174.34.34.31717172-Methylnaphthaleneμg/L4410016104.64.65.53240402-Naphthaleneμg/L2210018201616162020203-Methyl-Benzaldehydeμg/L11100183-Methylphenolμg/L11100123-Phenyl-2-Propenalμg/L111008.1Acenaphthyleneμg/L51201.81.93.83.8Acetophenoneμg/L1110011Bis(2-ethylhexyl)phthalateμg/L51201.30.631.31.3Di-n-butylphthalateμg/L51201.30.591.21.2Eicosaneμg/L1110032Fluoreneμg/L51202.02.44.94.9Heneicosaneμg/L1110022Heptadecaneμg/L33100308.94.14.14.1767676m-Cresolμg/L1110018Naphthaleneμg/L5480177.32.3366161n-Hexadecaneμg/L1110046Nonadecaneμg/L1110040Octadecaneμg/L1110044p-Cresolμg/L1110043319Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment320Table 3.6.14. Results of Generator Engine Sample Analyses for SVOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.2MedianConc.MinimumConc.10%25%75%90%MaximumConc.2Phenanthreneμg/L53603.93.26.89.79.7Phenolμg/L548023132.1487575Pyreneμg/L51201.40.901.81.8Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) In some cases, the detected concentration(s) for an analytecould be lower than the replacement value (1⁄2 of the reporting limit) for a concentration that was nondetected. In anextreme (but possible) case, this couldresult in an average concentration for an analyte that is greater than the maximum detected concentration.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 321 Figure 3.6.23. Box and Dot Density Plot of SVOC Concentrations Measured in Samples of Generator Engine Effluent
SVOCs are identified as follows: (1) 1-methylnaphthalene (2) 2,4-Dimethylphenol (3) 2-Cyclopenten1-one (4) 2-Hydroxy-Benzaldehyde (5) 2-Methylnaphthalene (6) 2- Naphthalenecarboxaldehyde (7) 3-Methyl-Benzaldehyde (8) 3-Methylphenol (9) 3-Phenyl-2-Propenal (10) Acenaphthylene (11) Acetophenone (12) Bis(2-ethylhexyl) phthalate (13) Di-n-butyl phthalate (14) Eicosane (15) Fluorene (16) Heneicosane (17) Heptadecane (18) m-Cresol (19) Naphthalene (20) n-Hexadecane (21) Nonadecane (22) Octadecane (23) p-Cresol (24) Phenanthrene (25) Phenol (26) Pyrene 

# 0 2 4 6 8 10 12 14 16 18 20 22 24 26 

# SVOCs 20 40 60 80

C o n c e n t r a t io n ( u g / L )Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 322 Figure 3.6.24. Box and Dot Density Plot of Po tential Hazard Quotients for SVOCs in Samples of Generator Engine Effluent SVOCs are identified as follows (replacemen t values for non-detects are circled): (1) 1-methylnaphthalene (2) 2,4-Dimethylphenol (3) 2-Cyclopenten1-one (4) 2-Hydroxy-Benzaldehyde (5) 2-Methylnaphthalene(6) 2-Naphthalenecarboxaldehyde (7) 3-Methyl-Benzaldehyde (8) 3-Methylphenol (9) 3-Phenyl-2-Propenal (10) Acenaphthylene (11) Acetophenone (12) Bis(2-ethylhexyl) phthalate (13) Di-n-butyl phthalate (14) Eicosane (15) Fluorene (16) Heneicosane (17) Heptadecane (18) m-Cresol (19) Naphthalene (20) n-Hexadecane (21) Nonadecane (22) Octadecane (23) p-Cresol (24) Phenanthrene (25) Phenol (26) Pyrene 

# 0 2 4 6 8 10 12 14 16 18 20 22 24 26 

# SVOCs 0.0001 0.0010 0.0100 0.1000 1.0000

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## 3.2.6.3.4 Volatile Organic Compounds

Generator engine effluent samples were analyzed for 80 VOCs. Table 3.6.15 presents analytica l results for the 28 VOCs that were detected. The detected results are also shown in Figures 3.6.25 and 3.6.26 for analyte concentrations and for PHQs based on the lowest NRWQC or other PHQ screening benchmark, where appli cable, respectively. EPA analyzed the sample
results to determine which VOCs were contributed primarily by generator engine operations and which were contributed primarily by background ambient concentr ations. All were found to be contributed primarily by ge nerator engine operations.

Twenty-two of the detected VOCs were analy zed for in only one sample. None of these compounds has an NRWQC or are PBT chemicals. Of the seven detected VOCs that were analyzed for in more than one sample, three have an NRWQC: benzen e, ethylbenzene, and
toluene. All of the detected ben zene concentrations (from three of the five samples) exceeded the PHQ screening benchmark of 2.2 μ g/L by factors ranging from one to nine. The single detected concentration for each of ethylenebenzene and toluene did not exceed their respective PHQ screening benchmarks.

Note that the generator effluent sample from the fire boat contained the maximum
concentration of 19 of the detected VOCs. These include benzene, toluene, ethylbenzene, xylene, trimethylbenzenes, and ketones.

323Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.15. Results of Generator Engine Sample Analyses for VOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.(E)-2-Butenalμg/L11100121,2,3,4-Tetrahydro-5-Methylnaphthaleneμg/L111005.91,2,3,4-Tetrahydro-6-Methylnaphthaleneμg/L111007.21,2,4-Trimethylbenzeneμg/L111008.01,3,5-Trimethylbenzeneμg/L111001.62,6-Dimethylμg/L111005.52-Butanoneμg/L11100832-Butenalμg/L11100192-Ethyl-1,4-DimethylBenzeneμg/L111005.74-Isopropyltolueneμg/L111000.404-Methyl-2-Pentanoneμg/L111001.7Acetoneμg/L22100120220222222220220220Benzaldehydeμg/L111004.2Benzeneμg/L53605.93.1122121Benzofuranμg/L111006.9Biphenylμg/L1110012Ethylbenzeneμg/L51201.41.02.02.0Isopropylbenzeneμg/L111000.50m-,p-Xylene (sum ofisomers)μg/L111005.3Methyl acetateμg/L111000.80n-Pentadecaneμg/L1110040n-Propylbenzeneμg/L111000.90n-Tetradecaneμg/L1110020O-Xyleneμg/L111003.4sec-Butylbenzeneμg/L111000.50324Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment325Table 3.6.15. Results of Generator Engine Sample Analyses for VOCs1AnalyteUnitsNo.SamplesNo.DetectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.Styreneμg/L111008.9Tolueneμg/L51203.56.21212Vinylacetateμg/L111001.5Notes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 326 Figure 3.6.25. Box and Dot Density Plot of VO C Concentrations Measured in Samples of Generator Engine Effluent
VOCs are identified as follows: (1) (E)-2-Butenal (2) 1,2,3,4-Tetrahydro-5- Methylnaphthalene (3) 1,2,3,4-Tetrahydro-6- Methylnaphthalene (4) 1,2,4-Trimethylbenzene (5) 1,3,5-Trimethylbenzene (6) 2,6-dimethylnaphthalene (7) 2-Butanone (8) 2-Butenal (9) 2-Ethyl-1,4-DimethylBenzene (10) 4-Isopropyltoluene (11) 4-Methyl-2-Pentanone (12) Acetone (13) Benzaldehyde (14) Benzene (15) Benzofuran (16) Biphenyl (17) Ethylbenzene (18) Isopropylbenzene (19) m-,p-Xylene (sum of isomers) (20) Methyl acetate (21) n-Pentadecane (22) n-Propylbenzene (23) n-Tetradecane (24) o-Xylene (25) sec-Butylbenzene (26) Styrene (27) Toluene (28) Vinyl acetate 

# 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 

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# 10.00

327 Figure 3.6.26. Box and Dot Density Plot of Po tential Hazard Quotients for VOCs in Samples of Generator Engine Effluent VOCs are identified as follows (replacemen t values for non-detects are circled): (1) (E)-2-Butenal (2) 1,2,3,4-Tetrahydro-5- Methylnaphthalene (3) 1,2,3,4-Tetrahydro-6- Methylnaphthalene (4) 1,2,4-Trimethylbenzene (5) 1,3,5-Trimethylbenzene (6) 2,6-dimethylnaphthalene (7) 2-Butanone (8) 2-Butenal (9) 2-Ethyl-1,4-DimethylBenzene (10) 4-Isopropyltoluene (11) 4-Methyl-2-Pentanone (12) Acetone (13) Benzaldehyde (14) Benzene (15) Benzofuran (16) Biphenyl (17) Ethylbenzene (18) Isopropylbenzene (19) m-,p-Xylene (sum of isomers) (20) Methyl acetate (21) n-Pentadecane (22) n-Propylbenzene (23) n-Tetradecane (25) sec-Butylbenzene (26) Styrene (27) Toluene (28) Vinyl acetate 

# 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 

# VOCs 0.00 0.01 0.10 1.00

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## 3.2.6.4 Comparison of Effluent Generated at Different Propulsion Engine Power Levels

Although inboard and outboard propulsion en gines were often sampled during operation at different power levels (e.g., idle, half power, full power), these samples were generally composited for a single analysis. Exceptions in clude samples for analysis of HEM/SGT-HEM and VOCs, which were collected and analyzed separately for each power level of engine operation (composite samples for these analytes are not appropriate). EPA reviewed the
HEM/SGT-HEM and VOC data to determine whether there were any trends in the resulting data based on engine power level of operation.

HEM was detected in the majority of inboard engine effluent samples; however, detected concentrations were low (the majority were less than the reporting limit of 5 mg/L). Of the eight vessels with inboard engines with detected HEM concentrations that were sampled at different power levels, engine effluent samples from six had higher HEM concentrations at higher engine levels than at idle. Data for the remaining tw o vessels were inconclusi ve. Note, however, that differences in HEM concentrations among power le vels were small, ranging from 0.1 to 5 mg/L. For outboard engines, HEM was not detected in any of the engine effluent samples.

Regarding VOC results for inboard engine s, EPA reviewed benzene, toluene, ethylbenzene, and xylene concentr ations as these compounds were the most frequently detected. Of the eight vessels with inboard engines with detected benzene concentrations that were sampled at different power levels, engine efflue nt samples from five contained higher benzene concentrations at higher engine levels than at idle. Data for th e remaining three vessels showed the opposite pattern, with higher benz ene concentrations at idle than at higher engine levels. For seven of these sampled vessels, differences in benzene concentrations among the power levels were small, ranging from 0.1 to 4.7 μ g/L. In contrast, for the remaining vessel (a recreational vessel), the difference in benzene concentratio ns from idle to three-quarter speed was 89 μ g/L, with the higher concentration detected at idle. As discussed previously, this recreational vessel was the only sampled vessel that used gasoline as fu el rather than diesel. In addition, the engines on this vessel were dewinterized immediately prior to sampling.

The differential among detected concentrations of ethylbenzene, xyl ene, and toluene at different power levels is too sm all to draw any conclusions, excep t for the engine effluent data
for the recreational vessel. Differences in detected concentrations between idle and three-quarter power were 18 μ g/L for ethylbenzene, 73 μ g/L for m-,p-xylene, 31 μ g/L for o-xylene, and 84

μ g/L for toluene. The higher concentrations were found at idle for all four analytes.

The UNDS sampling program provides a useful comparison for this study as it was specifically designed to evalua te engine wet exhaust charact eristics among power levels, including the separate collection and analysis of three replicate samples at each of five different

328Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 329 power levels. Tables 3.6.16 a nd 3.6.17 present sample results from the UNDS study by power
level for the LCPL a nd RIB, respectively.

EPA made several conclusions for the LCPL based on a review of the engine effluent results. Chromium, copper, lead, and nickel were all detected at con centrations significantly greater than background concentr ations for all five power le vels. For copper and nickel, concentrations were highest at idle, second hi ghest at 100 percent power, and then generally decreased with decreasing power levels (decre asing engine RPM). Chromium concentrations were highest at 100 percent power and then also decreased with decreas ing power levels, with
the lowest chromium concentrations found at id le. Lead concentrations were not significantly different at the various power levels. For TOC and phenol, only idle concentrations were significantly greater than background concentrations.

For the RIB, only TOC concentrations we re significantly greater than background concentrations for all five power levels. TOC c oncentrations were highest at 100 power and then generally decreased with decrea sing power levels; TOC concentra tions were lowest at idle.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.16. Mean Concentration Results, UNDS Engine WetExhaust Discharge and Background Samples for the LCPL1Mode 1RPM 2050(100% Power)Mode 2RPM 1850(75% Power)Mode 3RPM 1650(50% Power)Mode 4RPM 1300(25% Power)Mode 5RPM 750(0% Power)Background WaterAnalyteMeanMeanMeanMeanMeanMeanUnitsClassical ParametersNitrate/Nitrite (NO2+ NO3-N)ND(0.010)0.0110.011ND(0.010)0.012ND(0.010)mg/LTotal Organic Carbon (TOC)1.151.030.9330.8581.730.992mg/LMetalsArsenic,Total2.221.981.922.382.212.29μg/LCadmium,Total0.0320.0280.0240.0220.0220.020μg/LChromium,Total0.5740.4310.3130.3100.260ND(0.100)μg/LCopper,Total21.726.017.213.540.10.780μg/LLead,Total0.3690.1880.1450.1180.1270.030μg/LNickel,Total4.124.793.042.8114.80.477μg/LSVOCsBis(2-ethylhexyl)phthalateND (10.0)ND (10.0)ND (10.18)ND (10.0)20.4ND (10.0)μg/LPhenolND (10.0)ND (10.0)ND (10.18)ND (10.0)19.7ND (10.0)μg/LSource: USEPA, 2008b.(1) Mean values were estimated based on the replicate concentrations for each mode orbackground sample using a lognormal or modified-delta lognormal distribution.ND – Not detected (number in parentheses is reporting limit).330Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment331Table 3.6.17. Mean Concentration Results, UNDS Engine WetExhaust Discharge and Background Samples for the RIB1Mode 1RPM 2450(100% Power)Mode 2RPM 2270(75% Power)Mode 3RPM 1720(50% Power)Mode 4RPM 1290(25% Power)Mode 5RPM 400(0% Power)BackgroundWaterAnalyteMeanMeanMeanMeanMeanMeanUnitsClassical ParametersBiochemical Oxygen Demand (BOD)ND (2.00)ND (2.00)ND (2.00)4.83.33.3mg/LNitrate/Nitrite (NO2+ NO3-N)0.017ND (0.010)0.0150.0120.013ND (0.010)mg/LTotal Organic Carbon (TOC)1.671.551.271.151.290.832mg/LTotal Suspended Solids (TSS)11.912.4ND (5.00)5.3ND (5.00)ND (5.00)mg/LSVOCsPhenol32.424.6ND (10.0)ND (10.0)ND (10.0)ND (10.0)μg/LVOCs1,2,3-Trimethylbenzene12.3ND (10.0)ND(10.0)ND (10.0)12.6ND (10.0)μg/L1,3,5-Trimethylbenzene12.3ND (10.0)ND(10.0)ND (10.0)12.6ND (10.0)μg/LSource: USEPA, 2008b.(1) Mean values were estimated based on the replicate concentrations for each mode orbackground sample using a lognormal or modified-delta lognormal distribution.ND – Not detected (number in parentheses is reporting limit).Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.6.5 Engine Dewi nterizing Effluent

Marine engines used in cold climates typi cally require maintenance prior to winter storage to prevent engine damage caused by fr eezing or corrosion. The indirect cooling systems in inboard engines are typically winterized by draining the water from the ambient water cooling system and refilling the system with approxima tely 5 gallons of antifreeze. Marine engine antifreeze contains propylene glycol 37 

## , corrosion inhibitors, and othe r additives. In spring, the 5 gallons of antifreeze is emptied by starting the en gine, which discharges the glycol solution and replaces it with ambient water. EPA sampled dewi nterizing effluent from an inboard engine on a
recreational vessel as it was converted from wint er storage. This sample was collected in the same manner as that used for sampling other en gine effluents. The sample was analyzed for select classical pollutants and metals.

Table 3.6.18 presents the collected dewinterizi ng effluent data, together with the mean inboard propulsion engine effluent concentra tions from Tables 3.6.2 and 3.6.3. The source of the biochemical oxygen demand concentrations is the propylene glycol in the antifreeze. Elevated
metals concentrations in dewint erizing effluent compared to t hose in inboard engine effluent could have been due to prolonged contact of the antifreeze with the engi ne cooling system and associated piping.

Outboard engines are winterized by spraying an oily aerosol, co mmonly referred to as “fog,” into the combustion air intake while the motor is running. Therefore, the engine dewinterizing effluent sample re sults in this subsection are not applicable to outboard engines.

37 

### Ethylene glycol is not used for marine applications due to its higher toxicity as compared to propylene glycol.



## 332Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 333 Table 3.6.18. Comparison of Dewinterizing Effluent with Propulsion Effluent

Analyte Units Dewinterizing Effluent Inboard Propulsion Engine Mean Concentration from Tables 3.6.2 and 3.6.3

Classical Parameters Biochemical Oxygen Demand (BOD) mg/L 11 Not analyzed

Total Residual Chlorine mg/L 2.8 0.048 1

Turbidity NTU 350 32 2

Metals
Aluminum, Dissolved μg/L 560 200 1

Aluminum, Total μg/L 3,700 340 1

Antimony, Dissolved μg/L 2.1 Not detected
Antimony, Total μg/L 2.4 Not detected
Arsenic, Dissolved μg/L 24 4.2 2,4

Arsenic, Total μg/L 32 4.5 2,4

Barium, Dissolved μg/L 43 35 1

Barium, Total μg/L 59 36 1

Calcium, Dissolved μg/L 21,000 80,000 1

Calcium, Total μg/L 25,000 81,000 1

Chromium, Dissolved μg/L 820 1.2
Chromium, Total μg/L 720 1.3
Cobalt, Dissolved μg/L 8.7 Not detected
Cobalt, Total μg/L 12 Not detected
Copper, Dissolved μg/L 370 16
Copper, Total μg/L 820 18
Iron, Dissolved μg/L 3,300 64
Iron, Total μg/L 20,000 250 2

Lead, Dissolved μg/L 19 1.5
Lead, Total μg/L 64 3.0
Magnesium, Dissolved μg/L 5,200 200,000 1

Magnesium, Total μg/L 6,400 200,000 1

Manganese, Dissolved μg/L 160 43
Manganese, Total μg/L 400 55 1

Nickel, Dissolved μg/L 7.2 4.4
Nickel, Total μg/L 18 4.6 1

Potassium, Dissolved μg/L 23,000 32,000 1

Potassium, Total μg/L 23,000 32,000 1

Selenium, Dissolved μg/L 45 11 1,4

Selenium, Total μg/L 54 11 2,4

Sodium, Dissolved μg/L 690,000 770,000 2

Sodium, Total μg/L 630,000 860,000 2

Vanadium, Dissolved μg/L 230 Not detected
Vanadium, Total μg/L 190 Not detected
Zinc, Dissolved μg/L 570 38

Zinc, Total μg/L 900 38 (1) Sample concentrations were almost completely accounted for ( ≥ 90 percent) by background concentrations in ambient water. (2) Sample concentrations were predominantly accounted for ( ≥ 50 percent and <90 percent) by background concentrations in ambient water. (3) Measured concentrations well above thei r respective reporting limits for dissolved arsenic and selenium are suspected of be ing elevated due to positive interferenceChapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.6.6 Summary of the Characterization of Engine Effluent Analyses

Tables 3.6.19 and 3.6.20, and Table 3.6.21 at the e nd of this subsection, compare effluent characteristics for inboard and outboard propulsion engines and generator engines. Specifically, Table 3.6.19 compares the number of analytes det ected in effluent from these engines, while Table 3.6.20 compares engine effluent analyte con centrations for those po llutants that may have the potential to lead to envir onmental impacts. Finally, Table 3.6.21 summarizes the specific analytes within each engine effluent type with th e potential to pose risk to human health or the environment. The Table 3.6.21 is presented here to help interpret a realized risk likely posed by these analytes in engine effluent as summarized in Chapter 5.

Table 3.6.19. Comparison of Number of Dete cted Analytes in Engine Effluent

Number of Analytes Detected in Engine Effluent Analyte Class Inboard Propulsion Outboard Propulsion Generator
Classical Parameters 11 11 11

Metals 16 14 11

SVOCs 31 7 26

VOCs 38 18 28

Total 96 50 76



## Table 3.6.20. Comparison of Results for Sel ected Analytes in Engine Effluent

Mean Concentration Analyte Units Inboard Propulsion Outboard Propulsion Generator

Temperature Differential °C 5 (low power levels) 20 (high power levels) <5 <5 to 13

Oil and Grease (HEM) mg/L 3.0 Not detected 2.9

Arsenic, Total μ g/L 4.5 1 24 1 Not detected
Copper, Dissolved μ g/L 16 3.3 6.5

Lead, Dissolved μ g/L 1.5 Not detected Not detected

Lead, Total μ g/L 3.0 Not detected Not detected
Selenium, Dissolved μ g/L 11 1 76 1 Not detected

Zinc, Dissolved μ g/L 38 11 13

PAHs μ g/L 14 total detected 6 carcinogens 1 detected 0 carcinogens 5 detected 0 carcinogens

Benzene μ g/L 12 13 5.9 

### (1) Measured concentrations well above their respecti ve reporting limits for dissolved arsenic and selenium are suspected of being elevated due to positive interference.



## Among all engine types, the SVOCs and VOC s were the most frequently detected pollutants (Table 3.6.19). Concentr ations of PAHs were potentially high in inboard engine effluent. Fourteen PAHs were detected, including six of the seven PAHs classified as known carcinogens (Table 3.6.20), but these were only detected in a single inboard engine effluent from a gasoline engine of a recreati onal vessel (not a study vessel) dewi nterized immediately prior to sampling. PAH concentrations in this sample were several hundred to over 1,000 times greater than their associated benchmarks. PAHs were also detected in outboard engine and generator

334Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 335 effluents, but at concentrations lower than their associated benchmarks. Furthermore, none of the probable human carcinogens were detected in gene rator or outboard propulsion engine effluent samples.

The plasticizer bis(2-ethylhexyl) phthalate was found in the effluents of all engine types, PHQs were just above 1; however, the measured c oncentrations appear to be largely reflective of
ambient concentrations. The VOC benzene was also found at concentrations above the PHQ screening benchmarks in all engine effluents. Trimethylbenzenes and ketones (VOCs) were frequently detected in the effl uents of inboard engines, but no screening benchmarks exist for these compounds. Despite the high frequency of concentrations of benzene that exceeded screening benchmarks in engine effluent of all types, rarely were PHQs in excess of 5.

Among the classical pollutants, inboard propulsion engines increase cooling water temperatures by moderate amounts (<5°C) at low pow er levels, but by as much as 20°C at higher power levels. In contrast, outboard propulsion en gines increase cooling water temperatures by <5°C, regardless of engine level. Most of the generator engi ne effluent samples increased cooling water temperature by <5°C; however, two of the generator engine effluent samples had greater temperature differentials.

Oil and grease was not detected in effluent from outboard propulsion engines, but was detected at concentrations ju st above reporting limits in effl uent from inboard propulsion and generator engines. Such con centrations were well below PHQ screening benchmarks for saltwater discharge. However, EPA did occasiona lly observe a sheen in receiving waters where marine engines were operating.

Table 3.6.21 lists those metals that were f ound to be contributed primarily by engine operations (elevated above ambient water concentr ations) and were detect ed at concentrations that exceed a NRWQC, indicating that they ma y have the potential to cause environmental impacts. After accounting for b ackground concentrations, dissolve d concentrations of copper exceeded NRWQC in most inboard engine and generator effluents. The highest PHQ for dissolved copper was 17. Severa l effluents from inboard and outboard engines had dissolved selenium at concentrations approximately two to seven times higher than NRWQC benchmarks; however, these measured concententrations are suspected of being elevated due to positive interference. Among the tota l metals, PHQs for arsenic were much greater than 1 in both inboard and outboard engines. However, as in case of dissolved selenium, all of the arsenic values measured above reporting limits are suspected of being elevated due to positive interference. Total arsenic was not detected in generator effluents.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.6.21. Characterization of Engine Effluent and Summaryof Analytes that May Have the Potential to Pose RiskAnalytes that May Have the Potential to Pose Risk in Engine Effluent Discharge and Vessel Sources1,2Vessel Type (no. vessels) Microbiologicals Volatile Organic Compounds Semivolatile Organic Compounds Metals (dissolved) Metals (total) Oil and Grease Sulfide Short-Chain Alkylphenol Ethoxylates or NP Long-Chain Alkylphenol Ethoxylates Nutrients BOD, COD, and TOC Total Suspended Solids Other Physical/Chemical ParametersInboard EnginesWater Taxis (4)BenzeneBis(2-ethylhexyl)phthalateCuTemp3Tour Boats(3)BenzeneCuTemp3Fishing Vessels (2)CuTemp3Tow/Salvage Vessel (1)CuTemp3Fire Boat (1)Bis(2-ethylhexyl)phthalateCuTemp3Recreational Vessel (2)4BenzenePAHs5CuxTemp3Outboard EnginesTow/Salvage Vessel (4)BenzeneResearch (2)Benzene336Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the Environment337Table 3.6.21. Characterization of Engine Effluent and Summaryof Analytes that May Have the Potential to Pose RiskAnalytes that May Have the Potential to Pose Risk in Engine Effluent Discharge and Vessel Sources1,2Generator Engines(5)BenzeneBis(2-ethylhexyl)phthalateCuxTemp,TRCNotes:(1) Analytes are generallyboldedwhen a large proportion of the samples have concentrations exceeding the NRWQC (e.g., 25 to 50 percent), when several of the samples havePHQs > 10 (e.g., two or three of five), when a few samplesresult in PHQs greatly exceeding the screening benchmark (i.e., 100sto 1,000s), or, in the case of oil and grease and fornonylphenol, when one or more samples exceed an existing regulatorylimit by more than a factor of 2. See text in Section3.1.3for a definition of PHQs and Table 3.1 for screeningbenchmarks used to calculate these values.(2) EPA notes that the conclusion of potential risk is drawn froma small sample size, in somecases a single vessel, for certain discharges sampled from some vessel classes. EPAincluded these results in the tables to provide a concise summary of the data collected in the study, but strongly cautions thereader that these conclusions, where there are only a fewsamples from a given vessel class, should be considered preliminary and might not necessarily represent pollutant concentrations from these discharges from other vessels in thisclass.(3) At full (100%) power.(4) For inboard engine effluent, higher measured concentrations and concentrations that exceeded the screening benchmarks wereconsistently from the recreational vessel, whichwas de-winterized immediately prior to sampling (see text). The recreational vessel was the only vessel sampled that used gasoline instead of diesel fuel. PHQs for the majority ofsamples were less than 5.(5) All PAHs detected (6 of which are probable human carcinogens) were from one sample collected from a recreational vessel with a gasoline engine dewinterized immediately priorto sampling and after a winter of non-use.Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.7 Firemain Discharges

The primary purpose of the firemain system is to supply water for fire fighting, although this system can also be used for other second ary purposes (deck washing, various maintenance and training activities, anchor chain washdown, or to create bypass flow from the firemain pumps to cool auxiliary machinery equipment) onboa rd the vessels of inte rest in this study. The firemain systems (see Section 1.5) sampled by EP A on three tour boats, two tug boats, and the single fire boat for this study are generally onl y used during emergencies and during biweekly testing. The firemain system intake water sampled on the vessels selected in this study was taken from the surrounding (ambient) water without add ition of foam-forming agents such as aqueous film-forming foam (AFFF) or other chemical additions.

The Firemain Hose on a Tour Boat

It should be noted that AFFF agents could pot entially be used on the vessels of interest in this study, although none of the vessels were outfitted with systems that used AFFF. AFFF agents are used for fire suppression and are a combination of fluoro-chemical surfactants, hydrocarbon surfactants, and solvents that are inject ed into the water stream of a fire hose. These film-forming agents can form water soluti on films on the surface of flammable liquids, separating the fuel from the air (oxygen).

EPA focused on analyzing the samples of fi remain discharge water for metals, VOCs,
and SVOCs. Metals were selected for analysis because water in the “wet type” firemain system passes through a significant amount of metal pi pe onboard most vessels. EPA initially selected

338Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## VOCs and SVOCs to characterize the AFFF, whic h, as noted, none of the vessels sampled in the study used while testing their fi remain systems. Despite the l ack of AFFF use while testing firemain systems, EPA decided to analyze for VOCs and SVOCs in firemain system discharge
water anyway.

3.2.7.1 Metals

Only half the total number of metals analyzed for in water samples from firemain systems were detected in the six vessels sampled.

Figure 3.7.1 presents the concentration ranges fo r dissolved metals detected in firemain water samples. The figure shows that dissolved metals concentrations span two orders of magnitude. Average dissolved concentrations of aluminum and zinc were highest, followed, in order of decreasing concentr ation, by barium, copper, manganese, nickel, and lead.

Figure 3.7.2 presents the concentration ranges of total metals detected in firemain water samples. Except for barium (dissolved:total metal ratio, or f d 

## , of 0.96), total metal concentrations were much higher than their co rresponding dissolved metal concentrations, particularly for lead and copper. For the other total metal concentratio ns detected at higher le vels, a disproportionate
amount of the metals in ambient water is in th e particulate form (i.e., aluminum, manganese and probably iron).

Arsenic, cadmium, selenium, antimony, berylliu m, cobalt, silver, thallium, and vanadium were not detected in the firemain discharges.

Dissolved and total aluminum and total manganese were detected in the firemain effluent of all six of the vessels sampled. These metal concentrations are mode rately to strongly influenced by ambient water concentrations. Di ssolved zinc, also moderately influenced by ambient water, was detected in five of the sa mples. Dissolved and total copper, as well as dissolved manganese, were detected in four of the samples and were generally not affected by
ambient water concentrations. Total lead was detect ed in three of the samp les, and only one of the firemain systems had dissolved lead and chro mium at detectable levels. Dissolved and total
barium and total iron were also detected in one sample from a firemain system.

Disparities between dissolved:total metal c oncentrations sampled in firemain water versus ambient water suggest chromium, lead, a nd iron detected in firemain samples at least partially originated from the network of pipes within the firemain system. The dissolved:total metal ratio for copper was lower in the firemain water samples than in the ambient water samples (f

d 

## s of 0.79), suggesting the possibility that some of the total copper detected in firemain samples originated from the network of pi pes within the vessels that suppor t the firemain system - most likely due to corrosion. Dissolved:total concentra tions in firemain samples for the remaining metals (aluminum, barium, zinc, manganese, nickel) were similar to corresponding ambient

339Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 340 dissolved:total concentr ation ratios, suggesting most of these metals detected in firemain samples originated from the ambient water. Ambi ent harbor water data are not shown.

Figures 3.7.3 and 3.7.4 display th e distribution of PHQs base d on the most conservative (most protective) screening benchmark for each of the dissolved and total metals. PHQs for only one of the dissolved metals (c opper) include a value of greater than 10 (one dissolved copper concentration from the firemain system analyzed from a tour boat resulted in a PHQ of 24). PHQs with values of slightly higher than 1 we re found for two other disso lved metals (lead and zinc) when using the most conservative (most stringent 2006 NRWQC) sc reening benchmark. In contrast, all of the concentra tions for total aluminum and th e concentrations for the single
detected total iron value exceeded the most stringent 2006 NRWQC; however, none of these PHQs exceeded 11.

In summary, the concentration of metals in firemain water was generally lower than some other discharges (e.g. bilgewater, deck washdown water). The water used in the vessel firemain systems analyzed in this study was ambient wate r, and the concentratio ns of most of the
dissolved and total metals in firemain water reflect these surrounding am bient concentrations. Aluminum, manganese, and iron had high concentra tions in the ambient water from which the firemain withdrew water and were generally high er or the same as othe r discharges. Dissolved and total copper, dissolved and total lead, and to a lesser degr ee, nickel and zinc, were found in concentrations higher than the am bient water. Of these metals, di ssolved copper is the only metal
also found at concentrations c onsistently above the most cons ervative screening benchmarks, albeit only with PHQ values in the 1 to 11 range, which is cons iderably lower than values found in most other discharge type s discussed in this report.Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.7.1. Results of Firemain System Sample Analyses for Metals1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.5MedianConc.MinimumConc.10%25%75%90%MaximumConc.5ScreeningBM2Heavy and Other MetalsAluminum, Dissolved3μg/L66100110140151572150160160NAAluminum, Total4μg/L6610033036018018020044065065087Barium, Dissolved3μg/L1110036NABarium, Total3μg/L11100371000Chromium, Total4μg/L61171.71.24.94.9NACopper, Dissolvedμg/L646723154074743.1Copper, Totalμg/L6467150702905805801300Iron, Totalμg/L111003800300Lead, Dissolvedμg/L61172.11.14.34.32.5Lead, Totalμg/L6350507.681270270NAManganese, Dissolved4μg/L64671716314747NAManganese, Total4μg/L661008698494959120120120100Nickel, Dissolved4μg/L61174.91.14.44.48.2Nickel, Total4μg/L620337.0111111610Zinc, Dissolved4μg/L6583120585.327037037081Zinc, Totalμg/L661004902802020261200160016007400Cationic MetalsCalcium, Dissolved3μg/L661002700025000230002300024000290003700037000NACalcium, Total3μg/L661003000029000230002300023000380004000040000NAMagnesium, Dissolved3μg/L6610065006500520052005700720090009000NAMagnesium, Total3μg/L6610073006600550055006200920098009800NASodium, Dissolved3μg/L1110038000NASodium,Total3μg/L1110037000NAPotassium, Dissolved3μg/L111003800NAPotassium, Total3μg/L111003600NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 ofthe reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculated when analytes weredetected at a sufficient frequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blank cell reflects a situation when a median orpercentile could not be computed based on detected concentrations. The percentiles are the concentrations of each analyte belowwhich at least that percentage of the values fall. So the 10th percentile is theconcentration below which at least10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or otherconservative benchmark used to calculate PHQs.(3) Sample concentrations were strongly influenced by backgroundconcentrations in ambient water,accounting for greater than 90% of sample concentrations in the majority of samples.(4) Sample concentrations were moderately influenced by backgroundconcentrations in ambient water, accounting for between 50 and 90% of sample concentrations in the majority of samples.(5) In some cases, the detected concentration(s) for an analytecould be lower than the replacement value (1⁄2 of the reporting limit) for a concentration that was nondetected. In an extreme (but possible) case,this could result in an average concentration for an analyte that is greater than the maximum detected concentration.341Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 342 Figure 3.7.1. Box and Dot Density Plot of Di ssolved Metals Concentrations Measured in Samples of Firemain Water 

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## 343 Figure 3.7.2. Box and Dot Density Plot of Total Metals Concentrations Measured in Samples of Firemain Water A

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## 344 Figure 3.7.3. Box and Dot Density Plot of Pote ntial Hazard Quotients for Dissolved Metals in Samples of Firemain Water (Note: Replacement values for non-detects are circled). 

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## 345 Figure 3.7.4. Box and Dot Density Plot of Pote ntial Hazard Quotients for Total Metals in Samples of Firemain Water (Note: Replacement values for non-detects are circled). 

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## 3.2.7.2 Classical pollutants

The firem ain system water samples were analyzed for 10 classical pollutants (BOD, COD, TOC, and sulfide were not analyzed for as they were not expected in firemain system discharge (see Table 2.2). Of the 10 classical pollutants analyzed for, oil and grease (measured as HEM and SGT-HEM) were not det ected in any samples (Table 3.7.2) . The concentrations of all other pollutants, with th e possible exception of turb idity, were not elevated.

The conductivity, pH, and low salinity (rangi ng from 0.01 to 0.2 parts per thousand) in the firemain water samples are consistent with freshwater ambient water (all firemain samples were taken from vessels operating in fresh water). The pH of these waters was between 7 and 8, and turbidity and TSS was low, under 90 NTU a nd 20 mg/L, respectively. The firemain system effluent was sampled in the spring, and the te mperature was in a seasonal range of 14 to 22 o 

## C and varied according to geogra phic location (warmer water samples in southern United States
and colder in mid-Atlantic and northern states ). Dissolved oxygen in firemain system water ranged from a low of 4.1 mg/L (s lightly less then 50 percent satu ration) to a high of 13 mg/L (super-saturated). All of these valu es were, to a large degree, cons istent with concentrations of these parameters found in respective ambient water.

Figure 3.7.5 illustrates the variabil ity of the values measured for the classical pollutants in firemain system water, which is relatively lo w given the relative similarities in ambient water quality (freshwater harbors sampled during spri ngtime) for the three locations where vessels were sampled. The only other parameters detected in this category were TRC and turbidity. TRC was only detected in one of the six samples collected (measured at the reporting limit = 0.10 mg/L; PHQ = 13). All of the other TRC concen trations were below the reporting limit of 0.10 mg/L, which, when reported at half the repor ting limit or 0.05 mg/L, still exceeds the most stringent 2006 NRWQC for TRC of 0.0075 mg/L. In contrast, turbid ity ranged from a low of 4.6 to a high of 89 NTU, concentrations similar to th e range of turbities (3 to 180 NTU) observed in estuaries. In contrast, turbidity in raw sewage can be several hundred NTUs or more. There is no screening benchmark for turbidity from which to assess potential to cau se or contribute to adverse effects on water quality.

To summarize, the concentrations of classical pollutants in firemain system water samples are within the normally expected range s for the given season and geographical location where vessels were sampled. It appears that th e classical pollutant concentrations primarily
reflect concentrations found in the ambient water.

346Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.7.2. Results of FiremainSystem Water Sample Analyses for Classical Pollutants1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2ConductivitymS/cm551000.320.240.230.230.240.430.470.47NADissolved Oxygenmg/L551007.76.84.14.14.9111313NApHSU661007.47.46.96.97.07.87.97.9NASalinityppt551000.120.100.0100.0100.0550.200.200.20NATemperatureC551001819141415212222NATotal Residual Chlorinemg/L61170.050.0250.100.100.0075Total Suspended Solids (TSS)mg/L111001630TurbidityNTU6610033274.64.616488989NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.347Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 348 Figure 3.7.5. Box and Dot Density Plot of Cl assical Pollutants Measured in Samples of Firemain Water (Note: Concentrations reflect ambient water concentrations and values because ambient water was used as the source of water for all fireman systems in the vessels sampled in the study program). 

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## 3.2.7.3 Volatile and Semivolat ile Organic Chemicals

VOC and SVOCs were targeted in firema in systems for this program because of the expectation that AFFF agents might be injected in to the water stream of a fire hose to practice potential fire suppression scen arios. AFFF was not used, however, by any of the vessels sampled for this study.

Of the 57 SVOCs that were analyzed for in the six firemain system water samples, only six were detected, none of which were detected in more than one sample (Table 3.7.3 and Figure 3.7.6). Similarly, of 37 VOCs analyzed for, only fi ve were detected, and as with the SVOCs, none were detected in more than one sample (Table 3.7.3). When SVOC and VOC concentrations were above detection levels, conc entrations were relatively low. Of these, only bis(2-ethylhexyl) phthal ate was measured at a sufficiently high concentration of 4.6 μg/L that exceeded the associated PHQ of 3.8, based on the most conservative screening benchmark of 1.2 μg/L (human health criterion). Bis(2-ethylhexyl ) phthalate was also the only SVOC or VOC detected in ambient water, but interestingly, at a s lightly higher concentration of 13 μg/L.

349Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.7.3. Results of Firemain Water Sample Analyses for SVOCs1AnalyteUnitsNo.samplesNo.detectedDetectedProportion(%)AverageConc.1MedianConc.MinimumConc.10%25%75%90%MaximumConc.ScreeningBM2SVOCs2,6,10,14-TetramethylPentadecaneμg/L111009.9NA2-Mercaptobenzothiazoleμg/L111004.1NABenzothiazoleμg/L111007.2NABicyclo[2.2.1]heptane,1,7,7-Trimethyl-μg/L1110014NABis(2-ethylhexyl) phthalateμg/L41252.13.44.64.61.2Isopropylbenzene-4,methyl-1μg/L111009.9NAVOCs1-Methyl-2-(1-Methylethyl)-Benzeneμg/L1110097NA1-Methyl-4-(1-Methylidene)-Cyclohexaneμg/L111006.8NALimoneneμg/L111009.5NAn-Pentadecaneμg/L111003.8NAn-Tetradecaneμg/L111003.5NANotes:(1) Nondetect (censored) concentrations were replaced with 1⁄2 of the reporting limit for calculating average concentrations. Theremaining statistics in this table were only calculatedwhen analytes were detected at a sufficientfrequency. For example, if an analyte was detected in fewer than 50% of samples, then a median concentration was not calculated. A blankcell reflects a situation when a median or percentile could not be computed based ondetected concentrations. The percentiles are the concentrations of each analyte below which atleast that percentage of the values fall. So the 10th percentileis the concentration below whichat least 10% of the observations were found.(2) Screening BM represents the screening benchmark referred to in Section3.1.3, and is the most stringent 2006 NRWQC or other conservative benchmark used to calculate PHQs.350Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 351 Figure 3.7.6. Box and Dot Density Plot of SVOC Concentrations Measured in Samples of Firemain Water
SVOCs are identified as follows: (1) 2,6,10,14-Tetramethyl Pentadecane, (2) 2-Mercaptobenzothiazole, (3) Benzothiazole, (4) Bicyclo[2.2.1]Heptane,1,7,7- Trimethyl-, (5) Bis(2-Ethylhexyl) Phthalate,(6) Isopropylbenzene-4, Methyl1 

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## 3.2.7.4 Summary of the Characterization of Firemain System Water Analyses

Table 3.7.4 summarizes the specific analytes in firemain system effluent that may have the potential to pose risk to human health or the environment. EPA’s interpretation of a realized risk likely posed by these analytes, relative to pollutant loadings, bac kground ambient and source water contaminant levels and characteristics, an d other relevant information useful for this assessment, is presented in Chapter 5.

The proportion of dissolved to total metals for firemain system discharge was low overall, relative to other discharge types. Am ong the dissolved metals, copper was detected in the highest concentrations and exceeded the NRWQ C in the largest number of samples (four of six samples). The corresponding PHQs for dissolv ed copper ranged from approximately 4 to
over 20. Dissolved lead and zinc had concentrations that exceeded the most conservative NRWQC in one and three samples, respectively, but none of the PHQs were above 10. Total aluminum and iron concentrations exceeded NRWQ C benchmarks in all samples, with PHQs ranging from 1-5 (aluminum) and of approximatley 13 (iron; single sample from a fire boat). However, most of the aluminum in firemain di scharge can be attributed to aluminum in the ambient waters. Overall, the concentrations of me tals in firemain discharge were low compared to other discharge types.

Among the classical pollutants, TRC was the only pollutant of potential concern. However, TRC was detected right at the reporting lim it of 0.10 mg/L in only one of six samples and the concentration likely reflects an elevat ed TRC concentration in the ambient water.

Finally, the concentration of bis(2-ethyl hexyl) phthalate (an SVOC) exceeded the NRWQC (PHQ = 3.8) in one discharge sample; however, most SVOCs and VOCs sampled for were below detection limits, and when they were detected, occurred at very low concentrations. It is noteworthy to reiterate th at bis(2-ethylhexyl) phthalate was also th e only SVOC or VOC detected in ambient water, and at a slightly higher concentration (13 μg/L) than in the one firemain water sample.

352Chapter 3 – Analysis of Discharges and Potential Impact to Human Health and the EnvironmentTable 3.7.4. Characterization of Firemain Discharge and Summaryof Analytes that May Have the Potential to Pose RiskAnalytes that May Have the Potential to Pose Risk in Firemain Discharge and Probable Source1, 2Vessel Type (no. vessels) Microbiologicals Volatile Organic Compounds Semivolatile Organic Compounds Metals ( total and dissolved) Oil and Grease Sulfide Short-Chain Alkylphenol Ethoxylates and NP Long-Chain Alkylphenol Ethoxylates Nutrients BOD, COD, and TOC Total Suspended Solids Other Physical/Chemical ParametersTour (3)Bis(2-ethylhexyl)phthalateCu(dissolved);Fe (total)TRCTug (2)Fireboat (1)Cu (dissolved)Notes:(1) EPA notes that the conclusion of potential risk is drawn froma small sample size, in somecases a single vessel, for certain discharges sampled from some vessel classes. EPAincluded these results in the tables to provide a concise summary of the data collected in the study, but strongly cautions thereader that these conclusions, where there are only a fewsamples from a given vessel class, should be considered preliminary and might not necessarily represent pollutant concentrations from these discharges from other vessels in thisclass.(2) Analytes are generally bolded when a large proportion of thesamples have concentrations exceeding the NRWQC (e.g., 25 to 50 percent), when several of the samples havePHQs > 10 (e.g., two or three of five), when a few samplesresult in PHQs greatly exceeding the screening benchmark (i.e., 100sto 1,000s), or, in the case of oil and grease and fornonylphenol, when one or more samples exceed an existing regulatorylimit by more than a factor of 2. See text in Section3.1.3for a definition of PHQs and Table 3.1 for screeningbenchmarks used to calculate these values.353Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.8 Antifouling Hull Coatings

Antifouling hull systems (AFSs) are specialized paints and other coatings intended to retard the growth of algae, weeds, and encrusting organisms such as ba rnacles and zebra mussels on the underwater portion of vessel hulls. These or ganisms may foul hulls and other underwater parts, increasing corrosion and drag, reducing safety and mane uverability, decreasing fuel efficiency and economy, and lengthening transit times (WHOI, 1952). Vessel hull fouling is often significant as vessels can move between a diverse range of aquatic environments and remain in the photic zone that is the most productive region of the water body (Chambers et al., 2006). Exposed to a variety of organisms, vessel hulls can transfer the organisms into other water bodies, where they can become invasive species 38



## .

.

Figure 3.8.1. Encrusting organisms (left) and weeds (right) growing on vessel hulls (figures from the Naval Surface Warfa re Center’s Carderock Division, West Bethesda, Maryland, and the Boating Industry Association of Victoria, South Melbourne, Australia 39 

## ).

The development of AFSs has a long history, as mariners have tried for centuries to keep vessel bottoms free of barnacles and other fouling growth (Yebra et al., 2004; Readman, 2006). Ancient civiliza tions of the Greeks and the Romans coated their vessels with lead sheathing secured by What is a Biocide? A biocide is a chemical substance capable of killing living organisms, usually in a selective
way.

38 

### For this report, EPA did not evaluate the relationship between Anti Foulant Systems, fouled vessel hulls and the transport/spread of invasive species Other studies have shown that fouled vessel hulls contribute to the spread of invasive species and increase fuel consumption, thereby increasing greenhouse gas emissions and vessel operator cost. Though it is beyond the scope of this study, preventing vessel hull fouling provides important environmental and economic benefits, however, as discussed in this section, biocidal anti-foulant paints can also contribute to environmental degradation.

39 

### See http://www.dt.navy.mil/sur-str-mat/fun-mat/pa i-pr o-bra/fou-con-tec/images/fouling.jpg and http://www.biavic.com.au/f iles/weedun d erhull.jpg , respectively, for access to figures.



## 354Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## copper nails. These heavy me tals were early examples of using biocides to control fouling. Columbus’ ships are thought to have been coated with pitch and tallow. In the United Kingdom, lead sheathing was abandoned by the Navy in the late 1600s, and antifouli ng paints containing tar, grease, sulphur pitch and brimstone were developed (Carberry, 2006). One hundred years later, copper sheathing was used that prevented fouling through dissolution of the toxic metal ions (Readman, 2006). With the introduction of iron ships in the mid-1800s, different antifouling paints were needed because the copper sheathing reacted with the hull material to hasten corrosion of the iron. New paints were developed by adding toxic biocides such as copper oxide, arsenic, and mercury oxide to resin binders. Following the Sec ond World War, the introduction of petroleum-based resins and health and safety concerns re lating to arsenic- and mercurycontaining paints meant that copper-based paints became most popular (Readman, 2006).

In the late 1950s and early 1960s, new antifouling paint form ulations using tributyltin (TBT) proved to be excellent in preventing hull fouling. TBT, especially in “self-polishing” formulations, proved very efficient, and the a pplication of TBT-based paints rapidly expanded. TBT was frequently formulated together with cuprous oxide to contro l a broader range of organisms. Not only was antifouling performanc e improved, but tin-based formulas (without copper components) are noncorrosive to alum inum, which was being used more in the construction of vessel hulls and propulsion syst ems. Unfortunately, the use of TBT also had severe and unexpected environmental conseque nces (Carberry, 2006). As the popularity of TBT grew, oyster producers in France reported she ll malformations caused by paint leachate containing TBT that rendered their harvest worthless. Wild populations of other mollusc species were also affected at very low concentrations of TBT in the wa ter and sediment (Evans et al., 1994). For example, female dog whelks ( Nucella sp.) developed male characteristics (termed imposex) at these levels (Bryan et al., 1986). This masculinization of female gastropods was also reported in the open North Sea (Ten Hallers-Tjabb es et al., 1994). TBT use on small vessels was phased out in the late 1980s, when EPA and ot her regulatory agencies (including those in Canada, Australia, and many in Europe) restricted use of TBT-based AFSs to ships longer than 25 meters (see Section 6.2.3 of this report for further discussion about regulatory elimination of TBT).

Restrictions on the use of TBT-based AFSs opened the market for paint manufacturers and chemical companies developing new biocides for new antifouling paints to be used on vessels. Other metallic species, such as copper (copper hydroxide, copper thiocyanate) and zinc (zinc pyrithione), are currently used as subs titutes for TBT. Copper oxide (in formulations without TBT) is by far the most common of the me tallic biocides, used in more than 90 percent of the approximately 180 AFS products registered in California (Singh asemanon, 2008). A single AFS product might actually contain multiple biocid es, with “booster biocid es” incorporated to
increase the duration and functiona lity of copper-based AFSs (Cha mbers et al., 2006). Irgarol is currently the organic biocide boos ter most frequently formulated into AFS products. As was the case for TBT, the biocides used in AFSs today ca n be toxic to a range of aquatic organisms, not

355Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## just fouling organisms. In the subsections belo w, EPA discusses the literature on studies of
adverse effects of these AFS bioc ides to aqua tic resources as well as alternatives to using
biocidal AFSs.

EPA did not sample antifouling systems as part of this study because of lack of time and resources available for this study. Assessing A FS discharge involves isolating a commercial vessel within a confined body of water (a “boat ba g” or slip liner), and measuring the release, discharge, or leaching of the AFS biocide(s) over a period of time (weeks or months); the amount of time needed for the study would impo se economic hardship on the vessel’s owners and operators. Rather, EPA elected to rely on the significant secondary data on anitifouling systems available in the literature.

3.2.8.1 Copper Biocides

Copper is typically the biocide added to antifouling paints to prevent biofouling organisms from attaching to the hull. The most common form of copper used in AFSs is cuprous oxide, which acts as a preventative biocide by leaching into the water body. Cuprous oxide
concentrations in marine antifou ling paints range from 26 to 76 percent by weight, with most paints in the 40- to 70-percent range. Since cupr ous oxide is 89 percent copper by weight, typical cuprous oxide marine antifouling paints are 36 to 62 percent c opper by weight (TDC Environmental, 2004). Two additional copper bioc ides are occasionally used in AFSs: copper thiocyanate and copper hydroxide. These formul ations are not as common, although copper thiocyanate has the advantage of being compatible with alumi num. The contribution of copper from these paints to receiving water is small re lative to AFSs containing cuprous oxide (TDC Environmental, 2004).

Conventional copper-based AFSs fall into se veral general categories: copolymer or ablative paints and hard contact leaching pain ts (Conway and Locke, 1994). Copolymer paints release biocide at a constant rate, ablating (w earing away) much like a bar of soap, which is intended to reduce the need for cleaning. Hard contact leaching paints are usually modified epoxy paints that leach biocide upon contact with water, and, over time , the biocide is released at a decreasing rate. Each of these coating formul ations can benefit from periodic hull cleaning to remove fouling growth, maintain a smooth surf ace, and improve the copper release on vessel hulls, but underwater hull cleaning can be a sour ce of pollution or intr oduce non-native species if not done carefully. Cleaning frequencies and me thods vary by paint type, area of vessel operation, frequency and conditions of operation, and vessel operato r’s needs. Techniques that capture removed fouling growth and paint residu e reduce negative impacts on the environment.

Passive leaching rates from antifouling paint, including those that are copper-based, depend on a number of factors, including the paint matrix (e.g., vinyl, epoxy), copper content, age of the paint, time since last hull cleaning, an d frequency of painting. Leaching rates also vary

356Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## with environmental conditions such as pH, tem per ature, salinity, and the existing slime “biofilm” layer (CRWQCB, 2005).

Rates of passive leaching of dissolved coppe r from AFSs on seven recreational vessels painted with epoxy copper antifouling paints were investigated in studies conducted in Southern California by the U.S. Navy, under test conditions intended to represent realistic vessel conditions. Copper release rates were found to range from 2 to 14 μg/cm 2 

## /day, with an average leaching rate of 8.2 μg/cm 2 

## /day 40 

## . In another study of coppe r-based AFSs on recreational vessels, researchers with the S outhern California Coastal Wate r Research Project (SCCWRP) measured the mass emissions of dissolved coppe r from both passive l eaching and underwater hull cleaning (Schiff et al., 2003). Fiberglass pane ls were painted with copper-based antifoulin paints and immersed in seawater in a harbor environment. SCCW RP researchers determined th average flux rates for epoxy and ha rd vinyl copper antifouling pain ts to be approximately 4.3 3.7 μg/cm 2 

## /day over the course of a month, respectively. In the SC CWRP study, the authors al discussed the comparability of the results between the U.S. Navy and SCCWRP studies. According to the authors, the range of passive leaching measurements from the U.S. Navy study was within the range of measurements obtained in the SCCWRP study. By combining the results from the two studies, an average passive leaching rate for vessels at the Shelter Island Yacht Club (SIYB) was determined to be 6.5 μg/cm 2 

## /day (CRWQCB, 2005). In the United Kingdom, Thomas et al. (1999) found highe r copper leaching rates for ablati ve copper antifouling paint ranging from 18.6 to 21.6 μg/cm 2 

## /day in 17 day experiments (Schiff et al., 2003). Table 3.8.1 summarizes the passive leaching rates for vessel AFSs found in the literature. The copper leaching rates summarized in this table were measured in experiments designed to simulate environmentally relevant conditions. However, more recently developed types of AFSs may leach at different rates, and the actual rates of copper leaching from ma ny vessels and real-world environmental conditions may differ from those in Table 3.8.1 g

e and

so

41



## .

Estimates of copper released from AFS leaching and underwater hull cleaning were calculated based upon the 6.5 μg/cm 2 

## /day average flux rate cited above, which was extrapolated to vessels using the underwat er surface area of the hull 42 

## , and then to marinas (or harbors) based on the number of vessels in the marinas. Desp ite the caveats and limitations discussed above, EPA uses these estimates in Chapter 4 to calculate loadings from vessel hull AFSs to attempt to

40 

### EPA notes that a calculated average for release rates will not reflect real-world conditions for many vessels and environmental conditions.
41 

### Additional test data for copper AFC leaching rates were provided to EPA by the Antifouling Coatings Work Group (AFWG) of the American Coatings Assoc iation (ACA) during the public comment period. These data substantially agree with EPA's best estimate of copper AFC leaching rate (6.5 μg/cm 2 

### /day) used for water quality modeling in Chapter 4.
42 

### Hull surface area can be estimated using the following equation: Hull Surface Area = VesselLength*Beam*0.85 (Interlux, 1999)



### .



## 357Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## understand the impacts of this source of copper discharge from certain vessels on large water
bodies.

Even when an effective AFS is used, th e biofouling could accum ulate over time to unacceptable levels. If the AFS is still viable, this accumulated growth can be removed from vessel hulls by a number of methods, most fr equently by underwater hull cleaning. Several studies have investigated the re lease of copper from copper-based AFSs into water bodies during underwater hull cleaning. The amount of copper released depends on cleaning frequency, method of cleaning, type of paint, and frequency of painting (SWRCB, 1996). Valkirs et al. (1994) found that underwater hull cleaning resulted in elevated total copper concen trations near th e vicinity of the operation as dissolved copper was released during and shortly after hull cleaning. Smaller amounts of dissolved copper also leached from debris and sediments after cleaning. The particulate form of copper was rapidly incorpor ated into the bottom sediment, likely rendering it unavailable to aquatic organisms. The biologically active specie s of copper complexed rapidly, and dissolved copper levels return ed to precleaning c onditions within minutes to hours after the hull cleaning. Valkirs et al. (1994) concluded th at potential adverse eff ects of hull cleaning on aquatic organisms from the increas ed dissolved copper concentrations were relatively short-term and pulsed in nature, while the potential adverse effect s of increased particulate copper were probably long-term in nature, and dependent on resuspension or sediment uptake from benthic organisms.

McPherson and Peters (1995) also studied the effects of underwater hull cleaning on water body copper concentrations and toxicity to aquatic life. In the study, an underwater hull cleaning operation was performed in Shelter Island Yacht Basin using Best Management Practices (BMPs) that used less abrasive techni ques to remove fouling growth (e.g., hand-wiping with a soft cloth). Most of the copper released during the cleaning was in the dissolved form. Researchers found that the plume of copper released by cleaning moved with the current, and that the degree of plume contamination depende d on fouling extent and exertion by the diver. McPherson and Peters (1995) concluded that underw ater hull cleaning elevates concentrations in the vicinity of the operation, which return to background levels within minutes. The researchers did not identify the type of anti fouling paint (ablative or contact leaching paint), the age of the antifouling paint on the vessel, or the time sinc e last hull cleaning. While the study provided important information regarding impacts of underwater hull clean ing on water quality, it did not provide copper emission rates associated with hull cleaning.

Schiff et al. also estimated dissolved copper emissions rate s associated with underwater hull cleaning. Fiberglass panels were painted with copper antifoulants to simulate the hulls of recreational vessels. The study objec tive was to estimate the flux rates of dissolved copper from underwater hull cleaning of vessels painted wi th two commonly used types of copper-based antifouling paints in San Diego Bay. Schiff found that hull cleaning released between 3.8 to 17.4 μg/cm 2 

## per event (see Table 3.8.2), with an average release of 8.6 μg/cm 2 

## /event. The researchers
concluded that underwater hull cleaning results in a greater daily load of copper to the

358Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## environment than passiv e leaching. In terms of mass loading, the authors concluded that approximately 95 percent of dissolved copper from antifouling paint enters the environment via passive leaching (CRWQCB, 2005). EPA notes, however , that this does not include loading rates from particulate copper, which may also impa ir the environment in the benthos due to biogeochemical cycling.

AFSs that are applied to vessel hulls are one of the most commonly identified major sources for copper in marinas. A number of studies have been carried out to estimate the loading of copper from vessel AFSs. EPA estimated that copper loading from AFS use in California’s Lower Newport Bay (LNB) area, which harbors approximately 10,000 boats, contributed more than 62,000 pounds of copper (via passive leachi ng and underwater hull cleaning) into LNB waters annually (USEPA, 2002). EPA believed that this load could account for as much as 80 percent of all copper input into LNB.

The U.S. Navy and private researchers conduc ted two copper source loading studies for the San Diego Bay in the late 1990s (Johnson et al., 1998; PRC, 1997). Bo th studies concluded that AFSs accounted for the majority of disso lved copper loading to the bay. The San Diego Regional Water Quality Control Board (SDRWQCB) estimated that passive leaching and underwater hull cleaning of the 2,400 boats berthed in the SIYB marina combine to contribute 98 percent of the copper load to the basin (Singhasemanon et al., 2009). Of the approximately 1.8 pounds of copper estimated released per boat per year (TDC Environmental, 2004), about 95 percent is believed to leach from AFS while boa ts are moored at the dock; the remaining 5 percent is believed to be re leased during monthly underwat er hull cleaning activities.

The constant input of copper by leaching from the AFSs applied to pleasure, commercial, and military vessels has been cited as a likel y primary source of copper in San Diego Bay.
Sediment concentrations measured at the SI YB were relatively high (from 133 to 212 mg/kg) compared to other areas in San Diego Bay (Valki rs et al., 1994). Elevated copper concentrations (108 to 270 mg/kg) were found throughout San Die go Bay, with small boat harbors, commercial shipping berths, and military be rths most affected. This dist ribution pattern is expected, considering the historical use of coppe r-based antifouling paints in the area.

Marinas in general tend to have elevated leve ls of pollutants in the water and sediments, including copper, as explained later in this s ubsection. For example, moni toring in the Southern California Bight demonstrated that sediment fr om marinas throughout southern California had consistently elevated copper levels co mpared to surrounding waters (Bay et al., 2000). The National Oceanic and Atmospheric Administra tion (NOAA , 1991) found the highest sediment concentrations, reaching over 104 mg copper/dry kg, in marinas, compared to other areas throughout the Southern Californi a Bight. Sediment quality surveys around the United States routinely find high copper concentrations in marinas and harbors (USEPA, 1996; NOAA, 1994).

359Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## A recent study of AFS biocides in C a lifornia marinas found dissolved copper concentrations ranging from 0.1–18.4 μ g/L (Singhasemanon, 2008) in the water. Concentrations were significantly higher in salt- and brackish water marinas than in freshwater marinas. Dissolved copper concentrations in many of the salt- and br ackish water marinas exceeded established water quality standard s. Thus, there are ecological ri sks due to copper in many salt and brackish water marinas (Singhasemanon, 2008).

Copper contamination from vessel hulls is a water quality problem that is not unique to California. Within the United States, other ar eas of current concern to regulators include Chesapeake Bay, Maryland; Port Canaveral a nd Indian River Lagoon, Florida; and various
harbors in the state of Wash ington (Carson et al, 2009).

Elevated copper levels in marina s may be attributable to a nu mber of factors. Marinas are home to high concentrations of recreational a nd commercial vessels. Si nce recreational vessels spend much of their time moored in marinas, mo st of the biocide from the antifouling paints on
the vessel hulls is released in the marinas. Mo reover, marinas are purposefully constructed to shelter boats from currents and waves, so they are not flushed well. Elevated trace metal concentrations in marinas are partly the result of the lack of mixing and dispersion. Thus, AFS pollution at these locations would represent some of the worst-case scenarios with regard to water quality (Singhasemanon et al., 2009; CRWQCB, 2005).

The biocides leached from AFSs can accumulate in the water of poorly flushed boat basins to levels that might harm marine life, especially mollusks, crustaceans, and echinoderms (Johnson and Gonzalez, 2006). At rela tively low concentrations, coppe r is toxic to a wide range of aquatic organisms, not just fouling organi sms (CRWQCB, 2005). Concen trations as low as 5
to 25 μ g/L can be lethal for marine invertebrates (Chambers et al., 2006). Elevated copper levels affect growth, development, feed ing, reproduction, and survival at various life stages of fish, mussels, oysters, scallops, crustaceans, and sea urch ins. High copper levels also change the types of phytoplankton that thrive in boat basins (Calabrese et al., 1984). Low levels of dissolved copper affect the olfactory capab ilities in juvenile Coho salmon, which is critical for homing, foraging, and predator avoidance (Baldwin et al., 2004). The eff ect of copper on olfaction of juvenile salmonids suggests that copper might aff ect other fish species, to o. Most effects on fish are sublethal (e.g., they may hinder metabolic processes, reproduction, development, activity levels and behavior). Thus, the damage is chronic and less noticeable than, for example, fish kills caused by sudden oxygen depletion (Evans et al., 1994).

In the California marina study, significant t oxicity was measured in eight of 47 water samples; seven of the toxic samples came from Marina del Rey (MdR) in Los Angeles (Singhasemanon et al., 2009). The authors conclude d that copper was the most likely cause of the toxicity in these samples. Two models of copper bioavailability a nd toxicity to aquatic organisms, the Biotic Ligand Model (BLM) and dissolved organic carbon (DOC) model, were

360Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## used to confirm these findings. The BLM and DOC m odel predictions agreed favorably with the actual toxicity data, although both m odels tended to slightly overpred ict toxicity, especially when
close to the toxic effect concentration (i.e., EC 50 

## ) (Singhasemanon, 2008).

Rivera-Duarte et al. (2003) also investigated the bioavailabil ity and toxicity of copper in San Diego Bay and found that t oxicity was based on chemical speciation and followed the free ion activity model. The EC 50 

## for mussel larval development was observed near 10 -11 

## molar (i.e., 0.64 ng/L) free copper ion. The toxic threshold con centration of free copper ion was independent of spatial and temporal effect s, indicating the need to study chemical speciation of copper released from antifouling paints in order to determine its environmental effects (Rivera-Duarte et al., 2003).

Table 3.8.1. Rates of Passive Copper Leaching from Vessel AFSs

Study Test Method AFS Leaching Rate (μg/cm 2 /day)
UK (Thomas et al., 1999) Not reported Ablative copper antifouling paint 18.6 – 21.6
U.S. Navy (Zirino and

Seligman, 2002) Not reported Ablative copper antifouling paint Average = 3.9

U.S. Navy (Valkirs et al., 2003) 7 recreational vessels in recirculating dome system Epoxy copper antifouling paint 2 - 14 (average = 8.2)

Epoxy copper antifouling paint 4.3
Hard vinyl/Teflon copper antifouling paint 3.7 SCCWRP (Schiff et al., 2003) Fiberglass panels in recirculating dome system Biocide-free coating 0.24



## 361Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## Table 3.8.2. Dissolved Copper Release from Vessel AFSs During an Underw ater Hull Cleaning “Event”

AFS Cleaning Method Copper Release (μg/cm 2 /event) Less abrasive management practices 8.6 Epoxy copper antifouling paint No management practices 17.4 Less abrasive management practices 3.8 Hard vinyl/Teflon copper antifouling paint No management practices 4.2 Less abrasive management practices 0.03 Biocide-free coating No management practices 0.05
Source: Schiff et al., 2003



## Table 3.8.3. Estimated Dissolved Copper Ma ss Emissions from a 9.1m (30ft) Powerboat

Dissolved Copper Emission (grams/month) Source Epoxy Copper Antifouling Paint Hard Vinyl/Teflon Copper Antifouling Paint Biocide-Free Coating
Passive leaching (min-max) 24.9 (23.3-27.8) 21.4 (15.7-24.5) 1.4 (0.9-1.8)

Underwater hull cleaning with BMPs (min-max) 1.8 (1.7-2.0) 0.8 (0.5-1.2) <0.01 (0-0.01)

Total emissions (min-max) 26.7 (20.5-33.6) 22.2 (15.0-31.5) 1.4 (0.9-1.8) Source : Schiff et al., 2003



## 362Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 3.2.8.2 Irgarol and Other Organic Biocid e Boosters

Irgarol (Irgarol 1051, N -tert-butyl- N ′ -cyclopropyl-6-methylthio- 1,3,5-triazine-2,4- diamine) is a highly effective biocide used in AFSs to prevent the grow th of autotrophic (e.g., plants and algae) organisms on vessel hulls. After the ban of tributyltin (TBT) on vessels shorter than 25 meters, the use of TBT-free paints containing copper compounds and organic booster biocides such as Irgarol increased considerab ly and became more widespread (Mohr et al., 2009). Other organic biocides, including Diuron (3-(3,4-dichlo rophenyl)-1,1-dimethylurea), dichlorofluanid (1,1-dichloro-N-( dimethylamino)sulfonyl)-1-fluoro-Nphenylmethanesulfenamide), and Sea-Nine (4,5 -dichloro-2-n-octyl-4- isothiazolino-3-one) are also added to AFS preparations to boost perfor mance (Thomas et al., 2001). The use of biocide boosters is in part a response to concerns a bout performance, environmental impacts, and, according to Chambers et al., (2006), a reported increasing tolerance of some macrophytes and algae to copper. Freshwater locations such as the Great Lakes are plagued primarily by algae (West Marine, 2008), and booster biocides such as Irgar ol are used to restrict the growth of algae by blocking photosynthesis near the water surface. To date, however, most studies on Irgarol
have focused on marine areas a nd toxicity tests with marine organisms (Mohr et al., 2009).

Irgarol has been detected with increasing fr equency at ecologically sensitive levels in coastal waters worldwide, as reviewed by Konsta ntinou and Albanis (2004). In ports and marinas in coastal waters, it has been detected in relevant effect concen trations of up to 4.2 μ g/L (Basheer et al., 2002). Levels of up to 1.4 and 2.4 μ g/L have been reported from UK marinas and freshwater sites (Thomas et al., 2002). In the Un ited States, Irgarol and its major metabolite M1 have been detected in the Chesapeake Bay a nd Florida (Hall and Gardinali, 2004). In the California marina study, Irgarol a nd M1 were detected in all 45 marina samples (Singhasemanon et al., 2009); Irgarol concentra tions ranged from 12 to 712 ng/L, and M1 concentrations ranged from 1.6 to 217.1 ng/L. Higher concentrations of irgarol and M1 were found in salt water
marinas.

Although Irgarol was predicted to easily dissipa te under natural conditions (Hall et al., 2005), it is the most frequently detected anti fouling biocide worldwide (Konstantinou and Albanis, 2004). Published values of the half-life of Irgarol in water are between 24 and 200 days (Mohr et al., 2009).

363Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## EPA has expressed concern over the potential toxic effects of Irgarol on aquatic plants and algae (USEPA, 2003a). Compared to other tri azines like atrazine and simazine, Irgarol is a more potent inhibitor of al gal photosynthesis, and is therefore highly toxic to macrophytes, phytoplankton, and periphyton (Mohr et al., 2008). Irgarol is likely to
be much less toxic to animal s than flora (Mohr et al., 2009). The main metabolite M1 is also toxic to aquatic plants and algae, but in many cases much more than 10 times less toxic than Irgarol. What are Macrophytes, Phytoplankton, and Periphyton?

A macrophyte is an aquatic plant that grows in or near water and is either emergent, submergent, or floating.

Phytoplankton are planktonic algae that live in water bodies.

Periphyton is a complex mixture of algae, cyanobacteria, heterotrophic microbes, and detritus that is attached to submerged surfaces in most aquatic ecosystems. 

## Although Irgarol is formulated in AFSs to control periphyton on vesse l hulls, the range of
environmental concentrations m easured in freshwater can be toxic to nontarget macrophytes. The results of the Mohr et al. (2009) study indicate that Irgarol is likely to have serious impacts on natural macrophyte communities at environmentally relevant concentrations. The fact that Irgarol accumulates in macrophytes, especially at lower concentrations, suggests the expected toxi city of Irgarol may be underestimated (Mohr et al., 2009).

Irgarol concentrations at many of the marinas in the Calif ornia study were high enough to be toxic to some phytoplankton and aquatic plants (Singhasema non et al., 2009). For example, the range of observed Irgaro l concentrations (12 to 712 ng/L) exceed aquatic benchmark values that are protective of 90 percen t of aquatic plant species. Th e Irgarol metabolite M1 never exceeded the aquatic benchmark value (Singhasemanon, 2008).

3.2.8.3 Zinc Biocides

In recent years, there has been an increase in the registration of A FS products with zinc pyrithione (bis(N-oxopyridine-2-t hionato)zinc(II)), also commonl y known as zinc omadine, as the primary biocide (Singha semanon et al., 2009).

In a California marina study, dissolved zinc concentrations from pa ints containing zinc omadine ranged from 1.0–66.6 μ g/L with a concentration distribution that was similar to dissolved copper (Singhasemanon, 2008). Dissolved zinc concentrations were much higher in
saltwater marinas than brackish and freshwater marinas. Zinc concentrations did not exceed
California Toxics Rule (CTR) fresh- and saltwater standards. If zinc pyrithione becomes more popular as an AFS biocide in the future (e.g., as a replacement for copper AFSs), the

364Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## contri butions of zinc AFSs to the marina zinc load will increase and potentially lead to zincrelated toxicity (Si nghasemanon et al., 2009).

3.2.8.4 Emerging Biocides

As mentioned in the introduction to this subsection, AFSs using copper-containing
biocides are the most common substitutes for TB T. However, paint manufacturers continue to search for new antifouling biocides. One prom ising development is ECONEA, a metal-free biocide developed by a pharmaceutical compa ny. According to the paint manufacturers, ECONEA is rapidly biodegradable and does not a ccumulate in the marine environment, and is reported by the manufacturer to ve ry effectively control a wide range of invertebrate fouling organisms in significantly less amounts compared to conventional biocides. However, AFSs
formulated with ECONEA have not entered the market, and independent testing data are not currently available.

3.2.8.5 Biocide-Free (Nonbiocidal) AFSs

In recent years, biocide-free coatings desi gned to prevent fouling growth from adhering to boat hulls have entered the market. Biocide-free coatings are designed to produce a slick surface that prevents fouling organisms from fi rmly adhering to the hull. Currently available nonbiocidal bottom coatings may be silicone-b ased, epoxy-based, water (urethane)-based, or polymer-based. They do not include biocidal components. Epoxy coatings are durable, and are expected to last for many y ears, but require frequent and aggressive cleaning (Johnson and Miller, 2002). The most commonly used nonbiocidal coatings are silicone elastomeric coatings, which are rubbery and are more easily nicked or abraded than epoxy, although recent advances have improved their durability. They are sometim es called “fouling release” coatings, because fouling growth is sheared off the hull once th e vessel exceeds a certain speed (e.g., 20 knots).
Movement of a foul-release-coat ed vessel through the water disl odges organisms that do adhere. The utility of these coatings depends on vesse l speeds and the proportion of time the vessel is underway (rather than at dock). F oul-release coatings are typically more expensive than biocidal AFSs. Because of their expense and operational re quirements, foul-release systems generally are
not used on recreational vessels at this time.

To date, nontoxic AFS alternatives have not been widely accepted in the boating industry, due to concerns about practicality a nd cost. If adopted, thes e alternatives would eliminate the leaching of biocides from marine antifouling paint, as well as biocide release during underwater hull cleaning.

A number of projects are underway to de velop new biocide-free AFSs. The European Commission is collaborating with industry with the goal of de veloping a nonbiocidal antifouling

365Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment


## coating that relies on nanostru cturing to impede the adhesion of fouling organism s (Ambio, 2008). The U.S. Navy is sponsoring research by Un iversity of Florida en gineers to develop a biocide-free hull coating based on the geometry of shark skin scales. Ch ambers et al. (2006) provide a review of these and ot her biomimetic approaches to environmentally effective AFSs.

Because nonbiocidal coatings do not affect f ouling growth, they may need more frequent cleaning than biocide-based AFSs, and can be mo re effective when used with other practices designed to increase the amount of shearing and decrease exposure to fouling organisms during times of inactivity: using the vessel more often a nd/or operating it at higher speeds; storing it on land or on a hoist at the slip when not in use; and, surrounding the vessel with a slip liner and adding 10 to 15 percent fresh water to re duce salinity (Johnson and Gonzalez, 2006).

3.2.8.6 BMPs

The most effective way to reduce biocide emi ssions from AFSs on recreational vessels is by carefully selecting the AFS. The owner/opera tor should match antifouling performance with how the vessel typically operates. Choosing a nonbiocidal AFS can eliminate emissions from vessels that, for example, ope rate at high speeds when they are underway. Slow-release
formulations or formulations with lower biocide content may also reduce the release of biocides into the aquatic environment. As noted previ ously, passive leaching accounts for most of the
biocide release from recreational vessels, but biocide also coul d leach into the water body during underwater hull cleaning and AFS application and removal.

In addition to AFS selection, other BMPs ma y be used to limit emissions of toxic components from AFSs. These BMPs include speci fications for capturing and treating materials removed during underwater hull cleaning, properl y managing wastes from AFS application processes, and capturing and a ppropriately disposing of old hull coating residue prior to repainting. When nonbiocidal coati ngs are used, companion strategies can be used to reduce fouling including slip liners, boa t lifts, and frequent hull cleani ng (Johnson and Gonzalez, 2006).

BMPs for underwater hull cleaning must also address the potential in troduction of aquatic nuisance species (ANS). EPA notes that small ve ssels are strongly suspected of contributing to the spread of numerous invasive species incl uding zebra and quagga mussels. Prohibitions on biocide-containing AFSs could poten tially exacerbate the spread of ANS as the toxicity of vessel hull coatings declines and as water quality improves as a result.

Pollutants from passive leaching and hull cleaning can be reduced by implementing other BMPs, such as using nontoxic (or less toxic) an tifouling paints to replace copper-based paints. Switching to nontoxic and less toxi c antifouling paints will reduce the loading from both passive leaching and underwater hull cleaning. For example, if all new boats entering the Shelter Island Yacht Basin use nontoxic or less toxic coatings and existing boats replac e copper coatings with nontoxic or less toxic coatings at the next rou tine hull-stripping (as assumed in their total

366Chapter 3 – Analysis of Discharges and Potentia l Impact to Human Health and the Environment



## 367 maximum daily load), the basin’s water quality is expected to dramati cally improve (CRWQCB, 2005). Additionally, nontoxic or less toxic coatings will require co mpanion strategies such as slip liners, boat lifts, and fr equent hull cleaning to control f ouling (Johnson and Gonzalez, 2006).

3.2.8.7 Conclusion

Antifouling systems currently used on the majority of recreational and commercial vessels are paints that prevent and retard fou ling growth by leaching biocides, most frequently cuprous oxide, onto the hull. Biocides can enter a water body through passive leaching, underwater hull cleaning, hull painting, and AF S removal processes. Biocides leached from
vessel AFSs can accumulate in the water of poorly flushed boat basins to levels that could harm marine life. Copper from vessel hulls in particular is a wate r quality concern in many nearcoastal waters of the United States, including the waters of Southern California, the Chesapeake Bay, Port Canaveral and Indian Ri ver Lagoon in Florida, and in va rious harbors in the state of Washington. Copper leaching from vessel hulls has also been reported as a problem in several European countries, including Swed en, the Netherlands, and Denmark.

Concerns about impacts to aquatic ecosystems from both TBT and copper have led to the development of AFSs that use a lternative biocides or are biocide-free. At this time, these alternatives are relatively costly and have not been widely accepted by boaters. Releases of biocidal components of AFS can be reduced by implementing BMPs, including the use of nontoxic (or less toxic) antifouling pain ts to replace copper-based paints.Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



# CHAPTER 4

P OTENTIAL LARGE-SCALE IMPACTS OF STUDY VESSELS’

INCIDENTAL DISCHARGES TO HUMAN HEALTH AND THE

ENVIRONMENT

In Chapter 3, EPA described the variety of vessel discharges and the scope and magnitude of pollutants discharged by ‘study ve ssels.’ EPA discussed whether these discharges of pollutants exceeded a National Recommended Wa ter Quality Criteria (NRWQC) at end-ofpipe or contained persistent bioaccumulative toxic (PBT) chemicals which could indicate a potential for environmental effects. Public Law (P.L.) 110-299 tasks EPA with assessing the potential for discharges incident al to the normal operation of ve ssels to pose a risk to human health, welfare, or the environment from all sizes of commercial fi shing vessels and other
nonrecreational vessels less than 79 feet in length. As part of this assessment, EPA used a screening-level model as a tool to evaluate the cumulative effects of discharges from a population of such vessels operating in a large receiving water body.

EPA developed the screening-le vel water quality model to a ssess the impacts of vessel discharges on a hypotheti cal harbor environment 1 

## . For purposes of the model, EPA developed several vessel population scenarios that included multiple vessels from numerous vessel classes, such as fishing vessels, tour boats, water taxis, and tugboats dischargi ng various waste streams (e.g., antifouling leachate, bilgewater, engine e ffluent, graywater). EPA then modeled numerous scenarios combining the different vessel popul ations in different hypothetical harbors to represent a range of environmental conditions po tentially observed in harbors across the United
States.

Due to the limitations of this screening-level model, EPA assumed that the background concentration for all an alytes in the harbor water was zero. Although this assumption is likely unrealistic, removing other loading considerations fr om model calculations allowed
EPA to evaluate whether incident al discharges from study vessels alone have the potential to exceed National Recommended Water Quality Crit eria (NRWQC) in recei ving waters without any additional sources of polluti on. Vessel discharges may have a potential to contribute to water body impairment when vessel discharge pollu tant concentrations exceed the NRWQC at end-of-pipe, depending on the quantity of pollutant in the discharg e, what other potential sources of pollution are present, and the characteristics of the waters in which the vessel is operating. For example, if a group of vessels contributes a significant quantity of a given pollutant via a

1 

### For this analysis, the “harbor environment” refers to a la rge body of water that could potentially have 175 to 300 commercial vessels simultaneously discharging. EPA assumed that the harbor area extended beyond the defined vessel docking area to include the surrounding water body with an estimated surface area ranging from one to three square miles.



## 368Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment


## discharge into a water b ody, the impact of the vessel discharge is m ore likely to contribute to a water quality exceedance. If a group of vessels cont ributes only a very small quantity of a given pollutant via a discharge, the impact of the vessel discharge is less likely to contribute meaningfully to a water quality exceedance. EPA believes that a ssessing the potential for vessel discharges to contribute to water-body impairment is best conducted on a site-specific basis and is beyond the scope of this screening-level analysis.

Based on this assessment, EPA determined that incidental discharges from study vessels do not solely cause any NRWQC to be exceeded in the modeled hypothetical large estuaries and harbors. This determination suggests that th ese discharges alone are unlikely to cause impairments to relatively large water bodies. Ho wever, if a large water body already contains select pollutants, then vessels that contribute sign ificant quantities of these pollutants might contribute to such an NRWQC exceedance. Furt hermore, as discussed in Chapter 3, many pollutants detected in the vessel discharges we re present at concentrations that exceed an NRWQC at the end of pipe, and therefore have th e potential to negatively impact the receiving
water on a more localized scal e. Because the screening model assumes instantaneous and universal dilution in a large hypot hetical harbor, the model is not designed to examine impacts on a local scale, in small water bodies with many vessels, or in water bodies with little to no flushing (i.e. dilution). These discharges may cau se environmental concerns in areas such as small side embayments or marinas where flushi ng rates are low (see discussion in Section 4.6). As discussed above, EPA further notes that this model does not take into account any loadings from vessels that are not study vessels or othe r point/nonpoint sources th at discharge pollutants
that contribute to the lo adings in the water body.

For the purpose of this study, EPA selected a simple screening-level model to provide a coarse “big picture” assessment of the overall po tential for discharges from study vessels to
cause or contribute to an im pact on human health, welfare, or the environment. Although a screening-level model has severa l limitations, it identifies an y major water quality issues, provides valuable information on pollutants of c oncern, identifies data gaps, and serves as a starting point for any future site-specific studies that are beyond the scope and objectives of this study.

The remainder of this chapter details EPA’s cumulative effects assessment and is organized as follows:

 Section 4.1: Model Selection - Presents EPA’s rationale fo r selecting the Fraction of Freshwater Screening-Level Model for the analysis.

 Section 4.2: Fraction of Fres hwater Model - Describes th e “fraction of freshwater model” and presents the equations and i nput parameters required for the screeninglevel analysis.

369Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



##  Section 4.3: Vessel Discharge Loading Rates - De scribes the methodology for developing the input parameters required to calculate the total analyte-specific loading rates for each ve ssel population scenario.

 Section 4.4: Hypothetical Harbor - De scribes the methodology for developing hypothetical harbor input parameters.

 Section 4.5: Model Scenarios - Presents th e 24 model scenarios represented in the model.

 Section 4.6: Model Results - Presents the re sults from the “fraction of freshwater model.”

 Section 4.7: Conclusions - Pr esents EPA’s conclusions on the potential for vessel discharges from study vessels to solely im pact large-scale harbors or estuaries (e.g., to solely pose a risk to human hea lth, welfare, and the environment).



## 4.1 M ODEL 

## S ELECTION



## Study vessels discharge into coastal harbor s throughout the United States. Estuarine models, which are commonly used to assess ha rbor water quality, consist of two primary components: hydrodynamics (i.e., water transport pr ocesses) and water quality. Estuarine models are generally classified into the following four levels according to th e temporal and spatial complexity of the hydrodynamic component of the model:

 Level I - Desktop screening models th at calculate seasonal or annual mean concentrations based on steady-state c onditions and simplified flushing time estimates.

 Level II - Computerized steady-state or tidally averaged qua si-dynamic simulation models, which generally use a box or compartment-type network.

 Level III - Computerized one-dimensional (i.e ., estuary is well-mixed vertically and laterally) and quasi-two-dimensional (i.e ., a link-node system describes estuary longitudinal and lateral mixing) dynamic simulation models.

 Level IV - Computerized two-dimensional (i.e., represents estuary longitudinal and lateral mixing) and three-dimensional (i.e., represents estuary longitudinal, lateral, and vertical mixing) dynamic simulation models (EPA 2001).

The sheer number of different coastal harbor environments potentially impacted by these vessels precludes using the more complex and data-intensive Level II, III, and IV models for the cumulative impacts analysis. For these reasons, EP A selected a Level I screening-level model, the “fraction of freshwater model,” for the environmental assessment of vessel discharges from study vessels.

370Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment


## In addition to coastal harbors, study vessels also discharge to fres hwater environments
such as the Great Lakes and m ajor river syst ems (e.g., Mississippi Rive r). The “fraction of freshwater model” is applicable to only es tuarine or saltwater-influenced environments; therefore, the modeling approach presented in this chapter does not address the potential environmental impact of vessel discharges in completely freshwater environments. Additional screening-level modeling approaches would be required to assess possible impacts of vessel discharges in these environments. EPA assumes that discharges to freshwater systems represent a smaller percentage of the tota l load from study vessels based on hailing port information provided in the Marine Information for Safe ty and Law Enforcement (MISLE) database maintained by the U.S. Coast Guard. Based on thes e data, commercial fish ing vessels are almost exclusively located along U.S. coastal waters, and only about a third of other nonrecreational vessels less than 79 feet in length cite an inland waterway as their hailing port.



## 4.2 F RACTION OF 

## F RESHWATER 

## M ODEL



## The “fraction of freshwater model” is a seri es of equations that represent the harbor
environment in zero dimensions and at a stea dy state (USEPA, 2001). These calculations are zero-dimensional in that they estimate concentrat ions at a given point in a water body within a specified, spatially homogenous volume. For example, the calculations assume instantaneous and homogeneous mixing of vessel discharges within the defined volume of a given harbor. It does not account for gradients of concentrations that would occur with distance from discharge source(s) such as plumes from vessels and other sources 2 

## . Specifying plumes and accounting for locations of numerous discharge sources would require a two- or thre e-dimensional model, which is beyond this Level I screening-level analysis.

Steady state means that the calculations pr ovide an instantaneous estimate of the concentration under the assumption of chemical a nd physical equilibrium. Chemical equilibrium means that the water body salinity and the vessel discharge analyte concen trations do not change over time, while physical equilibrium means that the volume of water in the water body, tides, currents, and vessel discharge flow rates do not change over time. The assumption is that every process occurs instantaneously; therefore, tempor al variability is not a factor. Accounting for changes in tides, currents, rive r flow, vessel discharge flow rate s, and discharge concentrations over time would require a dynamic model, which is beyond this Level I sc reening-level model. This aspect of the model may cause it to underestimate localized environmental impacts,

2 

### Discharge plumes can be highly struct ured, especially in low-flushing enviro nments; therefore, the development of a worst-case scenario using a screening-level model is not entirely conservative due to the assumptions of instantaneous and homogenous mixing within the entire volume of the harbor. A true worst-case scenario would likely include the concentration of pollutants within a sm all area of the harbor due to minimal dispersion of discharge plumes across the harbor. It would also include background concentrations and take other pollutant loadings into account (e.g., sewage treatment facilities, recreational vessels and other large vessels, stormwater, agricultural runoff).



## 371Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment


## especially in areas with inadequate flushing. However, in estima ting quantities of pollutants discharged from the various discharge types, EPA has tended to use conservative parameter estimates (i.e., estimates that may overstate the average value) for variables such as flow and pollutant concentration.

The “fraction of freshwater model” calculat es the analyte concentration in a harbor resulting from vessel discharges using the following four steps:

 Step 1: Calculate vessel discharge analyt e loading rates (Equa tions 4-1 and 4-2)

 Step 2: Calculate the fraction of fres hwater in the har bor (Equation 4-3)

 Step 3: Calculate the harbor flushing time (Equation 4-4)

 Step 4: Calculate the harbor an alyte concentration (Equation 4-5)

The following subsections describe the input requirements, assumptions, and calculations for each step in the “fraction of freshwater model.”

4.2.1 Step 1: Calculate Vessel Di scharge Analyte Loading Rates

Analyte-specific total discharge loading rates ( W e 

## ) are required as input values in the
“fraction of freshwater model” to calculate the instantaneous analyte concentrations in the harbor ( C x 

## ). In this analysis, analyte lo ading rates were based on the following four input parameters:

 Average analyte concentrations for each vessel class discharge type;

 Estimated flow rate for each discha rge type within a vessel class;

 Number of vessels per vessel cl ass present in the harbor; and

 Percentage of vessels per vessel class disc harging each discharge type in the harbor (Equation 4-1).

W

e,z 

## =  ( C e,y,z 

## * Q y,z 

## * N ,z 

## * P y,z 

## ) Equation 4-1

Where:
W e,z 

## = Discharge loading rate for analyte e from vessel class z (mass/time)
C

e,y,z 

## = Average concentration of analyte e in discharge y from vessel class z (mass/volume) Q y,z 

## = Flow rate for discharge y from vessel class z (volume/time)

N

,z 

## = Number of vessels in vessel class z present in the harbor

P

y,z 

## = Percentage of vessels in vessel class z discharging discharge y

EPA calculated the analyte-specific tota l discharge loading rate by summing the discharge loading rates for that analyte from each vessel class (Equation 4-2). Section 4.3
describes EP A’s methodology for calculating this loading rate in more detail.

W

e 

## =  ( W e,z 

## ) Equation 4-2

372Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## Where:
W e 

## = Total discharge loading rate for analyte e from study vessel discharges (mass/time)
W

e,z 

## = Discharge loading rate for analyte e from vessel class z (mass/time)

4.2.2 Step 2: Calculate the Fraction of Freshwater in the Harbor

The “fraction of freshwater model” estimates analyte concentrations in one dimension using information on freshwater inflow and by comp aring salinity in the harbor with salinity in
the seawater at the mouth of the harbor (USEPA, 2001). The fraction of freshwater ( f

x 

## ) at any location in the estuary is calculated as:

f

x 

## = ( S s 

## – S x 

## )/ S s 

## Equation 4-3

Where: f x 

## = Fraction of freshwater at location x in the model harbor (unit-less)

S s 

## = Seaward boundary salinity at the mouth of model harbor (PSU)

S

x 

## = Salinity at location x in model harbor (PSU)

EPA states that this ratio ( f

x 

## ) “...can be viewed as the degr ee of dilution of the freshwater inflow (as well as pollutants) by seawater” from tidal influx in the harbor (USEPA, 2001).

4.2.3 Step 3: Calculate the Harbor Flushing Time

Harbor flushing time is defined as the amount of time required to replace the freshwater volume of the harbor by the river fres hwater input. The flushing time ( t ) of the model harbor is calculated using Equation 4-4:

t = (V * f x 

## )/Q fw 

## Equation 4-4

Where:

t = Model harbor flushing time

V = Volume of model harbor f

x 

## = Fraction of freshwater at location x in model harb or (unit-less)
Q

fw 

## = Inflow of freshwater to model harbor from the model river (volume/time)

373Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 4.2.4 Step 4: Calculate the Harbor Analyte Concentration

The concentration of an analyte at location x ( C x 

## ) is the analyte-specific total loading rate ( W e 

## in mass/time) divided by the fl ow rate away from location x , described by the volume of the harbor ( V ) divided by the flushing time ( t ) (USEPA 2001):

C

x 

## = W e 

## /( V / t ) Equation 4-5

Where:
C x 

## = Instantaneous analyte concentration at location x in model harbor (mass/volume)
W

e 

## = Analyte-specific loading rate (mass/time) as calculated under Step 1

V = Volume of the model harbor as defined in Step 3

t = Model harbor flushing time as calculated in Step 3



## 4.3 V ESSEL 

## D ISCHARGE 

## L OADING 

## R ATES



## Step 1 in the “fraction of freshwater model” calculates a range of analyte-specific total loading rates ( W e 

## in mass/time) from fishing and nonrecreat ional vessels less than 79 feet based on the analyte concentration in a given discharge, the estimated flow rate for a given discharge, and assumptions on the number of vessels pres ent in a harbor and percentage of vessels discharging each discharge type in the har bor. The following subsections present EPA’s methodology for developing the modeli ng input parameters to calcula te the analyte-specific total discharge loading rate.

4.3.1 Calculate the Average Analyte Concentrations

As described in Chapter 2, EPA collected wa stewater characterization data for nine vessel discharges sampled from a total of 61 vessels (See Table 2.1). The objective of EPA’s sampling program was to provide information on th e nature, type, and com position of discharges from representative single study vessels and st udy vessel classes. EPA calculated vessel-classspecific analyte concentrations by averaging a ll of the discharge effluent sampling data by discharge type and by analyte. Replicate samples from a single vessel were averaged together prior to calculating a ve ssel-class-specific average. Certain an alytes were not detected above the sample reporting limit in some wastewater samples. To fully represent the va riability of pollutant
concentrations in vessel disc harges, EPA included both nondetect ed and detected results in calculating average vessel-class-sp ecific analyte concentrations . For nondetected results, EPA assumed the analyte concentration was equal to one-half the sample reporting limit for that analyte. EPA based this assumption on the expectation that the analyte was present in wastewater, albeit at a concentrati on less than the sample reporting limit.

374Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 4.3.2 Discharge Flow Rate Assumptions

EPA calculated discharge-specific flow rates for each of the 59 3 

## study vessels sampled based on the following information for each discharge type:

 Known or estimated flow rates for the pump or mechanism contro lling the discharge

 Assumptions on the frequency of discharge

 Assumptions on the dura tion of the discharge

EPA estimated vessel-specific discharge flow rates based on data and field observations from EPA’s vessel sampling program, as well as information from secondary data sources. EPA developed frequency and duration assumptions based on interview responses from the vessel crew or observations from EPA’s vessel samplin g team. For example, EPA reviewed interview responses from a tow/salvage vessel operator to estimate bilge disc harges based on the observation that the bilge pump di scharges 60 gallons per minute for an approximate duration of five seconds per pump-out with an average frequency of one pump out every 10-minutes. As another example, the frequency at which fishing vessels discharge fish hold water into a harbor is generally dictated by how often the vessel offl oads its catch. EPA used vessel sampling team field observations to develop the discharge fre quency for each fishing vessel subclass (Table 4.3.1).

In addition, many of the study vessel classes discharge diffe rent amounts in different seasons. For example, fishing vessels operate duri ng certain times of the y ear to coincide with different peak fishing seasons. As a conservative estimate, to acc ount for the seasonal nature of these discharge loadings, EPA developed vessel fl ows to represent the loading rate that would typically occur during peak vesse l activity for each vessel class. Specifically, EPA calculated the loading rates to represent the summer (or peak) season for all vessels, which is the time of greatest fishing activity in the major harbors across the United States and is generally the peak of recreational and tourist activity. 4

3 

### As previously discussed, EPA excluded the sampling data from the two recreational vessels in the model because these vessels are not study vessels.

4 

### Vessel flow rates presented in the screening-level analysis are not intended to be used to estimate annual loads. Additional seasonal considerations, such as the length of different fishing seasons, are required to calculate annual loads, which is beyond the scope of the screening-level analysis.



## 375Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 376 Table 4.3.1. Offload Frequency by Fishing Vessel Subtype

Fishing Vessel Subclass Frequency of Offloads 1



### Purse Seiners Daily
Trollers Daily

Gillnetters Daily

Tenders Once every 2 days Longliners Once every 2 days Shrimpers Once every 3 days

Trawlers Once every 3 days
(1) Based on sampling team observation in the field.



## Table 4.3.2 provides examples of the known or estimated field data parameters and assumptions used to calculate the vessel-specifi c discharge flow rates for each discharge type. Where data parameter information were unknown, EP A used information from a similar vessel discharge type or used best professional judgment to estimate the required information. Appendix G provides a detailed de scription of the data and assu mptions used to calculate the discharge-specific flows for each of these 59 samp led vessels. EPA averaged the vessel-specific discharge flows presented in Appendix G by vesse l class and discharge type to calculate the vessel class-specific flow rates ( Q y,z 

## ) used in the model (Table 4.3.3).Chapter 4 – Potential Large Scale Impacts of Study Vessels Incidental Discharges to Human Health and the EnvironmentTable 4.3.2. Examples of Field Dataand Assumptions for Flow RateCalculations by DischargeDischargeTypeExample Data ParametersExample AssumptionsExample Discharge Flow CalculationBilgewater- Flow rate of bilge pump- Frequency of bilge pumpout- Duration of a single pumpout- 12 volt bilge pump at 20 gpm1- Discharged all year- 5 min to pump bilge- 2 pumpouts per day- 5 min to pump bilge- 1 pump per week- Discharged 365 days a year- 12 volt bilge pump at 20 gpm20 gal per min X 5 min X 1 pump/7 days = 14.3 gal/day (0.05 m3/day)Deck Wash- Volume of water usedduring deck wash down- Frequency of deck washes- Duration of deck washes- Flow rate of garden hose orhigh-pressure sprayers usedto wash decks- Garden hose flow rate is 11.67 gpm2- 1 wash every 2 weeks- 15 minutes per deck wash- Cleaned with hose- 15 minute per deck wash- Garden hose flow rate is 11.67 gpm- 1 wash every 2 weeks11.67 gal per min X 15 min X 1 wash/14 days = 7.21 gal/day(0.03 m3/day)Fish Hold- Volume of holding tanks- Volume of fish- Whether the tanks hold fishin water or ice- Amount of ice- Frequency of offloads- Length of fishing season- Density of fish is 0.9 kg/liter- Holding tank is 70% shrimp, 30%water3- Ice tank holds 50% fish, 35% ice,15% air4- 5,000-gallon tank- 75% full at offload- Holding tank is 70%shrimp, 30% water- 1 offload every 3 days5000 gal X 30% X 3/4 full X 1offload/3 days = 375 gal/day (1.42m3/day)Fish HoldClean- Frequency of tankcleanings- Length of fishing season- Washed with garden hose- 30-minute wash for tenders and purseseiners- 15-minute wash for all other fishingvessels- Wash done after each offload- Garden hose flow rate is 11.67 gpm- 15-minute hose down after each offload- 1 offload every 3 days- Garden hose flow rate is 11.67 gpm11.67 gal per min X 15 min X 1 wash/ 3 day = 33.66 gal/day(0.13 m3/day)Graywater- Number of crew onboard- Types of graywatergenerated- Frequency of laundrywashed- Frequency of showers- Laundry – front-load washer uses 25gal/load- Laundry - standard washer uses 40gal/load- Shower - 17.2 gal per shower5- Shower - 0.8 showers per person perday5- Sink - 30 min of sink use per crew perweek- Sink - 2.2 gal per min in standard sink- 3 crew- 17.2 gal per shower- 0.8 showers per person per day3 crew X 17.2 gal per shower X 0.8 showers per person per day = 41.28gal/day (0.16 m3/day)377Chapter 4 – Potential Large Scale Impacts of Study Vessels Incidental Discharges to Human Health and the Environment378Table 4.3.2. Examples of Field Dataand Assumptions for Flow RateCalculations by DischargeDischargeTypeExample Data ParametersExample AssumptionsExample Discharge Flow CalculationGeneratorEngine- Engine type- Cooling system type- Hours of use per year- 2 gpm cooling flow for a standardgenerator6- 17,000 hours over 15 years- 2 gpm cooling flow2 gal/min X 60 min/hr X 17000hrs/15 years/365 days = 372.6 gal/day(1.41 m3/day)PropulsionEngine- Engine type- Cooling system type- Hours of use per year- Number of enginesonboard- 1 gpm cooling water flow rate foroutboard engine- 20 gpm cooling water flow rate forinboard engine6- Cummins inboard 380hp diesel engine- 463 hours in last 2 years- 20 gpm cooling water flow rate20 gal per min X 231.5 hours/year = 761.1 gal/day (2.88 m3/day)ShaftWater- Duration of boat operation- 10 mL/min constant drip (3.8 gal/daydrip)4- operates 5 days/week- 10 mL/min constant drip (3.8 gal/day drip)3.8 gal per day X 5 days/week = 2.71 gal/day (0.01 m3/day)(1) Estimate based on commonly used 12-volt bilge pumps. Flow rates ranged from 5 gpm to 30 gpm via Google.(2) EPA usedhttp://www.uiweb.uidaho.edu/extension/lawn/Files/Garden_Hose.htmto calculate the average flow rate ofa garden hose (i.e., 11.67 gpm). EPAcalculated the flow rate as the average flowfor all three sizes of standard garden hose (1/2, 5/8, and 3/4 inches in diameter), assuming a water pressure of 40 PSIand a hose length of 100 feet.(3) Based on data from one of the sampled vessels: 2,700 cubic feet per tank, 3 tanks (229,461.75 liters oftanks space), holds325,000 lbs of salmon (163,798liters of fish assuming density of fish is0.9 kg/L). 163,798 litersof fish/229,461.75 liters oftanks space = 70% of fish. Assume remaining is hold water.(4) Based on sampling team observation in the field.(5) WaterSense Showerhead Factoids, Draft Date 7/27/09.Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 379 Table 4.3.3. Vessel Flow Rates

Vessel Class Vessel Subclass Discharge Flow Discharged to Harbor per Vessel (m 3 

### /day) 1



### Fire Boat NA Deck Wash 0.0100
Fire Boat NA Engine Effluent 36.3
Fire Boat NA Fire Main Effluent 0.00 2



### Fire Boat NA Generator Effluent 1.80 Fishing Gillnetter Engine Effluent 14.9 Fishing Gillnetter Fish Hold Effluent 0.800 Fishing Lobster Boat Fish Hold Effluent 2.83 Fishing Longliner Bilgewater 0.450 Fishing Longliner Fish Hold Effluent 2.83

Fishing Longliner Fish Hold Cleaning Effluent 0.00 2 

### Fishing Purse Seiner Engine Effluent 16.6 Fishing Purse Seiner Fish Hold Effluent 16.3

Fishing Purse Seiner Fish Hold Cleaning Effluent 1.07 Fishing Purse Seiner Generator Effluent 1.41 Fishing Shrimper Bilgewater 2.84 Fishing Shrimper Deck Wash 0.344 Fishing Shrimper Fish Hold Effluent 1.25 Fishing Shrimper Graywater 0.00 2 

### Fishing Tender Vessel Fish Hold Effluent 19.3

Fishing Tender Vessel Fish Hold Cleaning Effluent 0.660 Fishing Trawler Deck Wash 0.344 Fishing Trawler Fish Hold Effluent 1.25 Fishing Trawler Fish Hold Clean 0.220 Fishing Troller Deck Wash 0.470 Fishing Troller Fish Hold Effluent 3.04

Fishing Troller Fish Hold Cleaning Effluent 0.660
Research NA Engine Effluent 0.0900 Supply Boat NA Deck Wash 0.0300

Tour Boat NA Bilgewater 0.0400

Tour Boat NA Deck Wash 0.140

Tour Boat NA Engine Effluent 42.2

Tour Boat NA Fire Main Effluent 0.00 2



### Tour Boat NA Generator Effluent 3.82 Tow/Salvage NA Bilgewater 1.39 Tow/Salvage NA Deck Wash 0.0240 Tow/Salvage NA Engine Effluent 0.952 Tugboat NA Deck Wash 0.0978 Tugboat NA Fire Main Effluent 0.00 2 

### Tugboat NA Graywater 0.478 Tugboat NA Shaft Water 0.0100Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 380 Table 4.3.3. Vessel Flow Rates

Vessel Class Vessel Subclass Discharge Flow Discharged to Harbor per Vessel (m 3 

### /day) 1



### Water Taxi NA Bilgewater 0.130
Water Taxi NA Deck Wash 0.0650
Water Taxi NA Engine Effluent 39.8
Water Taxi NA Generator Effluent 9.08
Water Taxi NA Graywater 0.280 NA – Not applicable. (1) EPA estimated discharge flow rates for each vessel class based on data and field observations from EPA’s vessel sampling program, as well as information from secondary data sources. EPA assumes that discharges not listed for a given vessel class are either not generated by a given vessel class or are discharged outside of the hypothetical harbor area. (2) These waste streams are all discharged in the harbor; however, the relatively small volume and infrequency of the discharge results in an insignificant daily discharge volume.Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 4.3.3 Number of Vessels Present in the Harbor

The total number of vessels present in any given harbor and the di stribution of vessels among the different vessel classes operating in that harbor vary significantly across the United
States. The number and distri bution of vessels among the diffe rent classes depend on factors such as the regional economic base (e.g., fishing ve rsus recreation), size of the city supporting the harbor, and geographic locati on (e.g., Alaska versus Gulf of Mexico). To represent the variety of vessel combinations potentially pr esent in a harbor, EPA developed the following three vessel population scen arios for the model:

 Scenario 1: Fishing Harbor - A harbor where fishing is the primary economic driver in the region, and fishing vessels represen t the majority of vessels present in the harbor 5



## .

 Scenario 2: Large Metropolitan Harbor - A harbor where there are nonrecreational study vessels associated with a large metropolitan city that would require a greater number of support vessels such as supply boats, tow/salvage vessels, and tugboats. In addition, EPA assumed that there would be a hi gher level of vessel activity within the hypothetical harbor compared to the activity assumed for Scenarios 1 and 3. Note that this screening analysis does not include large non study vessels such as container ships, tankers, bulk carriers, or other larger vessels, which would be present in almost any large port 6



## .

 Scenario 3: Recreational Har bor – A harbor where the prim ary economic driver is the tourist or recreation indust ry. Although recreational ve ssels are not study vessels, EPA assumed that a recreational harbor would have a high concentration of nonrecreational support vessels su ch as tow/salvage, tour boats, and water taxis associated with the regional recreationa l and tourist industry. However, as noted previously, this analysis does not consid er discharges from non study vessels and other sources.

EPA used data from the MISLE database maintained by the U.S. Coast Guard to develop the number of vessels present in the hypotheti cal harbors for the three scenarios and the distribution among the different vessel classes. The MISLE database includes a wide range of information regarding vessel and facility characte ristics, accidents, marine pollution incidents, and other pertinent information tracked by th e U.S. Coast Guard from investigation and

5 

### Charter fishing vessels are not modeled as part of this analysis. Charter fishing vessels are generally either manufactured or used primarily for pleasure, or leased, re nted, or chartered to a pers on for the pleasure of that person. Many are not inspected by the US Coast Guar d. These vessels are exempted from NPDES permitting requirements by the Clean Boating Act (P .L. 110-288). Other charter fishing vessels are inspected by the US Coast Guard. These inspected, non- recreational vessels are not exempted from NPDES by the Clean Boating Act, and are study vessels only if they are less than 79 feet. As a ge neral matter, therefore, EPA an ticipates that a significant portion of charter fishing vessels are not study vessels.

6 

### Due to time and resource constraints, EPA did not sample these large vessels for this study. Therefore, EPA did not calculate loadings from these larger vessels for this screening analysis.



## 381Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 382 inspection activity. While MISLE represents the most comprehensive national dataset currently available, it may not capture the entire universe of study vessels th at operate in U.S. waters (see Chapter 1 of this report for further discussion about the vessel universe in this study and the MISLE database).

EPA identified and compiled hailing port and ve ssel class distribution data on the top 20 hailing ports cited in the MIS LE database. Based on the identi fied harbors, EPA selected representative harbors for each ve ssel population scenario to deve lop the vessel distributions in the model (see Table 4.3.4).

Table 4.3.4. Vessel Population Scenario Representative Harbors Based on the Top 20 Hailing Ports Cited in the MISLE Database

Top 20 Hailing Ports Cited in MISLE Vessel Population Scenario 1

Fishing Harbor Vessel Population Scenario 2

Large Metropolitan Harbor Vessel Population Scenario 3 Recreational Harbor

Boston, MA X Cordova, AK X Gloucester, MA X Homer, AK X Houma, LA X
Houston, TX X X Juneau, AK X Ketchikan, AK X Key West, FL X Kodiak, AK X Miami, FL X X New Orleans, LA X X X New York, NY X X Norfolk, VA X Petersburg, AK X Portland, OR X X San Diego, CA X X San Francisco, CA X Seattle, WA X X
Sitka, AK X



## For each representative harbor, EPA calculate d the percentages of fishing vessels and non-fishing study vessels reported in the MIS LE database (see Table 4.3.5, Table 4.3.6, and Table 4.3.7). EPA averaged the percentages of fi shing and non-fishing vessels to develop the overall proportion of these vessel types for each vessel population scenario.Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment


## Table 4.3.5. Percentage of Study Vessels Present in Representative Fishing Harbor

Hailing Port Percentage of Fishing Vessels Percentage of Non-fishing Study vessels
New Orleans, LA 26% 74% Seattle, WA 69% 31%
Houston, TX 56% 44%
Juneau, AK 82% 18%
Houma, LA 39% 61% Cordova, AK 94% 6% Homer, AK 82% 18% Sitka, AK 76% 24% Kodiak, AK 91% 9% Portland, OR 51% 49% Ketchikan, AK 62% 38% Gloucester, MA 84% 16% Petersburg, AK 93% 7% Average 70% 30%

Source: MISLE database.



## Table 4.3.6. Percentage of Study Vessels Present in Representative Large Metropolitan Harbor

Hailing Port Percentage of Fishing Vessels Percentage of Non-fishing Study vessels
New Orleans, LA 26% 74% New York, NY 21% 79% Miami, FL 43% 57%
Boston, MA 55% 45% San Diego, CA 37% 63% Average 36% 64%

Source: MISLE database.



## 383Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment


## Table 4.3.7. Percent of Study Vessels Present in Representative Recrea tional Harbor

Hailing Port Percent of Fishing Vessels Percent of Non-fishing Study vessels
New Orleans, LA 26% 74% Seattle, WA 69% 31% New York, NY 21% 79% Houston, TX 56% 44% San Francisco, CA 64% 36% Miami, FL 43% 57% Norfolk, VA 28% 72% Houma, LA 39% 61% San Diego, CA 37% 63% Portland, OR 51% 49% Key West, FL 47% 53% Average 44% 56%

Source: MISLE database.



## EPA established the total number of vessels present in each vesse l population scenario
based on:

 Field observations from EPA’s vessel sampling program.

 Total vessel population data for the top 20 hailing ports as reported in the MISLE database.

 An assumption that the hypothetical harbor is representative of up to 10 miles of shoreline.

 An assumption that the vessel distributions reflect vessel populations during peak activity for each scenario (i.e., summer s eason during peak fishing, recreational, and tourist activity).

Based on these assumptions, EPA selected a total vessel population of 175 vessels for
Scenarios 1 and 3 and 300 vessels for Scenar io 2 (see Table 4.3.8). Table 4.3.8 presents the distribution of vessels among the different vessel classes for each vessel population scenario developed using the vessel ratios discussed above, assumptions on the total vessel population, field observations, and best professional judgment.

384Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 385 Table 4.3.8. Vessel Population Scenarios

Vessel Class Vessel Subclass Vessel Population Scenario 1 Fishing Harbor Vessel Population Scenario 2 Metropolitan Harbor Vessel Population Scenario 3 Recreational Harbor

Fire Boat NA 1 5 1 Fishing Gillnetter 12 10 9 Fishing Lobster Boat 12 10 9 Fishing Longliner 24 16 15 Fishing Purse Seiner 12 10 9 Fishing Shrimper 10 8 5 Fishing Tender Vessel 20 10 9 Fishing Trawler 20 16 13 Fishing Troller 12 10 9
Research NA 2 10 8 Supply Boat NA 12 55 10

Tour Boat NA 10 20 24 Tow/Salvage NA 6 40 20 Tugboat NA 12 60 10
Water Taxi NA 10 20 24
Total Number of Vessels 175 1 

### 300 2 

### 175 3


### NA – Not applicable. (1) Fishing harbor - percentage of fishing vessels is 70%, percentage of non-fishing vessels is 30%. (2) Large metropolitan harbor - percentage of fishing vessels is 30%, percentage of non-fishing vessels is 70%. (3) Recreational harbor - percentage of fishing vessels is 45%, percentage of non-fishing vessels is 55%.



## 4.3.4 Percentage of Vessels Discharging in the Harbor

In addition to the number of vessels presen t in the harbor, EPA also established the percentage of vessels within each vessel class and discharge type that discharge into the harbor. The purpose of this is to account for the fact that not all vessels within a vessel class discharge all waste streams. EPA developed and selected the percentage of vesse ls discharging to the harbor (see Table 4.3.9) based on interview responses and data collected during EPA’s vessel sampling program. EPA assumed all sampled vessels generate all discharges unless otherwise noted by the vessel operators as follows:

 Vessel does not have the system or proce ss responsible for the discharge (e.g., the vessel does not generate graywater as it doe s not have sinks, showers, or washing machines).

 System has no discharge (e.g., vessel propul sion and generator engines are keelcooled).

 Vessel typically discharges outside U.S. waters (e.g., fishing vessel washes decks after each catch at fishing grounds greater than 12 nautical miles from shore).

Based on these criteria, EPA calcula ted the percentage of vessels ( P y,z 

## ) in each vessel class that discharge each discharge type in to the harbor using the following equation:Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 386 P

y,z 

## = Sample N y,z 

## / Sample N z 

## Equation 4-6

Where:
P y,z 

## = Percentage of vessels in vessel class z discharging discharge y Sample N y,z 

## = Number of vessels in vessel class z discharging discharge y from EPA’s vessel sampling program Sample N z 

## = Number of vessels from vessel class z from EPA’s vessel sampling program

Appendix G includes the field data and assump tions used to devel op the percentage of vessels input parameter ( P y,z 

## ) for each vessel class and discharge stream.

Table 4.3.9. Percentage of Vessels Discharging in the Harbor

Vessel Class Vessel Subclass Discharge Percentage of Vessels Discharging Flow in Harbor 1



### Fire Boat NA Deck Wash 100%
Fire Boat NA Engine Effluent 100%
Fire Boat NA Fire Main Effluent 100%
Fire Boat NA Generator Effluent 100% Fishing Gillnetter Engine Effluent 80% Fishing Gillnetter Fish Hold Effluent 80% Fishing Lobster Boat Fish Hold Effluent 100% Fishing Longliner Bilgewater 33% Fishing Longliner Fish Hold Effluent 100%

Fishing Longliner Fish Hold Cleaning Effluent 100% Fishing Purse Seiner Engine Effluent 40% Fishing Purse Seiner Fish Hold Effluent 100%

Fishing Purse Seiner Fish Hold Cleaning Effluent 100% Fishing Purse Seiner Generator Effluent 40% Fishing Shrimper Bilgewater 50% Fishing Shrimper Deck Wash 80% Fishing Shrimper Fish Hold Effluent 80% Fishing Shrimper Graywater 100% Fishing Tender Vessel Fish Hold Effluent 100%

Fishing Tender Vessel Fish Hold Cleaning Effluent 67% Fishing Trawler Deck Wash 80% Fishing Trawler Fish Hold Effluent 80%

Fishing Trawler Fish Hold Clean Effluent 40% Fishing Troller Deck Wash 17% Fishing Troller Fish Hold Effluent 100%

Fishing Troller Fish Hold Cleaning Effluent 33%Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 387 Table 4.3.9. Percentage of Vessels Discharging in the Harbor

Vessel Class Vessel Subclass Discharge Percentage of Vessels Discharging Flow in Harbor 1



### Research NA Engine Effluent 100% Supply Boat NA Deck Wash 100%

Tour Boat NA Bilgewater 67%

Tour Boat NA Deck Wash 67%

Tour Boat NA Engine Effluent 100%

Tour Boat NA Fire Main Effluent 100%

Tour Boat NA Generator Effluent 67% Tow/Salvage NA Bilgewater 33% Tow/Salvage NA Deck Wash 100% Tow/Salvage NA Engine Effluent 83% Tugboat NA Deck Wash 100% Tugboat NA Fire Main Effluent 100% Tugboat NA Graywater 67% Tugboat NA Shaft Water 89%
Water Taxi NA Bilgewater 75%
Water Taxi NA Deck Wash 100%
Water Taxi NA Engine Effluent 100%
Water Taxi NA Generator Effluent 25%
Water Taxi NA Graywater 25% NA – Not applicable. (1) The percentages of vessels discharging to the harbor were determined based on field observations of sampled vessels. As a conservative estimate, it was assumed that 100% of vessels in sampled vessel classes with no information available discharge in the harbor.



## 4.3.5 Vessel Discharge Loading Rates

EPA calculated the vessel class-specific loading rates for each analyte ( W e,z 

## ) using Equation 4-1 for each of the three vessel population scenarios described in Section 4.3.3 . EPA
then calcula ted the total an alyte-specific load rates ( W e 

## ) for each vessel population scenario using Equation 4-2. Appendix G presents the total analyte- specific loading rates for each of the three vessel population scenarios represented in the m odel (i.e., fishing harbor, large metropolitan harbor, and recreational harbor).

4.3.6 Dissolved Copper Loading Rates from Antifouling Paints

In addition to the loading rates calculated based on EPA’s vessel sampling program data, EPA also considered the additional dissolved copp er load to receiving waters associated with antifouling paints used on vesse l hulls. As described in Chap ter 3, antifouling systems (AFSs) are designed to release biocide over time to re tard growth and maintain a smooth underwater surface (Schiff et al., 2003). Copper oxide is the most common biocide added to AFSs to preventChapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 388 biofouling organisms from attaching to the hull. Numerous studies have i nvestigated the leaching rate of copper from both passive leaching and underwater hull cleaning (Thomas et al., 1999; Zirino and Seligman, 2002; Valkirs et al., 2003 ; Schiff et al., 2003). Based on estimates produced in these studies, EPA selected a dissolved copper leachi ng rate of 8.2 μg/cm 2 

## /day to estimate the additional dissolved copper load to the harbor from vessel AFSs. EPA estimated the average vessel length for each vessel class base d on information available in the MISLE database and field observations from EPA’s vessel samp ling program (Table 4.3.10). EPA assumed that the beam of the vessel beam (i.e., width) was equal to approximately one-third its length and used Equation 4-7 (Interlux, 1999) to estimate the hull surface area fo r each vessel class:

A z 

## = L z 

## * ( L z 

## /3) * 0.85 Equation 4-7

Where:
A z 

## = Hull surface area for indivi dual vessels in vessel class z (area)

L

z 

## = Average length of vessels in vessel class z (distance)

Table 4.3.10. Estimated Average Vessel Length by Vessel Class

Vessel Class Vessel Subclass Vessel Length (feet) 1



### Fire Boat NA 50 Fishing Gillnetter 35 Fishing Lobster Boat 35 Fishing Longliner 35 Fishing Purse Seiner 50 Fishing Shrimper 50 Fishing Tender Vessel 100 Fishing Trawler 50 Fishing Troller 35
Research NA 40 Supply Boat NA 50

Tour Boat NA 50 Tow/Salvage NA 40 Tugboat NA 79

Water Taxi NA 79 NA – Not applicable. (1) - EPA estimated the averag e vessel length for each vessel class based on information available in the MISLE database and field observations during EPA’s vessel sampling

program.



## EPA calculated the dissolved copper loading rate from AFSs for each vessel population scenario using Equation 4-8, and then added these loadings to the dissolved copper loading rates
calculated in Secti on 4.3.5 for the other vessel discharges to determine the total dissolved copperChapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 389 load introduced into the har bor for each loading scenario 7 

## . EPA calculated that AFSs contribute approximately 2.79 lbs/day of dissolved copper under Vessel Population Scenario 1 (fishing harbor), 4.86 lbs/day under Vessel Population Sc enario 2 (large metropolitan harbor), and 2.63 lbs/day under Vessel Population S cenario 3 (recre ational harbor 8 

## ). Appendix G presents the total dissolved copper loading rates represented in the model.

AFC W copper 

### =  

## N z 

## * A z 

### * 8.2 μg/cm 2 

### /day 

## Equation 4-8

Where:
AFS W copper 

## = AFS discharge loading rate for dissolved copper (mass/time)
N

z 

## = Number of vessels in vessel class z present in the harbor

A z 

## = Hull surface area for indivi dual vessels in vessel class z (area)



## 4.4 H YPOTHETICAL 

## H ARBOR



## Given the wide variety of coastal harbor environments potentially impacted by study vessel discharges, EPA developed several hypot hetical harbors for the vessel discharge environmental assessment to represent a range of environmental conditions that could potentially be impacted. To develop input va lues that represented realisti c environmental conditions, EPA
identified and collected environmental data on eight harbors (Table 4.4.1) that represented a geographically and environmentally diverse grou p of water bodies, had the potential for a high density of study vessels, and received freshw ater inflow from a major river system.

Table 4.4.1. Harbors Selected for Mo del Input Parameter Development

Harbor Name City Name State River Name

Cohasset Harbor Boston Massachusetts Gulf River Dorchester Bay Boston Massachusetts Neponset River Auke Bay Juneau Alaska Mendenhall River Biscayne Bay Miami Florida Miami River Mobile Bay Mobile Alabama Tensaw, Blakeley, and Mobile River Yaquina Bay Newport Oregon Yaquina River Craford Bay Norfolk Virginia Eastern and Southern Branch Elizabeth River

Eastern Channel Sitka Alaska Indian River



## The “fraction of freshwater model” requires th e following four input parameters to define the water body characteristics:

7 

### Note that some hull cleaning methods can release a plume of antifouling paint, which contains copper in particulate form, in the water. The particulate copper can settle into the sediments and over time reenter the water body in the dissolved form. EPA did not include the potential dissolved copper load from particulate copper resulting from hull cleaning.

8 

### As noted above, these loading rates do not include the loading from nonstudy vessels.Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 390  Seaward boundary salinity at the mouth of the harbor ( S s 

## )

 Salinity at location x in the harbor ( S x 

## )

 Volume of the harbor ( V )

 Inflow of freshwater to the harbor ( Q fw 

## )

EPA collected data on the four input paramete rs for the harbors li sted in Table 4.4.1 and calculated a flushing time usi ng Equation 4-4 in Section 4.2.3 . Appendix G presents the
environmental data iden tified by EPA for each harbor listed in Table 4.4.1. EPA selected the input parameters for the hypotheti cal harbors’ salinity, volume, and river flow based on the
environmental data collected for the harbors with the minimum and maximum flushing times (Table 4.4.2). EPA assumed an average ocean salinity of 35 PSU for the salinity at the seaward boundary of the hypothetical harbor.

Table 4.4.2. Hypothetical Harbor Input Parameters

Model Parameter Model Input Value Units

Harbor Salinity ( S
x 

### ) Minimum 26.1 PSU Harbor Salinity ( S
x 

### ) Maximum 31 PSU Ocean Salinity ( S
s 

### ) 35 PSU Harbor Volume ( V ) Minimum 3,090,000 m 3


### Harbor Volume ( V ) Maximum 38,500,000 m 3


### River Flow ( Q fw 

### ) Minimum 352,000 m 3 

### /day River Flow ( Q fw 

### ) Maximum 2,900,000 m 3 

### /day



## Using the input parameters in Table 4.4.2, EP A developed eight hypot hetical harbors for the vessel discharge environmental assessment (s ee Table 4.4.3). For each harbor scenario, EPA calculated the fraction of freshwater ( f

x 

## ) and flushing time ( t ) using Equations 4-3 and 4-4 in
Sections 4.2.2 and 4.2.3 , respectively. Flushing times for th e hypothetical harbors ranged from less than a day (0.122 days or 2.9 hours) to 27.8 days.Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 391 Table 4.4.3. Hypothetical Harbor Scenarios

Hypothetical Harbor Scenarios Harbor Salinity ( S
x 

### ) Ocean Salinity ( S
s 

### ) Harbor Volume ( V ) River Flow ( Q fw 

### ) f
x 

### Flushing Time (Days)

Harbor Scenario 1 26.1 PSU S
x 

### Min 35 PSU 3,090,000 m 3



### V Min 352,000 m 3 

### /day Q fw 

### Min 0.254 2.23

Harbor Scenario 2 26.1 PSU S
x 

### Min 35 PSU 3,090,000 m 3



### V Min 2,900,000 m 3 

### /day Q fw 

### Max 0.254 0.271

Harbor Scenario 3 26.1 PSU S
x 

### Min 35 PSU 38,500,000 m 3



### V Max 352,000 m 3 

### /day Q fw 

### Min 0.254 27.8

Harbor Scenario 4 26.1 PSU S
x 

### Min 35 PSU 38,500,000 m 3



### V Max 2,900,000 m 3 

### /day Q fw 

### Max 0.254 3.38

Harbor Scenario 5 31 PSU S
x 

### Max 35 PSU 3,090,000 m 3



### V Min 352,000 m 3 

### /day Q fw 

### Min 0.114 1

Harbor Scenario 6 31 PSU S
x 

### Max 35 PSU 3,090,000 m 3



### V Min 2,900,000 m 3 

### /day Q fw 

### Max 0.114 0.122

Harbor Scenario 7 31 PSU S
x 

### Max 35 PSU 38,500,000 m 3



### V Max 352,000 m 3 

### /day Q fw 

### Min 0.114 12.5

Harbor Scenario 8 31 PSU S
x 

### Max 35 PSU 38,500,000 m 3



### V Max 2,900,000 m 3 

### /day Q fw 

### Max 0.114 1.52



## 4.5 M ODEL 

## S CENARIOS



## EPA developed a total of 24 model scenarios (see Table 4.5.1) for the screening-level analysis based on the three ve ssel population scenarios and th e eight hypothetical harbors
discussed in Sections 4.3.3 and 4.4 , respectively. EPA calculated th e estimated harbor dilution
for each mo del scenario using the following equation:

D x 

## = ( V / t )/  ( Q y, z 

## * N y,z 

## * P y,z 

## ) Equation 4-9

Where:
D x 

## = Harbor dilution at location x
V = Volume of model harbor

t = Model harbor flushing time
Q y,z 

## = Flow rate for discharge y from vessel class z (volume/time)

N

y,z 

## = Number of vessels in vessel class z discharging discharge y
P

y,z 

## = Percent of vessels in vessel class z discharging discharge yChapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 392 Table 4.5.1. Fraction of Freshwater Model Scenarios

Model Scenario Total Loading Rate ( W e 

### ) Scenario Hypothetical Harbor Scenario Dilution ( D x 

### )

Model Scenario 1 Vessels Population Scenario 1 Fishing Harbor Harbor Scenario 1 705
Model Scenario 2 Vessels Population Scenario 1 Fishing Harbor Harbor Scenario 2 5,810
Model Scenario 3 Vessels Population Scenario 1 Fishing Harbor Harbor Scenario 3 705
Model Scenario 4 Vessels Population Scenario 1 Fishing Harbor Harbor Scenario 4 5,810
Model Scenario 5 Vessels Population Scenario 1 Fishing Harbor Harbor Scenario 5 1,570
Model Scenario 6 Vessels Population Scenario 1 Fishing Harbor Harbor Scenario 6 12,900
Model Scenario 7 Vessels Population Scenario 1 Fishing Harbor Harbor Scenario 7 1,570
Model Scenario 8 Vessels Population Scenario 1 Fishing Harbor Harbor Scenario 8 12,900
Model Scenario 9 Vessels Population Scenario 2 Metropolitan Harbor Harbor Scenario 1 506
Model Scenario 10 Vessels Population Scenario 2 Metropolitan Harbor Harbor Scenario 2 4,170
Model Scenario 11 Vessels Population Scenario 2 Metropolitan Harbor Harbor Scenario 3 506
Model Scenario 12 Vessels Population Scenario 2 Metropolitan Harbor Harbor Scenario 4 4,170
Model Scenario 13 Vessels Population Scenario 2 Metropolitan Harbor Harbor Scenario 5 1,130
Model Scenario 14 Vessels Population Scenario 2 Metropolitan Harbor Harbor Scenario 6 9,280
Model Scenario 15 Vessels Population Scenario 2 Metropolitan Harbor Harbor Scenario 7 1,130
Model Scenario 16 Vessels Population Scenario 2 Metropolitan Harbor Harbor Scenario 8 9,280
Model Scenario 17 Vessels Population Scenario 3 Recreational Harbor Harbor Scenario 1 494
Model Scenario 18 Vessels Population Scenario 3 Recreational Harbor Harbor Scenario 2 4,070
Model Scenario 19 Vessels Population Scenario 3 Recreational Harbor Harbor Scenario 3 494
Model Scenario 20 Vessels Population Scenario 3 Recreational Harbor Harbor Scenario 4 4,070
Model Scenario 21 Vessels Population Scenario 3 Recreational Harbor Harbor Scenario 5 1,100
Model Scenario 22 Vessels Population Scenario 3 Recreational Harbor Harbor Scenario 6 9,050
Model Scenario 23 Vessels Population Scenario 3 Recreational Harbor Harbor Scenario 7 1,100
Model Scenario 24 Vessels Population Scenario 3 Recreational Harbor Harbor Scenario 8 9,050



## As shown in Table 4.5.1, there are duplicate dilution factor values for different model scenarios (e.g., Model Scenarios 1 and 3 both have a dilution fact or of 705). Hence, there are effectively 12 unique model scenarios and not 24 pr esented in this screening-level analysis. The duplicate dilution factors are an artifact of EP A’s decision to calculat e dilution factors and
instantaneous harbor con centrations using all combinations of the input parameters in Table 4.4.2. In calculating the dilution factor , the volume of the harbor ( V ) cancels out of the dilution equation (Equation 4-9) and is not a consideration (see below).

D x 

## = ( V / t )/  ( Q y, z 

## * N y,z 

## * P y,z 

## )

Where: ( V / t ) = (V/(V*f
x 

## /Q fw 

## )

 ( Q y, z 

## * N y,z 

## * P y,z 

## ) = Total discharge flow from all vesselsChapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 393 EPA used three total discharge flows (  ( Q y, z 

## * N y,z 

## * P y,z 

## ) (i.e., vessel flows in a fishing harbor, large metropolitan har bor, and recreational harbor) an d four different volume-toflushing-time (V/t) ratio s (i.e., assumed two f
x 

## values in the model and two Q fw 

## values) in the model. Section 4.6 discusses the results from the 12 unique model scenarios and presents the results of the duplicate scenarios as one result (i .e., harbor concentrations from Model Scenarios 1 and 3).



## 4.6 M ODEL 

## R ESULTS



## EPA calculated the instantaneous concentration ( C x 

## ) in the hypothetical harbor using Equation 4-5 presented in Section 4.2.4 for each of the 12 model scenarios defined in Table 4.5.1. Appendix G presents the concentrations for all m odel scenarios fo r each vessel population scenario. EPA compared the instantaneous concen trations in the hypotheti cal harbor with the NRWQC to evaluate the potential for the cumulativ e effect of study vessel incidental discharges to impact aquatic life or human health. EPA determined that none of the modeled concentrations in the hypothetical harbor for the 12 scenar ios exceeded an aquatic life or human health NRWQC.

4.6.1 Dilution Factor Analysis

The model scenario dilutions factors calcula ted for the 12 unique scenarios ranged from 494 to 12,900. EPA performed a sensitivity analysis to determine the dilution factor at which point NRWQC would be exceeded. EPA calcula ted the “tipping point” dilution in the hypothetical harbor where the inst antaneous concentration in the harbor would equal the most stringent NRWQC for aquatic life or human health using the three vessel population scenario loading rates discussed in Section 4.3.5 . Table 4.6.1 presents the tippi ng point dilution factors for the top 10 analytes with the highe st dilution factor requireme nts to avoid exceeding an NRWQC. Based on the results of the dilution analysis, a ha rbor dilution factor of greater than 358 is required to avoid exceeding any NRWQC for aquatic life or human health, which is below the range of calculated model scenar io dilution factors (i.e., 494 to 12,900). This sensitivity analysis also demonstrates that dissolved copper and total arsenic represent the most significant environmental risk from study vesse ls incidental discharges. Thes e two analytes have relatively stringent range of dilution requi rements depending on the vessel population scenario selected to avoid exceeding a NRWQC (i.e., di lution factors of greater than 144 to 266 for dissolved copper and 284 to 358 for total arsenic) and represent the highest di lution requirements for all the analytes detected in vessel discharges. Followi ng dissolved copper, the required dilution factors drop off significantly with a dilu tion of greater than 33.7 required to avoid exceeding all other NRWQC with most of the remain ing dilution factors below one.Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 394 Table 4.6.1. “Tipping Point” Dilution Factors for Harbor Instantaneous Concentration to Equal the NRQWC Ba sed on Vessel Population Scenario Loading Rates 1



### Class Analyte Vessel Scenario 1 Fishing Harbor

Dilution (D
x 

### ) Vessel Scenario 2 Metropolitan Harbor Dilution (D
x 

### ) Vessel Scenario 3 Recreational Harbor Dilution (D
x 

### )
Metals Arsenic, Total 2 

### 358 331 284
Metals Copper, Dissolved 214 266 144
Metals Arsenic, Dissolved 2 

### 31.4 33.7 29.6
Classicals Total Residual Chlorine 12.4 16.2 12.2
Metals Aluminum, Total 6.77 5.15 4.83
Classicals Sulfide 1.75 2.36 1.65
Metals Selenium, Total 2 

### 1.13 1.46 1.52
VOC Benzene 0.756 1.57 1.34

Metals Manganese, Total 0.684 0.983 1.04 (1) Table includes only those analytes that required a dilution factor of greater than one to avoid exceeding a NRWQC. (2) EPA suspects a limited number of the samples analyzed for selenium (and even fewer for arsenic) for bilgewater, packing gland effluent, propulsion engine effluent, graywater and deck washdown water may have elevated measured concen trations due to positive interference. Despite these limited instances of interference, EPA belie ves the fish hold concentrations reasonably represent true effluent concentrations for the discha rge (see discussion in Sections 3.1.3 and 3.2.4.1 for further information). EPA considered these in terferences when interpreting the potential for vessel discharges to pose a risk to human health , aquatic life, or the e nvironment and determined that such cationic interference does not influence the major findings presented in the modeling analysis.



## 4.6.2 Supplemental Model Run in Response to Comments

In response to public comments submitted for the draft version of this report, EPA performed a supplemental model run using revised values based on information submitted by commenters to assess the impacts of these alternative values on the model results. EPA adjusted the model assumptions presented in Table 4.6.2 and recalculated the associ ated discharge flows and loads. EPA observed no signifi cant change in model results based on the revised values. Table 4.6.3 presents the revised “t ipping point” dilution factors for the supplemental model run.

Table 4.6.2. Revised Model Assumptions

Vessel Class Vessel Subclass Discharge Old Assumption New Assumption

Fishing Gillnetter Fish Hold Offloads daily Offloads once per five days Fishing Longliner Fish Hold Offloads once per two days Offloads once per five days Fishing Toller Fish Hold Clean Offloads daily Offloads once per seven days Fishing Toller Fish Hold Offloads daily Offloads once per seven days Fishing Toller Fish Hold 840 ft 3 

### fish hold 595 ft 3 

### fish hold Fishing Toller Fish Hold 5.5 tons of ice per offload 2 tons of ice per offload Fishing Toller Deck Wash 125 gallons per deck wash 50 gallons per deck wash Fishing Shrimping Bilge Water 150 gallons per minute bilge pump rate 20 gallons per minute bilge pump rate Tour Boat NA Bilge Water 14.3 gallons per day 5 gallons per dayChapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 395 Table 4.6.3. Supplemental Model Run “Tipping Point” Dilution Factors for Harbor Instantaneous Concentration to Equal the NRQWC Based on Vessel Population Scenario Loading Rates 1



### Class Analyte Vessel Scenario 1 Fishing Harbor

Dilution (D
x 

### ) Vessel Scenario 2 Metropolitan Harbor Dilution (D
x 

### ) Vessel Scenario 3 Recreational Harbor Dilution (D
x 

### )
Metals Arsenic, Total 2 

### 349 325 279
Metals Copper, Dissolved 3 

### 225 273 147
Metals Arsenic, Dissolved 2 

### 31.1 33.6 29.5
Classicals Total Residual Chlorine 12.4 16.2 12.1
Metals Aluminum, Total 6.77 5.10 4.79
Classicals Sulfide 1.68 2.33 1.60
Metals Selenium, Total 2 

### 1.03 1.42 1.50
VOC Benzene 3 

### 0.790 1.61 1.37

Metals Manganese, Total 3 

### 0.696 0.997 1.05 (1) Table includes only those analytes that required a dilution factor of greater than one to avoid exceeding a NRWQC. (2) EPA suspects a limited number of the samples analyzed for selenium (and even fewer for arsenic) for bilgewater, packing gland effluent, propulsion engine effluent, graywater and deck washdown water may have elevated measured concen trations due to positive interference. Despite these limited instances of interference, EPA belie ves the fish hold concentrations reasonably represent true effluent concentrations for the discha rge (see discussion in Sections 3.1.3 and 3.2.4.1 for further information). EPA considered these in terferences when interpreting the potential for vessel discharges to pose a risk to human health , aquatic life, or the e nvironment and determined that such cationic interference does not influence the major findings presented in the modeling analysis. (3) The revised model assumptions (see Table 4.6.2) did not significantly impact the total loads for this analyte; however, these assu mptions lowered the total discharge volume from these vessels. Therefore, the dilution factors fo r the supplemental model run for this analyte are higher than the original model run due to the same mass loading rate being divided by a smaller total discharge flow.



## 4.6.3 Loading Rate Analysis

EPA compared the three analyte-specific lo ading rates used in the model with other known loading rates to provide pe rspective on their magnitude a nd on their relative contribution to the possible impairment of receiving waters (see Table 4.6.2 and Table 4.6.3). EPA selected the following loading sources for comparison:

 Loads From Publicly Owned Treatment Works (POTW)

 Dissolved copper loads discharged to the Shelter Island Yacht Basin

 Estimated metal loading rates from urban stormwater

EPA generated estimates for hypothetical medium -sized sewage treatm ent facilities with a discharge rate of 10 million gallons per day (MGD). These estimates were derived from theChapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 396 National Research Council’s 1993 report “Managing Wastewater in Urban Areas”. EPA calculated loadings by multiplying an effluent volume of 10 MGD times the low and high effluent concentrations for selected paramete rs using four types of wastewater treatment (chemically-enhanced primary plus biological tr eatment, primary or chemically enhanced primary plus nutrient removal, primary or chemically enhanced primary plus nutrient removal plus gravity filtration, or primary or chemically enhanced primary plus nutrient removal plus high lime plus filtration) 9 

## . Values presented in Table 4.6.2 present the lowest and highest derived loadings for these medium systems. EP A determined that the nutrient loads from the 175 to 300 study vessels were comparable to th e low end estimates for Ammonia as Nitrogen and total phosphorus, but notably lower than those from the high end treated effluent estimates from sewage treatment facilities. As noted a bove, the model nutrient loadings from study vessels do not include sewage discharges (which is lik ely a source of nutrients from these vessels) 10



## , whereas these data are from POTW effluent, whic h has a significant sewage component. Table 4.6.2 shows that a medium sewage treatment facility discharges a higher volume of metals than these 175 to 300 study vessels. Finally, these stud y vessels discharge comparable levels of BOD; though sewage treatment facilities are discharging a larger volume of effluent, they remove significant quantities of BOD from the effluent. On the other hand, study vessels’ incidental discharges are untreated waste, some of which has notably high BOD concentrations (e.g., fish hold effluent).

EPA also obtained nutrient loading estimates from a sewage treatment facility with advanced nutrient removal capabil ities to provide real world exam ple nutrient loadings that may be associated with POTW discharges (Albert, 20 07). This facility discharges approximately 40 to
50 MGD. EPA determined that the nutrient load s (i.e., ammonia as nitrog en, nitrate/nitrite as nitrogen, total Kjeldahl nitrog en, and total phosphorus) from the 175 to 300 study vessels used to establish the vessel loads in the screening-level analysis were notably lower than the nutrient loads from this sewage treatment facility. It is important to note that these model nutrient loads
do not include nutrient contributions from vesse l sewage discharges (possibly a significant source of nutrients), as sewage discharges are excluded from the scope of P.L. 110-299.

9 

### A number of systems exist which are both smaller and larg er than 10 MGD; for example, the Blue Plains POTW in Washington DC is the largest advanced wastewater treatment system in the word and discharges an average of approximately 330 MGD. The wastewater treatment faciliti es in nearby Arlington County discharge less than 40 MGD. In comparison, the sewage treat ment facility in Sitka, Alaska is designed to discharge only 1.8 MGD.

10 

### Sewage from vessels within the meaning of CWA s ection 312, which includes graywater in the case of commercial vessels operating on the Great Lakes, is exempt from the CWA definition of “pollutant”. 33 U.S.C. 1362(6); 33 U.S.C. 1322(a)(6). As a result, vessel sewage discharges are not subject to NPDES permitting. Instead, Congress enacted a separate non-permitting scheme – CWA section 312 – to regulate the discharge of sewage from vessels. Under section 312 of the CWA, all vessels equipped with installed toilet facilities must also be equipped with an operable U.S. Coast Guard-certified marine sanitation device (MSD). 33 U.S.C. 1322(h). The provisions of section 312 are implemented jointly by EPA and the Coast Guard: EPA sets performance standa rds for MSDs, and the Coast Guard is responsible for developing regulations governing the design, construction, certification, installation and operation of MSDs, consistent with EPA’s standards. 33 U. S.C. 1322(b). Current performance standards which apply to MSDs have standards for solid s and fecal coliform. Generally speaki ng, most MSDs currently installed on study vessels are not designed to remove nutrients from sewage.Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 397 Therefore, these estimates are not a complete repr esentation of vessel nutr ient loadings; rather, they are merely an estimate of nutrient loadings from incidental discharges.

As described in Chapter, 3 dissolved coppe r concentrations resu lting from study vessels’ incidental discharges potentially pose a risk to aquatic life. A signifi cant contribu tion of the dissolved copper load is from copper leaching fr om antifouling coatings on vessel hulls. In 2005, the California Regional Water Quality Control Board examined the dissolved copper loads to
Shelter Island Yacht Basin from recreational ve ssel antifouling hull coatings and other source loads in support of a Total Maximum Daily Load (TMDL) analysis for the impaired water. EPA compared the dissolved copper loads from Sh elter Island Yacht Basin TMDL to the vessel population scenario loading rate s (Table 4.6.2). EPA determined that the estimated dissolved copper loads from 175 to 300 study vessels used in the model (i.e., 2.75 to 4.97 lb/day) were consistent with the combined dissolved copper loads from passive leaching and hull cleaning from 2,363 recreational vessels pres ent in Shelter Island Yacht Basin (i.e., 12.7 lb/day). EPA also compared the model dissolved copper loads to th e combined estimated contributions from urban runoff, background, and atmospheric deposition in Shelter Island Yacht Basin (i.e., 0.381 lb/day). The model dissolved copper loads from hull leaching and other discharge streams were significantly larger than the other source contri butions present in Shelter Island Yacht Basin, suggesting that dissolved copper from study vesse ls incidental discharges can represent a significant portion of the dissolved copper load in a water body.

EPA also estimated metal loading rates fo r urban stormwater r unoff based on reported loading rates from a 2001 literature study by Davi s et al. and an assumed watershed area of approximately 17 square miles (watershed area de termined from readily available information on watersheds’ drainage areas for the water bodie s discussed in Table 4.4.1) . As shown in Table 4.6.2, EPA determined that urban stormwater likely represents a greater load of total copper, total lead, zinc, and cadmi um to receiving waters than discharges from 175 to 300 study vessels. However, the model results indicate that dissolved copper loads from study vessels are significant.Chapter 4 – Potential Large Scale Impacts of Study Vessels Incidental Discharges to Human Health and the EnvironmentTable 4.6.4. Comparison of Model Loading Rates withOther Potential Point Source Loading RatesModel Loading Rates fromVessel Population Scenarios1Shelter Island Yacht Basin Loading Rates4,5,6AnalyteFishingHarbor(lb/day)LargeMetropolitanHarbor(lb/day)RecreationalHarbor(lb/day)POTWLoadingRates10mg/day2(lb/day)POTWLoadingRates~40mg/day3(lb/day)PassiveLeaching(lb/day)HullCleaning(lb/day)UrbanRunoff(lb/day)Background(lb/day)AtmosphericDeposition(lb/day)EstimatedUrbanRunoffLoadingRates7(lb/day)Ammonia asNitrogen(NH3-N)8.526.075.078.35-41.736.2NANANANANANABiochemicalOxygenDemand (BOD)635481392250.4-751.1NANANANANANANANitrate/Nitrite(NO3 + NO2-N)0.1270.2030.102NA1,320NANANANANANATotalPhosphorus13.88.917.748.35-125.222.0NANANANANANATotal KjeldahlNitrogen(TKN)97.868.559.0NA285NANANANANANAArsenic, Total0.02790.03590.03150.117-1.17NANANANANANANACadmium,Total0.0007490.0006570.0005510.117-0.609NANANANANANA0.032Copper,Dissolved2.884.972.75NANA12.10.6040.1810.1810.0181NACopper, Total0.1580.1790.1651.25-4.17NANANANANANA1.0Lead, Total0.01080.01540.01421.50-4.01NANANANANANA1.8Zinc, Total0.7580.6130.5163.34-9.35NANANANANANA17NA- Not available.(1) Model loading rates do not include contributions from study vessel sewage waste streams as these discharges are not coveredunder P.L. 110-299.(2) Estimated loadings from concentrations for medium sewagetreatment facilities (~10 mg/d) derived from concentrations presented in National Research Council (1993).(3) Estimated nutrient loads from an actual sewage treatment facility with advanced nutrient removal capabilities with an average of approximately 40 mgd discharge (Albert, 2007).(4) Estimated point source loads to Shelter Island Yacht Basin (California Regional Water Quality Control Board, 2005).(5) Passive leaching and hull cleaning loading rates were based on an assumption of 2,363 recreational vessels present in Shelter Island Yacht Basin.(6) Urban runoff contributions were based on a watershed area of0.84 mi2 draining to Shelter Island Yacht Basin, and the atmospheric deposition loads were based on a surface area ofShelter Island Yacht Basin of 0.27 mi2.(7) Estimated urban stormwater loads werebased on loading rates presented in Davis etal., 2001 and an assumed watershed area of 17 mi2 (MA DEP, 2006).The loading rates presented are average annual daily loads.398Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 4.7 C ONCLUSIONS



## This screening-level analysis evaluated the potential for di scharges incidental to the normal operation of vessels to pose a risk to human health, welfare, or the environment in large water bodies. The analysis in cludes all sizes of commercia l fishing vessels and other
nonrecreational vessels less than 79 feet in length. EPA selected a Level I screening-level model (see Section 4.1 ) to help assess the potential impacts fr om study vessels’ incidental discharges
and m odeled several scenarios combining different vessel assemblages and different hypothetical harbors to represent a range of environmental conditions poten tially observed in harbors across
the United States. The modeled constituent conc entrations from the discharges into the hypothetical harbor for the 12 scenarios did not exceed an aquatic life or human health NRWQC solely from study vessel discharges; however , the model did not account for background loadings. Certain pollutants (e.g., arsenic and dissol ved copper) are more likel y to contribute to a water quality criterion being exceeded under real -world conditions. Furthermore, the model’s capabilities do not allow for the evaluation of whether these disc harges cause localized impacts (see Section 4.2 ), nor do they allow an analysis of issues such as bioaccumul ation or persistent toxicity in wa ter bodies or accumulation of pollutants in sediments.

As discussed in the introduction, EPA’s fraction of freshwater analysis is only intended to
evaluate environmental effects from vessel discha rges at the water body or harbor scale and does not address the environmental effects that could potentially occur in localized areas such as small side embayments or marinas. As discussed in Section 4.1 , the “fraction of freshwater model” does not describe concentration gr adients within plumes from ve ssels. Accounting for spatial and

tem poral variability in a harbor would require a more data intensive dynamic model and is beyond a Level I screeni ng-level model. EPA acknowledges that incidental discharges from study vessels may pose an environmental threat in confined areas with low receiving water flushing rates and a large populati on of vessels. In the dilution an alysis discussed in Section 4.6

, EPA determined that a “tipping po int” dilution factor of greate r than 358 would be required to avoid exceeding any NRWQC based on the estimated loading rates used in the model (see Table 4.6.1). These results suggest that the loading rates represente d in the model may have the potential to cause a water quality criterion to be exceeded on a localized scale either before complete mixing is achieved in the receiving wa ter (i.e., as the plume dissipates) or if the discharges are released in a receiving water with a dilution potential of lower than 358. The model further suggests that these vessels may be more likely to contri bute to an NRWQC being exceeded (particularly where the diluting factor is high for a pollutant) where the ambient concentrations or other sources of pollutants are significant. On the other hand, EPA has tended to use conservative estimates of some parameters (e.g., flow and pollutant concentrations) in its modeling.

In the “fraction of freshwater model,” EPA calculated the instantaneous concentration in the hypothetical harbor based solely on pollutant contributions from discharges from study

399Chapter 4 – Potential Large Scale Impacts of Study Vessels In cidental Discharges to Huma n Health and the Environment



## 400 vessels. Although the assumption that harbor background pollutant con centrations are zero for all analytes is likely unrealistic, removing other loading considerations from model calculations allows for the assessment of the potential for study vessel incidental discharges alone to cause an NRWQC to be exceeded. Although the “fraction of freshwater model” results suggest that study vessels’ incidental discharges wi ll not cause an environmental im pact on their own, the fact that pollutants are present in the vesse l discharges at concentrations that exceed the NRWQC at endof-pipe may support a determination that some of these discharges ha ve the potential to contribute to a water quality standard exceedence.

Based on the dilution results, the two pollutant s that represent the greatest risk for contributing to an environmental effect or wate r body impairment are total arsenic and dissolved copper. EPA determined that the loading rate s from the metropolitan harbor (i.e., Model Scenarios 9 and 11) were at the greatest risk of exceeding the NRWQC for these pollutants. However, the minimum dilution factors requir ed to avoid exceeding the NRWQC for these pollutants (i.e., 284 for total arsenic and 144 for di ssolved copper in the r ecreational harbor) are
similar to the lowest dilution f actor represented in the hypothetic al harbor scenarios (i.e., 494). This suggests that study vessel’s in cidental discharges may be c ontributing a significant load of these two pollutants to the wa ter body. Given the right enviro nmental conditions (i.e., low flushing) or pollutant loadings from other point/nonpoint sources (e.g., recreational vessels, large commercial vessels, stormwater runoff, and industrial and municipal point sources), the concentrations of these pollutants may have a poten tial to cause or contribute to an exceedence of the NRWQC, regardless of vessel class distribu tions. These results are consistent with realworld observations that metals ar e frequently associated with vesse l discharges in concentrations of potential environmental concern (see Chapter 3) . In particular, environmental impacts from dissolved copper leaching from hull coatings has been well documented in low flushing
environments such as Shelter Island Yacht Basin near Sa n Diego, California, and Marina Del Rey Harbor in Los Angeles, California.

Nutrients from study vessels’ incidental dischar ges represent another pol lutant class with the potential to contribute to deleterious environmenta l effects. Nutrients differ from other pollutants present in vessel discharges in that the environmental effects are driven by sitespecific environmental conditions (e.g., water te mperature, types of algae present, limiting nutrient). For example, the estimated nutrient load s used in the modeling analysis may contribute to an environmental effect in one water body, bu t not another depending on a variety of factors that control eutrophication. EPA has not deve loped an NRWQC for nutrients; however, some
states have established water- body-specific or state-wi de standards for nutrients based on sitespecific evaluations.Chapter 5 - Summary of Findings



# CHAPTER 5

S UMMARY OF FINDINGS

This chapter summarizes the major findings of EPA’s detailed analyses described in Chapters 1, 3, and 4. It describe s findings on vessel classes th at are covered by this study. It summarizes major findings from the characterizati on of select discharges from the study vessels, including EPA’s interpretation of these findings in the context of the level of potential risk from these pollutant loadings . Additionally, it discusses major fi ndings of EPA’s assessment of the predicted impacts of these disc harges to a hypothetical harbor. This chapter also briefly summarizes possible benefits to human health, welfare, and the environment from reducing, eliminating, controlling, or mitigating discharges from study vessels.



## 5.1 S UMMARY OF 

## C LASSES OF 

## V ESSELS 

## C OVERED 

## B Y THIS 

## S TUDY



## EPA estimates there is a population of a pproximately 140,000 study vessels. According to the U.S. Coast Guard’s Marine Information for Safety and Law Enforcement (MISLE) database, there are approximately 70,000 commercial fishing vessels op erating in the United States. These vessels represent the largest cate gory of study vessels. Pa ssenger vessels comprise the second highest number of vessels within the study population, with approximately 21,000 vessels. These vessels are further classified by su btypes according to the types of activities in which they are involved, such as diving vessels, charter fishing vessels, ferries, harbor cruise vessels, and sailing vessels. The study population also include s over 11,000 utility vessels, including tugs/towing vessels, school ships, research vessels/ships, mobile offshore drilling units, offshore vessels, offshore supply vessels, oil r ecovery vessels, and industrial vessels. Other vessel categories such as freight barges (approximately 8,000 vessels), tank barges (approximately 900 vessels), frei ght ships (approximately 800 ve ssels), unclassified public vessels (approximately 600 vesse ls), and tank ships (approximat ely 200 vessels) account for the remainder of other non-recreational study vesse ls. An additional 27,375 vessels in the MISLE database are also believed to be study vessels; ho wever, the database does not indicate their type of service. See Chapter 1 for additional discussions of the study vessel and recreational vessel populations.



## 5.2 S UMMARY OF 

## E FFLUENT 

## C HARACTERIZATION OF 

## S ELECT 

## D ISCHARGES

FROM THE 

## S TUDY 

## V ESSELS



## The major findings of EPA’s analysis of the vessel discharge characterization data for study vessels are summarized below. For this study, EPA sampled 61 vessels in nine states generating over 22,000 data points. EPA tested for 301 analytes and detected 154 of these analytes in at least one sample; therefore, 158 of the tested analytes were never found in the

401Chapter 5 - Summary of Findings



## discharges. Section 5.2.1 discu sses the estima ted volumes of the discharges and Section 5.2.2 discusses the detected pollutants that may have the potential to pose a risk to human health or the environment. See chapters 3 and 4 for more t echnical, in-depth discus sions of these results.

5.2.1 Estimated Volumes of Select Discharges from the Study Vessels

EPA estimated volumes for each discharge from the study vessels based on data and field observations from EPA’s vessel sampling efforts, as well as information from secondary data sources. Discharge volumes are im portant to both characterize the discharge and to analyze the potential risk of the pollutant concentrations discharged from vessels. EPA also used these discharge volumes to calculate fl ow rates for the modeling of pollu tant loadings to a hypothetical harbor in Chapter 4.

Bilgewater generation rates are highly variable. EPA observed as little as 2 gallons of bilgewater discharged from a tow/salvage vesse l following a tow activity to as much as 750 gallons of bilgewater discharged during the da ily bilge pump-out from a 62-foot shrimp boat from the Gulf of Mexico. In general, based on observations from dozens of vessel operations, EPA estimates that small (less than 79 feet), nonrecreational vessels typi cally generate between 10 and 15 gallons per day (gpd) of bilgewater.

Stern tube packing gland effl uent is by nature limited to the small amount of water needed to provide cooling and lubrication to the gland around the drive shaft. The range in estimated discharge for stern tube packing gl and effluent is approximately 4 to 8 gpd.

For deckwash water from tour boats, wate r taxis, and tow boats, EPA estimates a discharge volume of between 20 and 30 gpd. Fish ing boats are estimate d to generate more deckwash water and the volumes generated vary with the type of boat. Trollers, trawlers, gillnetters, and purse seiners may wash their d ecks three to four times per day while fishing, producing as much as an estimated 750 to 900 gpd of deckwash water.

The volume of fish hold effluent generated by a fishing vessel depends on the size of the vessel and the method used to keep the product fresh. Smaller fishing vessels such as small salmon trollers or long-liners may discharge an estimated fish hold volume ranging from 70 to 200 gpd. Mid-size fishing vessels, su ch as gill netters and purse seiners found in Alaska and shrimp boats in the Gulf of Mexico may discharge approximately 333 to 1,000 gpd. Larger fishing vessels such as off-shore trawlers f ound in New England and tenders found in Alaska, however, can have refrigerated seawater holding tanks or i ce hold tanks as large as 15,000 gallons. These vessels are expected to offload s eafood and discharge the fish hold effluent every three to five days, resulti ng in an estimated flow rate ranging from 900 to 2,000 gpd. EPA estimates the volume of fish hold cleaning effluent discharged by certain fishing vessels to be anywhere from 300 to 400 gallons per cleaning, whic h occur typically every three to five days

402Chapter 5 - Summary of Findings



## when the fish holds are emptied (discharge volumes range from an estim ated 60 to 200 gpd depending on frequency of offloading).

Fisherman unloading their catch to the dock from a trawler (dragger) in Massachusetts.



## Graywater volumes also vary considerably de pending on the class of vessel and its use, size, number of crew and passengers onboard, an d types of graywater-generating activities onboard (e.g., galleys, sinks, showers, and washing machines). For example, EPA estimated that tugboats, some of which provide living quarters for three to five crew members, generate approximately 130 gpd of graywater. Water taxi s typically have considerably more people onboard, but less graywater is gene rated per person because the disc harge is typically limited to bathroom sinks with an estimated 75-gpd di scharge. Graywater generation on commercial fishing boats might range from a few to hundred s of gpd, depending on the length of the trip and
the size of the crew.

Finally, the volume of engine effluent discharged depends on the type of engine and power level of operation. Vessels with outboard propulsion engines are es timated to discharge between 1 to 2 gallons per minute (gpm) of ra w cooling water per engi ne. The cooling water discharge rate from inboard marine diesel engi nes varies based on power levels, but typically averages around 20 gpm for the study vessels . Marine diesel generator sets require approximately 5 to 6 gpm of cooling water for sm aller units, and up to 20 to 25 gpm of cooling water for larger marine generator sets. Daily di scharge rates for these engines are a function of the daily operating time.

403Chapter 5 - Summary of Findings



## 5.2.2 Analytes of Potential Risk in Se lect Discharges from Study Vessels

EPA compared the measured concentration of any given analyte to its most stringent
benchmark 1 

## (Table 3-1) as one means to identify pollu tants in vessel discharges that may have a potential to pose a risk to huma n health or aquatic life. EPA di vided the concentration of an analyte by its corresponding benchmark to calculate a potential h azard quotient (PHQ). If a PHQ is less than 1, there is less of a concern that the pollutant in the discharge will have impacts to human health or aquatic life. An exception to this determination is when the pollutant is persistent and/or bioaccumulative and may increa se in concentration within the ecosystem food chain to harmful levels. If a PHQ is equal to or greater than 1, then there is more of a concern. However, PHQs of greater than 1 do not provide conclusive eviden ce of risk to human health or the environment for the following reasons:

1. Samples were collected at the “end of pipe” as the vessels discharged into larger waters (e.g., harbors, rivers). However, the disc harge is typically diluted in the water body. Therefore, accounting for possi ble dilution in the receiving water could result in ambient PHQ of less than 1 (except possibly small har bors or marinas with limited or no flushing or where the receiving water PHQ is alre ady above 1 due to other factors).

2. The benchmarks used to evaluate the potential for risk were always the most protective, even if it was not the most commonly applicab le screening benchmark for that particular analyte. Given this, the potential for risk might be over-stated.

3. The surrounding ambient water or source water (vessel service 2 

## or city water supply) used in the vessel systems that generated th ese discharges (e.g., engine cooling water drawn from ambient water or potable water us ed for deck cleaning) may already contain high concentrations of some of these an alytes. In these instances, a high analyte concentration measured at the “end of pipe” may not originate from vessel activities, but rather from the water used in these operations.

EPA made the following general observations based on its review of the vessel discharge data (see Chapter 3 for EPA’s detailed analysis of the data):

 Dissolved copper was the analyte detected in vessel discharges at concentrations that consistently posed the greates t potential risk for local im pacts and for contributing to exceedances of water quality standards in la rger water bodies. Copper is a heavy metal that can restrict the growth and reproduc tion of plants and algae and can produce both acute (short-term) and chronic (long-term) toxic effects on reproduction, growth, and

1 

### To provide a context for the level of contaminant concentrations presented, EPA used National Recommended Water Quality Criteria (NRWQC) and several other benchmarks as a preliminary screen for all discharge data with the potential to cause or contribute to the nonattainment of a water quality sta ndard in a given receiving water body.

2 

### Service water here means the vessel potable water supply. For study vessels, vessel service water generally originates from municipal water supply rather than produced on board.



## 404Chapter 5 - Summary of Findings



## survival in fish and shellfish. Prolonged e xposure to elevated copper concentrations can lead to long-term liver and kidney dam age in humans. Concentrations of dissolved copper exceeding the most protective screeni ng benchmark were found in at least some samples for every sampled discharge type, except for outboard engine and generator engine effluents.

Dissolved copper was detected at the highe st concentrations in the deck washdown, graywater, fish hold, and bilgewater discharg es from most vessel classes, particularly utility vessels (e.g., towboats, supply boats ). PHQs for mean dissolved copper concentrations ranged from a low of 1.1 in graywater discharges to a high of approximately 200 in fish hold effluent. Ba sed on concentration and average discharge volume, deck washdown and fish hold discharges contribute the most dissolved copper.

Copper is released (leached) from antifouli ng hull coatings used on certain vessels to prevent buildup of organisms such as barnacle s and algae. Copper can also be released via underwater hull cleaning, hull coating removal operatio ns, and paint application. Although copper antifouling discharges were not measured, previous studies have shown it can be a major contributor to copper concentr ations in harbors, especially marinas with large vessel populations (see Section 3.2.8.1).

Average ambient dissolved coppe r concentrations in the harbors sampled in this study were also slightly higher than the mo st protective benchmark (mean PHQ of 1.6). However, discharge concentrations still exce eded the benchmark ev en after subtracting the potential contribution of copper from ambient waters.

 Total arsenic 3 

## concentrations in vessel discharges were also notably higher than the most protective screening benchmark. In samples wh ere arsenic was detected, PHQs for mean total arsenic concentrations ranged from a low of 110 in graywater disc harge to a high of 2,900 in bilgewater discharge. Arsenic is a metalloid (a nonmetallic element with some metal properties) that is easily absorbed by aquatic plants, algae, fish, and shellfish. Arsenic can cause a variety of acute and chr onic toxic effects in a quatic organisms, as well as in humans who inge st arsenic via drinking wate r and contaminated seafood. Arsenic is a known carcinogen, and prolonged high exposures via ingestion can cause cancer, skin irritation, kidne y and liver damage, and neurological damage.

Despite the high potential toxicity of total arse nic, the risk posed to aquatic life is lower than what is suggested by this analysis fo r two reasons. First, th e screening benchmark
for total arsenic is a human h ealth criterion to prevent can cer-causing agents in drinking
water and is over 100 times lower than that of any other metal in this study. The high

3 

### See discussion in Section 3.1.3 regarding potential positive interference which may have resulted in elevated measured concentrations of arse nic for a subset of samples.



## 405Chapter 5 - Summary of Findings



## total arsenic PHQs in vessel discharges are the result of this low benchmark for hum an health, which is 2,000 times lower than the di ssolved arsenic benchmark that is based on chronic, long-term toxicity to saltwater aquatic life. Many of the waters where many study vessels operate, particularly for certain vessel types such as commercial fishing vessels, are not typically used as drinking wa ter sources (i.e., ocean and coastal waters). However, some waters where study vessels operate (e.g., the Missi ssippi River) do serve as drinking water sources and high arsenic load ings in these waters could contribute to
human health concerns.

Second, between 20 to 100 percent of the tota l arsenic measured in the various vessel discharges can be attributed to ambient wa ter that is used as source water for vessel systems. Vessel discharges most influenced by ambient total arsenic concentrations
include those from stern tube packing glands, outboard engi nes, and firemain systems. However, less than half of the total arsenic measured in bilgewater, deckwash, and fish hold discharges appears to be contributed by concentrations in ambient water, indicating that these discharges potentially contribute to arsenic toxicity in receiving waters. Based on concentration and average discharge volume, deck washdown and fish hold discharges appear to contribute th e most total arsenic.

 Total aluminum concentrations exceeded be nchmark concentrations in at least some samples for all discharge types; however, some of the aluminum concentrations in the discharge may be due to background concentrat ions (e.g., not added to the discharge by the vessel). Average PHQs for total alum inum ranged from a high of 39 in deck washdown discharge to a low of 1.8 in outboard engine effluent. The metalloid aluminum is most toxic to aquatic organisms in acidic conditions (i.e., waters with a pH < 7). When pH is neutral (7) or higher, aluminum can stil l inhibit growth of aquatic organisms but to a lesser extent. The pH measured in the vesse l discharges and ambient water sampled in this study was generally 7 or hi gher. Chronic exposure to hi gh concentrations can cause aluminum to accumulate in bones of fish (and humans) and lead to loss of kidney
function.

Indications are that the potenti al risk from total aluminum is greatest in deck washdown discharges, followed by fish hold discharg es, and then stern tube packing gland discharges. For deck washdown, there is an el evated risk because of the high aluminum concentrations (possibly from the leaching of the abundant amount of aluminum found on the surfaces of many vessels), as well as the potentially la rge discharge volume (up to 900 gpd). Fish hold discharge also contains high total aluminum concentrations with discharges up to 1,000 gpd. Although concentrations in the stern tube packing gland discharge are nearly as high as those in fish hold effluent, potential for risk from stern tube packing gland effluent is lower due to the lower volume of the discharge.

406Chapter 5 - Summary of Findings



## Ambient concentrations of total alum inum were high (ranging from 29 to 3,950 μg/L – see Appendix E) in all of the sampled har bors for this study. The average concentration of total aluminum in ambient water is highe r than the average c oncentration of total aluminum for all discharge t ypes except for deck washdown, fi sh hold effluent, and stern tube/packing gland e ffluent. For fish hold 4 

## and stern tube packing gland discharges, it appears half of the measured total aluminum likely originates from the ambient water. Deck washdown discharge from vessels that use ambient water to clean decks have an estimated 20 percent of the measured tota l aluminum concentrations contributed by ambient water. In contrast, only 2 percent of the measured total aluminum concentrations were attributable to backgr ound concentrations for vessels that used service water to clean their decks (primarily tugboats/utility vessels).

 Concentrations of other metals such as to tal iron and manganese and dissolved cadmium, lead and zinc above their respective scr eening benchmarks were measured in some samples of deck washdown effluents (PHQs ranging from 1 to 11). These heavy metals are all known to produce acute and chronic toxic effects in aquatic organisms and humans, in the following order: cadmium is more toxic than lead, which is more toxic than zinc, which is more toxic than iron. Thes e elevated concentrations were particularly prevalent in the deck washdown discharges from utility vessels. However, decks of utility vessels (tugboats) are washed less frequently than fishing vessel decks, so overall metal loads from the two types of vessels are more comparable than concentrations alone might suggest. Although background concentrations of these metals in the ambient and service waters used to wash decks were generall y low (except for dissolved zinc in some background samples), average PHQs of all thes e metals in vessel discharges were not significantly greater than 1, indicating that these metals likely pose minimal potential risk
to the environment.

 Total phosphorus concentrations were elevat ed in some samples of bilgewater, deck washdown, fish hold, and graywater discharg es. Average PHQs for total phosphorus in these discharge categories ranged from a high of 130 in fish hold effluent to a low of 14 in graywater. Total phosphorus in some vesse l discharges comes from detergents and soaps. Other total phosphorus loadings come from decaying seafood (in fish hold) or leftover food (graywater). Based on concentr ation and average disc harge volume, fish hold effluent contributes the most total phosphorus.

Phosphorus is an important macronutrient limiting reproduction and growth of plant material and algae (so called “primary produc tion”). Elevated leve ls of phosphorus can

4 

### The assertion that background concentrations contribute approximately half of aluminum concentrations for fish hold effluent assumes that vessels either took in the origin al fish hold water from the surrounding harbor waters, or that the fishing grounds where the vessel took in the fish hold water share similar characteristics with surrounding harbor waters.



## 407Chapter 5 - Summary of Findings



## contribute to nuisance algal blooms, eutroph ication (nutrient enrichm ent), and low dissolved oxygen levels in the water column (hypoxia). Ambient concentrations of total phosphorus, averaged across all sampled harbor s, were twice the concentration of the PHQ screening benchmark.

 The concentrations of reactive nitrogen compounds (e.g., nitr ate, nitrite, ammonia) and the parameter TKN were generally not significa ntly elevated; except for in fish hold and fish hold cleaning effluents. Concentrati ons of ammonia exceed the most stringent recommended acute aquatic life criterion. Conc entrations of TKN also exceeded the most stringent screening value. TKN in fish hold and fish hold cleaning effluent were also typical of concentrated raw sewage.

 Biochemical oxygen demand (BOD) and chemi cal oxygen demand (COD) were elevated in bilgewater, deck washdown, fish hold, a nd graywater discharges. BOD and COD are measures of oxygen-demanding substances pr esent in the discha rges (e.g., organic matter) that can contribute to hypoxia (low dissolved oxygen) in receiving waters. Average BOD concentrations were highest in fish hold effluents (as high as 25 times the concentrations in raw sewage), followed by graywater and then bilgewater and deck
washdown water. The BOD levels in fish hold effluent and graywater are comparable to
BOD concentrations in raw sewage. Fish hold effluent also has a relatively high discharge volume, so this discharge can c ontribute a significant BOD/COD loading to receiving waters, particularly when multiple vessels discharge at the sample location (e.g., pierside at a fish processing facili ty). Hence, depending upon receiving water characteristics, BOD and COD from fish hold effluent may significantly impact the local environment and contribute to water qua lity exceedances in receiving waters.

 Pathogen indicators, E. coli , enterococci, and fecal coliforms, were also found in elevated concentrations in some samples of bilgewat er and deck washdown (fishing vessels only), fish hold, and graywater discharg es. These three types of bact eria are all found in animal digestive tracts. Epidemiological studies s uggest a link between high concentrations of E.
coli and enterococci in ambien t waters and incidents of gastrointestinal illnesses associated with swimming. Accordingly, they are used as indicators of the possible presence of intestinal pathogens. The highest concentrations by far of all three pathogen indicators were found in graywater, with PHQs of around 1,000 for all three bacteria. The estimated discharge volume of graywater from study vessels, however, is relatively small (130 gpd maximum). Larger vessels with additio nal crew or passengers are expected to generate considerably more graywater (see EPA’s Cruise Ship Discharge Assessment Report, USEPA, 2008c). Fish hold effluent co ntained the second highe st concentrations of these pathogen indicators and may pose a potential level of ri sk considering the relatively high volume of this discharge and possible discharge by multiple vessels in the same location. However, EPA notes that most of the pathogen concentrations in fish hold

408Chapter 5 - Summary of Findings



## effluent were well below or similar to am bi ent water concentrations, and this study is
inconclusive as to whether fish hold effluent results in additional discharge of pathogen
indicators 5



## .

 The semivolatile organic com pound bis(2-ethylhexyl ) phthalate was f ound in elevated concentrations in some samples of bilgewat er, stern tube packing gland, deck washdown, firemain, and inboard engine and engine gene rator discharges. The highest PHQ of 59 for bis(2-ethylhexyl) phthalate was found in a bilgewater discharge sample. Even though bis(2-ethylhexyl) phthalate was found at elevated concentrations in multiple discharges, the overall frequency of detection was low and generally detected at concentrations just slightly above the benchmark. This compound is a plasticizer that is added to an everincreasing variety of plastics to provide flexibility and is the most common phthalate in the environment. Although no conclusive evidence exists demonstrating bis(2- ethylhexyl) phthalate affects humans, high conc entrations have been shown to feminize males of other species. Bis(2- ethylhexyl) phthalate was not an alyzed for in fish hold or graywater discharge samples.

 Benzene was the only volatile organic compound found with any frequency at concentrations above, but generally close to, the PHQ benchmark. Benzene is a known carcinogen that is a common constituent of fuel . Benzene can also be formed as a product of incomplete combustion of fuel. Elevated co ncentrations of benzene were detected in a bilgewater sample and in samples from both outboard engine and generator engine discharges.

 Long- or short-chain nonylphenol and octylphenol ethoxylates (two distinct subsets of alkylphenol ethoxylates) were dete cted in some samples of bilgewater, stern tube/packing gland, deck washdown, and graywater discharg es, and total nonylphenol was detected in one sample from bilgewater. Nonylphenols we re not analyzed for in samples of the remaining discharge types.

Nonylphenols (a term used generally here to identify a specific group of alkylphenols of potential human and environmental concern wh ich also includes th e octylphenols) are manmade organic compounds that are used in a wide variety of applications, such as the manufacturing of detergents , because of their surfactan t properties. Nonylphenols are synthetic estrogens, which means they can mi mic the natural vertebrate hormone estrogen

5 

### Fish hold water may also serve as a potential pathway fo r the spread of aquatic nuisan ce species (ANS). This might occur where fish and water are taken onboard in one place and then transported signific ant distances for sale or unloading and the water is discharged. Organisms discharged with the water may include parasites and commensals taken in with fish, as well as organisms taken in with water used for refrigerated seawater. EPA did not study the potential for these discharges to transport ANS; however, the Agency is identifying this as a potential area of concern that may warrant further research.



## 409Chapter 5 - Summary of Findings



## 410 and evoke an estrogen-like response. An exampl e of such a response is the disruption of male sexual development, causing female characteristics to emerge.

Commercial nonylphenol is most accurat ely described by CAS number 84852-15-3 (phenol, 4-nonyl-branched), but CAS nu mbers 104-40-5 (phenol, 4-nonyl-) and 25154- 52-3 (phenol, nonyl) have also been used to describe these compounds. The commercial nonylphenol mixtures tested that correspond with EPA’s criteria are those with CAS numbers 84852-15-3 and 25154-52-3. The analyte category named “total nonylphenol” in the database generated for this study is directly equivalent to the commercial mixture of nonylphenol isomers specified under CAS Number 84852-15-3, and thus is directly comparable to the NRWQC.

Total nonlyphenol (or NP) was not detected, exce pt in one bilgewater sample with a PHQ of 4. Long-chain nonylphenol and octylphenol et hoxylates were detected with far greater frequency, but these longer chain compounds ar e more water soluble and less toxic than NP. The long-chain nonylphenol and octylphenol ethoxylates will all degrade into NP over time; however, research is ongoing with regard to proportion and duration of the
conversion.

Table 5.1 summarizes the major findings discussed above.411Table 5.1. Analytes of Potential Risk by Discharge1Analyte GroupDischarge Type(Volume/vessel) Microbi ologicals Volatile a nd Semivola tile Orga nic Compounds Metals (dissolved) Metals (total) Oil an d Grease Classical Pollutants Nutrients Nonyl phenols 32CommentsBilgewater(2 to hundredsof gpd; averagebetween 10 and15 gpd)enterococci(detected inonly samplecollected –shrimpingboat;PHQ=124)Benzene(Detected in4 of 7samples –highest PHQ= 187;towboat)Bis(2-ethylhexyl)phthalate(detected in 4of 7 samples– non-fishingvessels only;PHQs up to59)Copper(detected in all of7 samples; PHQup to 113 - tourboat)Cadmium(detected in only1 sample; PHQvalue of 40 –tour boat).Arsenic(detected in all of7 samples; PHQs72 to 1,790)HEM(detectedin all of 7samples; onlyone samplewhere PHQexceeds factorof 2 – conc. =44 mg/L;towboat)Sulfide(detected in only 2samples; PHQ ashigh as 210 from afishing boat)TRC(highest conc. 0.16mg/L, tour boat;PHQ = 21)BOD/COD(elevated in 3 of 5samples; conc.roughly equivalent toraw sewage)Totalphosphorus(elevated in 3 of5 samples;highestPHQ=130 –longliner fishingboat)Long- andshortchain(NP insinglesampleshrimpingboat; PHQ= 4)Tour and tow/salvageboats (utility boats) tendedto have highestconcentrations of metalsand VOCs/SVOCsStern tubepacking glandeffluent(from 4 to 8 gpd)NABis(2-ethylhexyl)phthalate(detected in 3of 9 samples– max. conc.= 24 μg/L;PHQ = 20)Nickel(detected in 6 of9 samples;PHQs in 4samples from 13to 126)Copper(detected in 4 of9 samples;PHQs from 5 to30)Arsenic(detected in 3 of9 samples; PHQspossibly exceed250)TSS(detected in all of 9samples – maxconc. = 270 mg/L;PHQ = 9)HEM detected at a maxconc. = 67 mg/L; max SGTHEM = 56 mg/L – PHQsapprox. 4, respectively.No nonylphenol polyethoxylates (NPEOs)detected, only longer chainoctylphenolpolyethoxylates (OPEOs)indicative of contaminationfrom lubricants.412Table 5.1. Analytes of Potential Risk by Discharge1Analyte GroupDischarge Type(Volume/vessel) Microbiologicals Volatile and Semivolatile Organic Compounds Metals (dissolved) Metals (total) Oil and Grease Classical Polluta nts Nutrients Nonylphenols 32CommentsDeckwashdownand/or runoff(from 20 to 30gpd utility; 750to 900 gpdfishing)Fecalcoliform,enterococciE. coli(detected inall 5samplescollected -fishingvesselsonly.Concentrations of fecalcoliformhighest insamples;PHQs ashigh as 40)Copper(detected in 29of 31 samples -PHQs from 2 to65; highest forutility vessels)Zinc(detected in all of31 samples –67% of PHQsbetween 1 and10. Max. conc. of1,200 μg/L intugboat; PHQ =14)Lead(detected in 15of 31 samples –PHQs in 2samples from 10to 21)Cadmium(detected in 2 of31 samples –max. conc. = 22μg/L in tow boat;PHQ = 90)Arsenic(detected in 23 of31 samples;conc. from 4 to83 μg/L – PHQsfrom 200 to 4,000because very lowNRWQC)Aluminum(detected in 30 of31 samples –PHQs between7.5 and 150.Max. conc. of13,000 μg/L intugboat)Iron(detected in 18 of19 samples –PHQs between3.1 and 48. Max.conc. of 14,500μg/L in tugboat)Manganese(detected only intugboats andwater taxi –PHQs between1.2 and 13. Max.conc. of 12,800μg/L in watertaxi)2HEM(detected in 26of 29 samples –only 3 sampleswith PHQ > 2.Range ofconcentrations1.1 to a max of133 mg/L in atugboat)SGT HEM(detected in 22of 29 samples –only 1 samplewith PHQ > 2.Range ofconcentration0.91 to a maxof 84 mg/L in atugboat)BOD and COD(detected in 29 of 31BOD samples- allCOD samples;concentrationsroughly equivalent toraw sewage- allvessel types)TSS(detected in all of 32samples – PHQsbetween 1 and 17;max. concentrationsin tugboats)TRC(detected in 7 of 31samples - PHQsbetween 23 and 100.Max. conc. of 0.8mg/L in fish trollingboatTotalphosphorus(detected in all of31 samples;PHQ as high as220 in a tugboat)Concentrations of manydissolved metals in socalled “utility”or non-fishingvessels statistically highercompared with fishingvessels.Elevated concentrations oftotal arsenic, aluminumand iron stronglyinfluenced by surroundingambient waterconcentrations.TOC detected in all of 25samples at concentrationsfrom a low of 3.5 to a veryhigh 350 mg/L (tugboat).Bis(2-ethylhexyl)-phthalatedetected in only 1 sample(PHQ = 5.6).Only 3 of 29 vesselssampled had detectableconcentrations of NPEOsof the shortest chain(NP3EO) indicative ofdetergents; concentrationsranging from 0.80 to 29μg/L.413Table 5.1. Analytes of Potential Risk by Discharge1Analyte GroupDischarge Type(Volume/vessel) Microbi ologicals Volatile a nd Semivolatile Organic Compounds Metals (dissolved) Metals (total) Oil and Grease Classical Polluta nts

Nutrie nts Nonylphenols 32CommentsFish hold/Fish holdcleaningeffluent -Fishing vesselsonly(tens to severalhundred or a fewthousand gpd(or gallons perseveral daysdependent uponoffloadingfrequency)based on fishingvessel type andplatform)Fecalcoliform,enterococci(detected inonly 1sample wellaboveambientconcentrations; PHQs of8,900 and68respectively)NACopper(detected in 23of 26 samples -PHQs from 1 to300. Max. conc.of 921 μg/L inshrimper)Arsenic(detected in 16 of26 samples;conc. from 3.1 to380 μg/L – PHQsfrom 170 topotentially 21,000because very lowNRWQC)BOD and COD(detected in 24 of 26BOD samples- allCOD samples;medianconcentrations ofBOD and COD were440 and 940 mg/Lwith max of 5,100and 8,700 mg/Lequivalent tosewage sludge)Sulfide(detected in 7 of 25samples – PHQsbetween 5 and 80;max. concentrations= 0.16 mg/L in fishtrawler)TSS(detected in all of 26samples – PHQs of4 samples between17 and 37)DO(hypoxic, i.e.,≤2.0mg/L in 3 of 26samples – all purseseiners)Ammonia(detected in 25of 26 samples;conc. from 0.087to 160 μg/L –PHQ at maxconc. = 133)TKN(detected in 25of 26 samples;values indicativeof strongsewage)Totalphosphorus(detected in 25of 26 samples -all but 3 samplesresulting inPHQs above 10;highestPHQ=760)NALevel of detection of allanalytes similar in fish holdcleaning effluent, althoughconcentrations somewhatreduced.HEM detected at a maxconc. = 16 mg/L; PHQ = 1.414Table 5.1. Analytes of Potential Risk by Discharge1Analyte GroupDischarge Type(Volume/vessel) Microbiologicals Volatile a nd Semivolatile Organic Compounds Metals (dissolved) Metals (total) Oil and Grease Classical Pollutants Nutrients Nonylphenols 32CommentsGraywater(tugs – 130 gpd;taxis – 75 gpd;fishing – a few tofew hundredgpd)E. coli,Fecalcoliform,enterococci(detected in7 of 8samplescollected -concentrations of fecalcoliformgenerallyhighest inmixedshower/sinksamples;PHQs ashigh as1,000)NACopper(detected in all of8 samples -PHQs from 1.7to 90. Max. conc.of 280 μg/L intugboat)Zinc(detected in all of8 samples - max.conc. = 1,500μg/L in sinkwater from awater taxi; PHQ= 19)HEM(detected in allof 8 samples -4 samples withPHQ 2 or more.Concentrationsfrom 9.4 to amax of 100mg/L intugboats)SGT HEM(detected in 6of 8 samples –only 1 samplewith PHQ >2.Range ofconcentration1.3 to a max of35 mg/L from atugboat)Sulfide(detected in 5 of 8samples – PHQsbetween 4.8 and370; max.concentration = 0.73mg/L in tugboat)BOD andCOD(detected in all of 8samples; medianconcentration ofBOD and COD were260 and 440 mg/L,respectively withmax of 1,200 and4,000 mg/Lindicative of strongsewage)Totalphosphorus(detected in 8 of8 samples – allbut 3 PHQsabove 10;highest PHQ=34in tugboat)Only 1 of 8 vesselssampled had detectableconcentrations of NPEOsof the shortest chain(NP3EO) indicative ofdetergents; concentrationof 0.99 μg/L.415Table 5.1. Analytes of Potential Risk by Discharge1Analyte GroupDischarge Type(Volume/vessel) Microbiologicals Volatile a nd Semivola tile

Organic Compounds Metals (dissolved) Metals (total) Oil and Grease Classical Polluta nts Nutrients Nonylphenols 32CommentsPropulsionEngine Effluent– inboard(20 gpm – highpower)NAPAHs(6 probablecarcinogenicPAHsdetected insample froma recreationalvessel with agasolineengine.Measuredconcentrations result inPHQs from2,100 to4,800)Copper(detected in 12of 13 samples -PHQs from 3samples from 11to 17. Max. conc.of 53 μg/L insample fromwater taxi at idle)Temperature(high idle only;temperatureincreases of up to20oC)NANANote: Though therecreational vessel with thegasoline engine is not a“study vessel”, itrepresents EPA’s onlysamples from a gasolineengine. EPA assumesgasoline engines fromsimilarly designed studyvessels would have similarcharacteristics.PropulsionEngine Effluent– outboard(1 to 2 gpm)NABenzene(detected in 6of 6 samples– only onesample with aPHQ above10; value of28 based ona max. conc.of 62 μg/L insample fromresearchvesselaveragedfrom variablespeeds)NANA416Table 5.1. Analytes of Potential Risk by Discharge1Analyte GroupDischarge Type(Volume/vessel) Microbiologicals Volatile a nd Semivola tile Orga nic Compounds Metals (dissolved) Metals (total) Oil and Grease Classical Pollutants Nutrients Nonylphenols 32CommentsEngine Effluent- Generator(5 to 25 gpm)NABenzene(detected in 3of 5 samples– only onesample with aPHQapproaching10; value of 9based on amax. conc. of21 μg/L insample froma fire boat)NANAFiremainSystems(no volumeestimated- usedinfrequently)NACopper(detected in 4 of6 samples -PHQs from 3.8to 23; highest fora tour boat)NANANotes:(1) Generally includes analytes when a large proportion of thesamples have concentrations exceeding the NRWQC, when several ofthe samples have PHQs > 10, when a fewsamples result in PHQs greatly exceeding the screening benchmark (i.e., 100s to 1,000s), or, in the case of oil and grease andfor nonylphenol, when one or more samples exceed anexisting regulatory limit by more than a factor of 2. See textabove and in Section 3.1.3 for a definition of PHQs and Table 3.1 for screening benchmarks used tocalculate these values.(2) Longer chain nonylphenol and octylphenol ethoxylates degrade to shorter chained ethoxylatesunder aerobic conditions. In general, the shorter the chain, the more hydrophobic,persistent, and toxic the substance becomes.4-Nonylphenol (NP) is a shorter-chainnonylphenol that has been found in surface water and is toxic to aquatic life. NP is formed fromthe longer chain nonylphenol and octylphenol ethoxylates as they break down. The time span from time of use on the vessel to time of sampling of the discharge was probably not longenough for this to occur, except for discharges of bilgewater.gpm = gallons per minutegpd = gallons per dayNA - Not applicable; discharge not analyzed for this analyte group.

## 5.3 S UMMARY OF 

## P REDICTED 

## I MPACTS FROM 

## S ELECT 

## P OLLUTANTS IN 

## S TUDY 

## V ESSEL 

## D ISCHARGES



## 5.3.1 Potential Watershed-Wide Impacts from Study Vessels

Using estimated discharge volumes and averag e pollutant concentrations, EPA evaluated the potential for cumulative effects of the discha rges from an assemblage of study vessels on a large hypothetical harbor. The ev aluation used a screening-level water quality model to estimate the pollutant concentration into several hypothe tical harbors based on di fferent scenarios of vessel groups. Model assumptions included inst antaneous and universal dilution of vessel discharges in the harbor and a background concentr ation of zero for all an alytes in the harbor environment (i.e., the model is no t able to evaluate whether vesse l discharges are likely to cause environmental or human health impacts in the imme diate vicinity of the vessel discharges or in small water bodies). Instead, the m odel can only analyze potential vessel load ings to and impacts on hypothetical large water bodies. Furthermore, the m odel is not able to analyze parameters that do not have numeric aquatic life or human health based criteria such as BOD or nutrients.

The model did not predict that discharges fr om the study vessels solely exceeded aquatic life or human health NRWQC for any of the hypot hetical harbor scenarios evaluated. This is primarily due to the large dilution predicted in these large harbors (e ven with low flushing). However, some of these pollutants from these vessels could reasonably have more significant local impacts (although determining th is is outside the scope of the model used in this study). In smaller water bodies with many vessels or in more confined areas of a harbor with little to no flushing, EPA believes study vessel di scharges have the potential to cause or contribute to exceedances of NRWQC in receiving waters.

Under the low-dilution scenarios, dissolved c opper and total arsenic discharges represent the greatest environmental concern and are more likely than other pollutants to contribute to exceedances of water quality standards, particularly if there are other sources of these pollutants (e.g., stormwater runoff) present. Thes e results are summarized below.

Dissolved Copper

EPA determined that the loading rates of dissolved copper from a metropolitan harbor likely posed the greatest potenti al risk to human health and aquatic life from study vessels on a large scale. Compared to other types of harbors, a metropolitan harbor has a higher level of activity from its vessel populati on and has more support utility vessels such as supply boats, tow/salvage vessels, and tugboats. The model predicted that discharges from study vessels have the reasonable potential to cont ribute a significant load of dissolved copper to a water body. Furthermore, when considering the loadings of dissolved copper from other sources (e.g., recreational vessels, large commercial vessels, st ormwater runoff, and in dustrial and municipal

417

## point sources), the model results suggest a reas onable potential for the concentrations of dissolved copper to exceed the NRWQ C in this type of harbor.

The results of this study are consistent with real-world observations that metals are frequently associated with vessel discharges in concentrations of potential environmental concern. Environmental impacts from dissolved copper leaching from antifouling hull coatings have been well documented in low-flushing envi ronments in harbors with large numbers of recreational vessels, such as the Shelter Island Yacht Basin near San Diego, California, and Marina Del Rey Harbor in Los Angeles, Califo rnia (see Section 3.3.8.1 of this report). The impacts from the high levels of dissolved copper include reduced primary production andproductivity; accumulation of copper in sediments, reducing sediment quality; and chronic lowlevel toxicity to aquatic organisms, especially sensitive mollusks, crustaceans, and echinoderms.

Total Arsenic

EPA determined that the loading rates of tota l arsenic (and to a certain extent, dissolved arsenic) may pose a potential risk to human heal th and the environment in low-dilution or lowflushing environments. Arsenic was found to be ubiquitous in this study, both in vessel discharges and in ambient water 6 

## . Although arsenic concentrations in ambient water can be quite high in select harbors, certain discharges from study vessels contribute to the overall arsenic
load. While the source of total arsenic in vessel discharges is unknown, EPA suspects that atmospheric deposition contribu tes to total arsenic concentr ations in deck washdown and possibly in bilgewater. Total arsenic in fish hold discharges may be biolog ical in origin (from seafood catch) or from sediment entrained in th e catch. The biological co ntribution of arsenic may be significant in that total arsenic concentr ations are substantially greater in seawater organisms than in freshwater organisms (Fra ncesconi and Kuehnelt, 2002; USEPA 2003b).

The greatest impact of high total arsenic in harbors is primarily via the food chain and subsequent bioaccumulation to high levels in seafood consumed by humans. Arsenic exposure through drinking water is also of concern where r eceiving water is used as a source for drinking water. Arsenic is strongly linked to cancer in humans and a potent inhibitor of certain enzymes in
vertebrates.

5.3.2 Potential Localized or Near-Field Impa cts of Vessel Discharges to Receiving Waters

EPA found that some study vessel incidental discharges may pose an environmental
threat in confined water bodies with low flushi ng rates and a large population of vessels, in water bodies that are hypoxic or hypereut rophic, and/or where the bac kground concentrations or other

6 

### See discussion in Section 3.1.3 regarding potential positive interference which may have resulted in elevated measured concentrations of arse nic for a subset of samples.



## 418

## sources of these pollutants are significant. In ad dition to the parame ters (copper and arsenic) discussed in Section 5.3.1, the following classical po llutants may likely exhib it near-field effects.

BOD and COD

In general, oxygen-demanding compounds in vessels discharges (measured as BOD and COD) are expected to pose little risk to the env ironment due to the relatively low volume of vessel discharges that contain these pollutants. However, the frequency and magnitude of BOD and COD in certain discharges (as much as 25 t imes the concentrations found in raw sewage)
warrant additional discussion.

Specifically, the relatively hi gh BOD and COD concentrations in fish hold and fish hold cleaning effluent could pose a localized water quality impact in areas such as small side embayments where flushing rates are low or wher e portions of the water body are already low in dissolved oxygen. The high levels of BOD result from the degradation of organic material and its by-products in the fish hold. Higher volume discharges with high BOD concentrations (e.g., certain fish hold effluent) may contribute to localized hypoxic c onditions in receiving waters, depending on the volume of effluent discharged, the number of vessels di scharging in confined areas, and other factors such as season and water temperature.

Pathogen Indicators

Bacteria such as E. coli , enterococci, and fecal coliforms are generally of limited concern for most discharges where the pathogens were pr esent (i.e., bilgewater, deck washdown, and fish hold discharges). However, high levels of pathogens in graywate r (and potentially other discharge types) may pose some risk to human h ealth and larger vessels with additional crew or passengers are expected to generate considerably more graywater than sma ller vessels. However, looked at on a relative basis, the risk from pathogens in graywa ter is substantially lower than risks from other sources that cause very high concentrations of pathogen indicators in surrounding ambient water. For example, during sa mpling for this study in Massachusetts that took place in wet weather, a sanitary sewer overflow and a combined sewer overflow caused extremely high pathogen indicator counts in two different harbors, relative to what would be expected from graywater discharges from study vessels.

Total Phosphorus

Nutrients in vessel discharges are generall y expected to pose little risk to the environment. However, the frequency and magnit ude of total phosphorus in certain discharges
warrants some addi tional discussion.

The environmental effects of n utrients are driven by site-specific environmental conditions (e.g., receiving water temperature, types of algae present, and limiting nutrient conditions). For example, nutrients in vessel di scharges may contribute to an environmental

419

## effect in one water body, but not ano ther dependi ng on a variety of environmental conditions that control eutrophication (excess productivity in a water body). While EPA has not developed NRWQC for total phosphorus and othe r nutrients in coastal waters, some states have established water-body-specific or state-wide standards for nutrients based on site-specific evaluations.

As mentioned above, the water quality imp act of concern for total phosphorus is eutrophication. The first indicati ons of potential problems are the increased ambient levels of total phosphorus, often followed by an immediate increase in th e density (biomass) of the planktonic algal community. This increased algal biomass usually blocks light and reduces water clarity and may contribute to nu isance algal blooms and declin ing dissolved oxygen. Of note in this study was that the mean total phosphorus concentration in the 15 ambient water samples collected was two times the screening benchmar k, suggesting that the incremental effect of discharges from study vessels may be small.



## 5.4 P OSSIBLE 

## B ENEFITS TO 

## H UMAN 

## H EALTH 

## , W ELFARE 

## , AND THE 

## E NVIRONMENT FROM 

## R EDUCING 

## , E LIMINATING 

## , C ONTROLLING 

## , OR 

## M ITIGATING 

## O NE OR 

## M ORE OF THE 

## D ISCHARGES FROM THE 

## S TUDY 

## V ESSELS



## Some vessel discharges from commercial fi shing vessels and commercial vessels less than 79 feet in length may have the potential to impact the aquatic environment and/or human health. As noted above, using the results obtai ned in this study, EPA modeled a hypothetical large harbor to evaluate the potential water quality impacts caused by th e nine vessel discharge types EPA sampled. Based on this evaluation, EPA determined that the in cidental discharges from study vessels to a relatively large water bod y are not likely to solely cause an exceedance of any NRWQC (i.e., these discharges are unlikely to pose acute or chronic excursions of the NRWQC across an entire large water body). Howeve r, many of the pollutants in the vessel discharges were at end-of-pipe concentrations that exceeded an NRWQC, and therefore have the potential to contribute to an ex ceedance of water quality standards at a more localized scale. The study results indicate that tota l arsenic and dissolved copper are the most significant water quality concern for the study vessels as a whole. These pollutants are more likely than other pollutants to contribute to exceedances of water quali ty standards, particularly if there are other sources of pollutants or the receiving water already has high backgr ound concentrations.

420

## 421 .

Gloucester Harbor faces many environmental stressors including Combined Sewer Overflows and Urban Stormwater Runoff. For most pollutants, the impact of these sources may be more significant than from study vessels. However, some pollutants, such as copper or BOD are discharged in notable quantities from certain study vessel discharges.



## Like an individual house in an urban waters hed, most individual vessels have only a minimal environmental impact. However, the im pacts caused by these vessels is potentially significant where there are high vessel concentr ations, low circulation in waters, additional environmental stressors, or polluta nt loadings from other sources (e.g., recreational vessels, large commercial vessels, stormwater runoff, and industrial and municipal point sources). Reducing certain discharges or certain pollutants in discha rges from these vessels in sensitive waters may result in significant environmental benefits to those waters; however, EPA did not analyze the feasibility or cost of managing thes e discharges as pa rt of this study.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 422 

# CHAPTER 6

A NALYSIS OF THE EXTENT TO WHICH INCIDENTAL

DISCHARGES ARE CURRENTL Y SUBJECT TO REGULATION

UNDER FEDERAL LAW OR A BINDING INTERNATIONAL

OBLIGATION OF THE UNITED STATES

As discussed in Chapter 1, Congress directed EPA, in consultation with the U.S. Coast Guard and other interested federal agencies, to conduct a study of discharges incidental to the normal operation of all fishing vessels and nonrec reational vessels less th an 79 feet in length (study vessels). Among other things, the study’s charge directed EP A to include an “analysis of the extent to which the discharges are curren tly subject to regulati on under federal law or a binding international obligation of the United States” (Public Law (P.L.) 110-299 § 3(b)(6)). This chapter and accompanying tables present that analysis. Note, however, that as discussed in Chapter 1, this chapter includes some discussion of treaties and statutes that pertain to nonstudy vessels for information purposes. In accordance with P.L. 110-299, this study does not include significant discussion about discharg es of sewage or ballast water. 1



## This chapter is organized into four secti ons. Section 6.1 offers brief overviews of the international obligations addressing vessel disc harges, while Section 6.2 summarizes applicable federal statutes and regulations. Section 6.3 includes a brief overv iew of other international and federal laws that do not directly regulate discha rges incidental to th e normal operation of a vessel, but which the Agency felt merited some discussion. Finally, Secti on 6.4 provides tables identifying which applicable laws appl y to specific incidental discharges.



## 6.1 I NTERNATIONAL 

## A GREEMENTS



## 6.1.1 The International Convention for the Prev ention of Pollution from Ships (MARPOL 73/78)

The International Convention for the Prev ention of Pollution from Ships, 1973, as modified by the Protocol of 1978 (MARPOL 73/78), is the primary international instrument for regulating and preventing pollution from vessels . A total of 150 countries are Parties to

1 

### As of the writing of this report, ballast water discharges are regulated by the U.S. Coast Guard under the National Invasive Species Act of 1996 (NISA), by EPA under Section 402 of the Clean Water Act, and by several states under state law. NISA is discussed briefly in this analys is to the extent that it addresses invasive species from sources other than ballast water. Furthermore, the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM Convention), ad opted by the International Maritime Organization (IMO) in 2004, establishes ballast water discharge standards. Th e Convention has not yet attracted the requisite number of Parties necessary for its entry into force. For further di scussion, see Standards for Li ving Organisms in Ships’ Ballast Water Discharged in U.S. Waters (74 FR 44,631 (Aug. 28, 2009)).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 423 MARPOL. MARPOL includes six annexes, coveri ng six categories of vessel discharges: oil (Annex I), noxious liquid substances (Annex II), harmful packaged substances (Annex III), sewage (Annex IV), garbage (Annex V), and air emissions (Annex VI).

Before entering into force, the Convention re quired ratification by 15 member states, with a combined merchant fleet of not less than 50 per cent of the total world shipping fleet, measured by gross tonnage. To ratify the convention, member states are required to ratify only Annexes I and II; the remaining annexes are optional. The United States has ra tified Annexes I, II, III, V, and VI (the United States has not ratified Annex IV, which regul ates sewage discharges from ships; the United States regulat es sewage under Section 312 of th e Clean Water Act, which is discussed in Section 6.2, Federal Laws).

In the United States, MARPOL is primarily implemented through the Act to Prevent Pollution from Ships (APPS), 33 U.S.C. §§ 1901–1915. APPS implements Annexes I, II, V, and VI. Annex III of MARPOL is implemented through the Hazardous Materials Transportation Act, 49 U.S.C. § 5101 et seq . These implementing statutes are discussed in depth in Section 6.2,
Federal Laws.

6.1.1.1 MARPOL Annex I: Preventi on of Pollution by Oil

MARPOL Annex I establishes requirements for the control of oil pollution from vessels. As previously discussed in this report, small to large amounts of oil can be found in numerous vessel discharges, including bilg ewater, deck runoff, and engine effluent. The requirements of this Annex apply to all ships operating in the marine environment, unless expressly provided
otherwise.

Every oil tanker of 150 gt and above and every other ship of 400 gt and above is required to undergo a series of surveys to ensure that th e ship’s structure, equipment, systems, fittings, arrangements, and material are in full compliance with all applicable Annex I requirements and do not pose “an unreasonable threat of harm to the marine environment” (Annex I, Regulations 6.1 and 6.4.1). The surveys are required before th e ship is put in se rvice (or before an International Oil Pollution Prevention Certificate [IOPP Certificate], explained below, is issued for the first time); for IOPP Certificate renewa l purposes; at certain intervals surrounding the anniversary date of the ship’s IOPP Certificate; and after ce rtain repairs or renewals are completed (Annex I, Regulation 6).

Oil tankers of 150 gt and above and ships of 400 gt and abov e that travel to ports or offshore terminals under the jurisdiction of other Pa rties to Annex I are requi red to have an IOPP Certificate, which indicates completion of and compliance with Annex I’s inspection requirements. These certificates are issued or endorsed by the government of the state, or any persons or organizations authorized by it, under whose authority the ship is operating (Annex I,Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 424 Regulation 7). The IOPP Certificate shall not be issued for a time period exceeding five years, subject to various survey pr ovisions contained in the A nnex (Annex I, Regulation 10).

Annex I prohibits the discharge of oil or o ily mixtures into the sea, except under the following circumstances:

 Ships of 400 gt and above, whether insi de or outside a special area where:

o The ship is proceeding en route

.
o The oily mixture is processed through area-appropriate oil filtering equipment (under Regulation 14).

o The oil content of the effluent withou t dilution does not exceed 15 parts per million (ppm).

o The oily mixture does not originate from cargo pump-room bilges on oil tankers.

o The oily mixture, in case of oil tankers, is not mixed with oil cargo residues.

 Ships of less than 400 gt, whether insi de or outside a special area where:

o The ship is proceeding en route

.
o The ship has in operation equipment of a design approved by the government under whose authority the ship is operating, that ensures that the oil content of the effluent without dilution does not exceed 15 ppm.

o The oily mixture does not originate from cargo pump-room bilges on oil tankers.

o The oily mixture, in the cas e of oil tankers, is not mixed with oil cargo residues (Annex 1, Regulation 15).

 Discharges of oil or oily mixtures from car go areas of oil tankers outside special areas where:

o The tanker is more than 50 nautical miles from the nearest land.

o The tanker is proceeding en route

.
o The instantaneous rate of discharge of oil content does not exceed 30 liters per nautical mile.

o For tankers delivered on or before December 31, 1979, the total quantity of oil discharged into the sea does not excee d 1/15,000 of the total quantity of the particular cargo of which the residue form ed a part, or for tankers delivered after December 31, 1979, 1/30,000 of the total quantit y of the particular cargo of which the residue formed a part.

o The tanker has in operation an oil discha rge monitoring and control system and a slop tank arrangement (under Regulations 29 and 31). (Annex 1, Regulation 34).

Discharges of oil or oily mixtures from the cargo area of an oil tanker while in a special area are prohibited (Annex 1, Regulation 34).

Discharging oil or oily mi xtures from a ny ship in the Antarctic area is expressly prohibited. No discharge into the sea may contain substances in qua ntities or concentrations that
are hazardous to the marine environment or substances introduced for the purpose of circumventing the conditions of discharge sp ecified in Annex 1 (Annex 1, Regulation 15).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 425 The prohibition against the discharge of oil and oily mixtures does not apply where the discharge is necessary for the purpo se of securing the safety of a ship or saving life at sea. The prohibition also does not apply where the discharge resulted from damage to the ship or its equipment, provided that all reasonable precauti ons were taken after th e occurrence of the damage or discovery of the discharge and the da mage was not caused intentionally or recklessly with knowledge that damage woul d probably result. Ships may di scharge substances containing oil when those substances are being used to comb at specific pollution incidents in an effort to minimize damage from the pollu tion, subject to relevant gove rnments’ approvals (Annex I, Regulation 4).

Every oil tanker of 150 gt and above and ev ery other ship of 400 gt and above must
maintain an Oil Record Book Part I. 2 

## The Oil Record Book Part I must be completed whenever any of the following machinery-space events occu r: ballasting or cleani ng of oil fuel tanks; discharge of dirty ballast water or cleaning water from oil fuel tanks; collection and disposal of oil residues; discharge overboard or disposal ot herwise of bilgewater that has accumulated in machinery spaces; bunkering of fuel or bulk lubr icating oil; accidental or other exceptional discharge of oil; and failure of oil filtering equipment. The Oil Record Book Part I must be readily available for inspection. A Party to Annex I may request inspection of the Oil Record Book Part I while any ship to which this Annex applies is in its port or offshore terminal and require the master of the ship to certify that any copies made of the Oil Record Book Part I are true. (Annex I, Regulation 17).

Oil tankers of 150 gt and above and all ot her ships of 400 gt and above must carry onboard a shipboard oil pollution emergency pl an approved by the government under whose authority the tanker is op erating. The plan must include the procedures for ship operators to follow to report an oil pollution incident, the list of authorities or people to be contacted in the event of an oil pollution incident, a detailed desc ription of the actions to be taken immediately to reduce the discharges of oil following an in cident, and a contact onboard responsible for coordinating with authorities to combat the po llution. This plan may be combined with the emergency response plan required by MARPOL Annex II (discussed below). Oil tankers of 5,000 tons deadweight or more must have prompt access to computerized damage stability and
residual structural stre ngth calculation programs (Annex I, Regulation 37).

Governments of Parties to Annex I must ensure that there are adequate reception facilities for discharging oil and oily residues and comp ly with various requirements related thereto, including capacity and location requ irements (Annex I, Regulation 38).

2 

### Oil tankers must also maintain an Oil Record Book Part II (Annex I, Regulation 36).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 426 Although ballast water falls ou tside the scope of P.L. 110-299, the Agency notes that Annex I includes regulations govern ing ballast water. These regulations establish when ships must have segregated ballast tanks and under what circumstances ballast wa ter may be carried in oil fuel tanks or cargo tanks (A nnex I, Regulations 16 and 18).

In addition to the requirements discu ssed above, Annex I includes a number of requirements applicable to oil ta nkers alone. Since oil tankers woul d not generally be expected to be study vessels, EPA has omitted an in-depth discussion of these requirements, which include:

1. New-build protective cargo tank arrangements (including double-hull/double-bottom requirements) for certain tankers (Annex I, Regulations 19–20). 2. Double-bottom pump-room requirements for o il tankers of 5,000 tons deadweight and above constructed on or after Janua ry 1, 2007 (Annex I, Regulation 22). 3. Requirement that oil tankers delivered on or after January 1, 2010, be built in such a way that if they are damaged, oil will not spill from them at a rate greater than MARPOL allows (Annex I, Regulations 23-25). 4. Limitations on the size and a rrangement of cargo tanks for oil tankers of 150 gt and above, depending on delivery date (Annex I, Regulation 26). 5. Subdivision, damage stability, a nd intact stabili ty criteria (Annex I, Regulations 27–28).
6. Cargo tank cleaning requirements, including requ irements relating to slop tanks (Annex I, Regulation 29).
7. Pumping, piping, and discharge arrangement re gulations governing the discharge of dirty ballast water or oil-contaminated water (Annex I, Regulation 30). 8. Oil discharge monitoring and control system requirements, including requirements for effective government-approved oil/water inte rface detectors (Annex I, Regulations 31– 32).

Also outside the scope of this study, bu t worth noting, is that Annex I includes requirements applicable to fixed or floating platforms. Specifica lly, fixed or floating platforms must comply with the requirements of the Annex applicable to ships of 400 gt and above, other than oil tankers, except that they shall be equipp ed only to the extent practicable relating to tanks for oily residue and oil filtering equipment. R ecords involving oil or oily mixture discharges must be kept in a form approved by the government under whose aut hority the vessel is operating, and the discharge of oil or oily mixtur es to the sea is prohibited except when the oil content of the discharge without dilution doe s not exceed 15 ppm (Annex I, Regulation 39).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 427 6.1.1.2 MARPOL Annex II: Control of Polluti on by Noxious Liquid Substances in Bulk

MARPOL Annex II addresses pollution caused by “noxious liquid substances” (NLS) carried in bulk. Substances regulated as NLS under MARPOL are ca tegorized into four categories 3 

## based on their potenti al to cause harm:

 Category X: Substances that, if discha rged into the sea from tank cleaning or deballasting operations, present a ma jor hazard to either marine resources or human health and therefore justify the prohibition of the discharge into th e marine environment.

 Category Y: Substances that, if discha rged into the sea from tank cleaning or deballasting operations, present a hazard to either marine resources or human health or cau se harm to amenities or other legitimate uses of the sea and therefore justify a limitation on the quality and quantity of the discharge into the marine environment.

 Category Z: Substances that, if discharg ed into the sea from tank cleaning or deballasting operations, will present a minor hazard to either marine resources or human hea lth and therefore justify less stringent restrictions on the quali ty and quantity of the discharge into the marine environment.

 Other Substances: Substances that fall ou tside of categories X, Y, or Z because they are considered to present no harm to marine resources, human health, amenities, or other legitimate uses of the sea when discharged into the sea fr om tank cleaning or deballasting operations. The discharge of bilg e or ballast water or other residues or mixtures containing th ese substances are not subject to any requirements under MA RPOL Annex II. (Annex II, Regulation 6).

All ships certified to carry one or more of these substances in bulk must follow the requirements established in Annex II unless th e discharge is necessa ry for the purpose of securing the safety of a ship or saving life at sea (Annex II, Regulat ions 2–3). The Annex’s requirements also do not apply where the discharg e resulted from damage to the ship or its equipment, provided that reasonable precautions were taken after the occurrence of the damage or discovery of the discharge, and the damage was not caused inte ntionally or recklessly with knowledge that damage would probably result. Di scharges of other substances may also be exempted from Annex II’s requirements if they are government-approved (by both the government under whose authority the ship is operating and any government in whose

3 

### This categorization scheme was developed when Annex II was revised; it entered into force in January 2007. The United States Coast Guard’s implementing regulations, discussed below, have not yet been revised to reflect this new scheme.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 428 jurisdiction the discharge will occur) and being used to combat specific pollution incidents in an effort to minimize damage from the pollution (A nnex II, Regulation 3). Regulation 4 of Annex II provides for a number of other specific ex emptions to the Annex’s requirements.

Ships intending to carry NLS in bulk to ot her Parties to MARPOL must obtain an
International Pollution Prevention Certificate for the Carriage of Noxious Liquid Substances inBulk (“Certificate”). The Certificate records the results of the various inspections to which NLScarrying ships are subject. The government under which the ship is registered is typically responsible for issuing the Cer tificate, using a form provided in Appendix 3 to Annex II (Annex II, Regulation 9). Certificates ar e issued for a period of time not to exceed five years (Annex II, Regulation 10).

Prior to and at periodic intervals after a ship is issued a Certificate, it is subject to a complete inspection of its structure, equipment, systems, fittings, arrangements, and materials to ensure compliance with Annex II. The government of the country under whos e authority a ship is operating is responsible for having these inspecti ons conducted. If a ship or its equipment is found to not correspond substantially with the particulars of the Certificate, co rrective action
must be taken. If corrective action is not take n, the ship’s Certificat e should be withdrawn. Conformity with these MARPOL requirements is n ecessary to ensure that the ship does not pose
an unreasonable threat of harm to the ma rine environment (Annex II, Regulation 8).

Ships that are certified to carry NLS in bulk that are identified in chapter 17 of the International Bulk Chemical Code must gene rally ensure that thei r design, construction, equipment, and operation are in conformance with the requirements of that Code (Annex II, Regulation 11).

Ships constructed prior to July 1, 1986, must have a pumping and piping arrangement ensuring that each tank certified to carry substances in Category X or Y does not retain more
than 300 liters of residue in th e tank and its associated piping. Each tank certified to carry substances in Category Z must not retain more than 900 liters in the tank and its associated piping (Annex II, Regulation 12 (1)). Ships constructed on or after July 1, 1986, but before January 1, 2007, must not retain re sidue greater than 100 liters for Category X or Y substances or 300 liters for Category Z substances in the tank and its associated piping (Annex II, Regulation 12(2)). Ships constructed after January 1, 2007, must not retain residue in a quantity greater than
75 liters in the tank or its associ ated piping for Category X, Y, or Z (Annex II, Regulation 12(3)).

Ships certified to carry Category X, Y, or Z substances, except ships constructed before January 1, 2007, and certified to carry Category Z s ubstances, must have at least one underwater discharge outlet, which must be located within th e cargo area in the vicinity of the turn of the bilge and arranged to avoid the re-intake of re sidue/water mixtures by the ship’s seawater intakes. The residue/water mixture discharged into the sea must not pass through the ship’s boundary layer (Annex II, Regulation 12 (6)-(9)).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 429 Ships are prohibited from discharging into the sea residues of Category X, Y, or Z substances or ballast water, tank washings, or other mixtures containing these substances unless the discharges fully comply with the applic able operational requirements of Annex II. Specifically, 1) the ship must be proceeding en rout e at a speed of at least 7 knots in the case of self-propelled ships or at least 4 knots for other ships, 2) the discharge must be made below the waterline through the underwater di scharge outlets at a rate not to exceed what the outlet was designed for, and 3) the discharge must be made no less than 12 nautical miles from the nearest land and in water not less that 25 meters deep (Annex II, Regulation 13(1)-(2)). For Category Z substances on ships not required to have an underwater discharg e outlet, the requirement that discharges occur below the water line does not apply. Annex II also sets out requirements for the discharge of NLS residues (Annex II, Regulation 13( 6)–(7)). Any discharge of NLS or mixtures into the Antarctic area is prohibi ted (Annex II, Regulation 13(8)).

Every ship certified to carry Category X, Y, or Z substances must have a government approved Manual onboard. The Manual is meant to inform the ship’s officers of the physical arrangements and operational pr ocedures necessary to comp ly with Annex II (Annex II, Regulation 14). Ships must also carry with th em a Cargo Record Book to record where NLS
substances were loaded and unloaded and the ci rcumstances of the loading and unloading. If any accidental or emergency discharges occur, those must also be recorded in the Cargo Record Book (Annex II, Regulation 15).

Ships certified to carry NLS in bulk that weigh 150 gt or above must carry onboard a marine pollution emergency plan for NLS. The plan must be government approved and must include the procedures for ship operators to follo w to report an NLS pollution incident, the list of authorities and people to be c ontacted in the event of an NL S pollution incident, a detailed description of the actions to be taken immediat ely to reduce the discharges of NLS following an incident, and a contact onboard responsible for coordi nating with authorities to combat the pollution (Annex II, Regulation 17).

The Government of each Party to MARPOL must ensure that its port s and terminals have adequate NLS reception facilities for the ships u tilizing those ports and terminals to meet the requirements of Annex II (Annex II, Regulation 18).

6.1.1.3 MARPOL Annex III: Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form

MARPOL Annex III establishes requirements for preventing pollution caused by harmful substances that are carried in packaged form. “Harmful substances” are defined as those substances that are identified as marine pollu tants in the Internati onal Maritime Dangerous Goods Code (IMDG Code). “Packaged form” is de fined as the forms of containment specified for harmful substances in the IMDG Code (Annex III, Regulation 1(1)). Although the requirements of this Annex do not directly regulat e discharges incidental to the normal operationChapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 430 of a vessel, they play a critical role in preven ting harmful substances from entering into such discharge streams.

Annex III prohibits the carriag e of harmful substances from all ships unless the requirements of the Annex are followed (Annex III, Regulation 1(2)). Empty packages that were previously used to carry harmful substances and contain harmful residue are themselves considered harmful substances and must be treated as such (Annex III, Regulation 1(4)). Additionally, the Government of each Party to MARPOL is required to issue detailed requirements on packing, marking, labeling, doc umentation, stowage, quantity limitations, and exceptions for preventing or minimizing pollu tion of the marine environment by harmful substances (Annex III, Regulation 1(3)).

The Annex requires that packages containi ng harmful substances be adequate to minimize the hazard to the marine environment, having regard to their specific contents (Annex III, Regulation 2). They must be durably marked with the correct technical name (trade names alone are prohibited), must indi cate that the substance is a ma rine pollutant, and should be supplemented where possible by other means (e.g., us e of the relevant United Nations number). The durability of both the package and the mark ings must be considered because the Annex requires that the markings be able to withstand at least three months im mersed in the sea (Annex III, Regulation 3).

In all documents relating to the carriage of harmful substances at sea, the correct technical name of each substance must be used, and the substance must be identified with the words “MARINE POLLUTANT.” The shipping doc uments provided by the shipper must be accompanied by a signed certificate declaring that th e shipment is properly packaged and marked and in proper condition for carriage to minimize the hazard to the marine environment. Every ship must keep, both onboard and onshore, a list or manifest detailing the harmful substances onboard and where they are stowed (Annex III, Regulation 4).

Packages containing harmful substances must be stowed and secured so as to minimize the hazards to the marine environment, without impairing the safety of the ship and the people onboard (Annex III, Regulation 5). Some harmfu l substances may face restrictions, for sound
scientific and technical reasons, as to the quantity that can be carried onbo ard, and in some cases, carrying them might be prohibited altogether. Th ese determinations will take into account the size, construction, and equipment of the ship, as well as the packaging and nature of the substance (Annex III, Regulation 6).

Except where necessary to protect the ship or saving life at sea, the jettisoning of harmful substances carried in packaged form is prohibited (Annex III, Regulation 7).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 431 6.1.1.4 MARPOL Annex IV: Prevention of Pollution by Sewage from Ships

Annex IV of MARPOL establishes requireme nts for the prevention of pollution caused by sewage from ships. The discussion of discharges of sewage from vessels was specifically excluded from the scope of this study; therefore, the summary of this section is omitted. See P.L. 110–299, § 3(c)(2). It should also be noted that, as mentioned above , the United States is not a party to Annex IV and is therefore not obligated to follow its requirements.

6.1.1.5 MARPOL Annex V: Prevention of Pollution by Garbage from Ships

Annex V of MARPOL regulates garbage pollution from ships. Under the Annex, “Garbage” is defined as all kinds of victual, domestic, and op erational waste (excluding fresh fish and fish parts) generated during the normal opera tion of the ship and liable to be disposed of continuously or periodically (Annex V, Regula tion 1(1)). Although the requirements of this Annex do not directly regulate discharges subject to this report (“garbage” is not subject to the former NPDES permit exclusion at 40 CFR 122.3(a )), they play a critical role in preventing garbage from entering into and contaminating discharge streams subject to this report.

The Annex establishes different disposal re quirements depending on the type of garbage being disposed of. Disposal in to the sea of dunnage— lining and packing materials that will float—is prohibited if the ship is closer th an 25 nautical miles from the nearest land. The disposal of food wastes and all other garbage, including paper products, rags, glass, metal, bottles, crockery, and similar refuse is prohibite d less than 12 nautical miles from the nearest land; however, it may be permitted if it has passe d through a comminuter or grinder, is small enough that it can pass through a screen with openings no greater than 25 mm, and is disposed of as far as practicable from the nearest land (but no closer than 3 nautical miles). The disposal of plastics, including but not limited to synthetic rope s, synthetic fishing ne ts, and plastic garbage bags, is prohibited. Where garbage is mixed, th e more stringent requirements will apply (Annex V, Regulation 3). Additional specia l requirements are in place for di scharges into certain defined

areas. 4



## None of the disposal regulations describe d above apply where: 1) the disposal was necessary for the purpose of securing the safety of the ship or those onboard or saving life at sea; 2) the garbage escaped as the result of damage to the ship (provided al l reasonable precautions were taken before and after the incident to prev ent or minimize the escape); or 3) disposal was the result of an accidental loss of synthetic fishin g nets (provided that all reasonable precautions were taken to prevent the lo ss) (Annex V, Regulation 6).

4 

### For the purposes of Annex V, the special areas are the Mediterranean Sea area; the Baltic Sea area; the Black Sea area; the Red Sea area; the “Gulfs” ar ea; the North Sea area: the Antarctic area; and the wider Caribbean region, including the Gulf of Mexico and the Caribbean Sea (although the rules have not entered into force with respect to all of these areas yet). For the specific requirements, see Annex V, Regulation 5.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 432 The Parties to the Annex must ensure that po rts and terminals have adequate facilities for the reception of garbage (Annex V, Regulation 7).

Each ship 12 meters or more in length must display placards that notify those onboard of the various disposal requirements . The placards must be written in the working language of the ship’s personnel and, for ships engaged in voya ges to ports or offshore terminals under the jurisdiction of other Pa rties to the Convention, shall also be in English, French, or Spanish (Annex V, Regulation 9(1)).

Every ship 400 gt and above and every ship certified to carry 15 or more people must carry a garbage management plan for the crew to follow. The plan must describe procedures for collecting, storing, processing, and disposing of garbage, including the use of equipment
onboard. It must be written in the working language of the crew and identify the person in charge of carrying out the plan (Annex V, Regulation 9(2)). Ships of this size or certification that travel to ports or offshore terminals under the jurisd iction of other countries party to MARPOL, and every fixed and floating platform engaged in exploration and e xploitation of the seabed, must also carry a Garbage Record Book onboard. The Ga rbage Record Book must include a record of every discharge operation or incineration, includi ng the date and time of the discharge, the position of the ship, a description of the garbag e, and the estimated amount discharged or incinerated. Any escapes or accid ental losses must also be note d in the Garbage Record Book, along with a description of the circumstances of the loss (Annex V, Regulation 9(3)).

6.1.1.6 MARPOL Annex VI: Prevention of Air Pollution from Ships

Annex VI of MARPOL regulates air emissions from ships. Air emissions are outside the scope of this study, therefore, the summary of this Annex has been omitted.

6.1.1.7 MARPOL Summary

The earlier chapters of this study describe a number of po llutants detected by EPA in incidental vessel discharges that have the poten tial to pose a risk to human health or the environment. Of these pollutants of concern, it ap pears that oil and grease are the only pollutants found in incidental discharges that would be directly regulated by MARPOL, through Annex I. However, MARPOL may indirectly regulate other pollutants found in incidental discharges, such as metals, to the extent that they are found in any of the noxious liquid substances categorized under Annex II or garbage under Annex V and prev ented from entering incidental discharge streams . In all cases, the requirements of MARP OL only apply to those vessels that are large enough to meet the size threshol ds established in the treaty.

6.1.2 The International Convention on the Cont rol of Harmful Anti-Foulin g Systems on Ships

The International Convention on the Control of Harmful An ti-Fouling Systems on Ships was adopted by the IMO on October 5, 2001, and entered into force on September 17, 2008. TheChapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 433 U.S. Senate gave its consent to ratify the Convention on September 26, 2008; however, the United States will not deposit its instrument of ratification with the IMO until Congress adopts the necessary implementing legislation. Implemen ting legislation was introduced on September, 24, 2009. See Clean Hull Act of 2009, H.R. 3618, 111th Congress (1st Session 2009). If passed, this new legislation would replace the Orga notin Anti-Fouling Pain t Control Act of 1988 (OAPC), discussed below.

Parties to the Convention are re quired to take steps to reduce or eliminate adverse effects
on the marine environment and human health caused by antifouling systems. Under the Convention, an “antifouling system” is any coatin g, paint, surface treatment, surface, or device used on a ship to control or prevent the att achment of unwanted organisms (Article 2(2)).

The Convention applies to any ship entitled to fl y the flag of a Party; ships not entitled to fly the flag of a Party but that operate under the authority of that Party; and ships that enter a port, shipyard, or offshore terminal of a Party but do not fall under one of the earlier categories. Warships, naval auxiliary, or other ships owned or operated by a Party are exempted when used only for noncommercial government service. Howe ver, each Party must ensure that these exempted ships operate in a manner consistent with the Convention, where reasonable and practicable. Parties must also ensu re that favorable treatment is not given to ships registered to
countries that are not Parties to the Convention (Article 3).

Under the Convention, Parties must prohibi t and/or restrict the application, reapplication, installation, or us e of environmentally harmful antifouling systems on ships registered under them, as well as on ships that en ter its ports, shipyards, or offshore terminals (Article 4). As of January 1, 2008, ships are pr ohibited from having any organotin compounds on their hulls that act as biocides, unless the compounds have been s ealed so that no leaching occurs (Annex I).

Parties to the Convention must take measures to require that wastes generated by the application or removal of an an tifouling system are collected, ha ndled, treated, and disposed of in a safe and environmentally sound manner (Artic le 5). In the United States., this provision would be implemented through the Solid Waste Disposal Act, 33 U.S.C. §§ 6901–6992, and the Clean Water Act, 33 U.S.C. §§ 1251–1387.

Any Party can propose an amendment to the Convention, including pr oposals to prohibit antifouling systems other than organotins. Th e process for proposing an amendment, and subsequently considering and adopting it, is described in Articles 6, 7, and 16.

Parties must take appropriate measures to pr omote and facilitate scientific and technical research on the effects of antifouling systems, as well as monitoring these effects. The research should include observation, measurement, sampling, evaluation, and analysis of the effects ofChapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 434 antifouling systems. Parties should share the info rmation learned in these studies with other
Parties to the Convention when requested (Article 8).

The Convention requires Parties to report to the IMO a list of all surveyors and organizations that are authorized to act on behalf of that Party in administration of matters relating to the control of anti-fouling systems. Parties mu st also annually report information regarding any antifouling systems that were approved, restri cted, or prohibited under domestic law. For antifouling systems that were approved, registered, or licensed by a Party, that Party must provide to other Parties upon request relevant information on which that decision was made (alternatively, a Party could requ ire the manufacturers of appr oved, registered, or licensed antifouling systems to provide this information) (Article 9).

A Party must ensure that ships entitled to fl y under its flag or operate under its authority are surveyed and certified in accordance with the requirements of Annex 4 (Article 10). Annex 4 requires that ships of 400 gt and above that are engaged in international voyages be surveyed before the ship is put into service and whenever the antifouling systems are changed or replaced. The survey is intended to ensure the ship ’s antifouling system fully complies with the Convention (Annex 4, Regulation 1). At the conclusi on of the survey, the ship will be issued an International Anti-Fouling Syst em Certificate (Annex 4, Regula tion 2). Ships less than 400 gt and 24 meters or more in length and that are engaged in international voyages must carry a Declaration, signed by the owner or his agent, declaring that th e antifouling system used on the ship complies with the requirements of the Convention (Annex 4, Regulation 5).

Ships to which the Convention applies may be inspected in any port, shipyard, or offshore terminal of a Party. Unless there are clear grounds for believing that a ship is in violation of the Convention, the in spection is limited to: 1) verify ing that, where required, there is a valid International Anti-Fouling System Certif icate or Declaration onboard; and/or 2) a brief sampling of the ship’s antifouli ng system, taking into account IMO guidelines. If there are clear grounds to believe that a ship is in violati on of the Convention, a mo re thorough inspection is permitted, taking into account IMO guidelines. A dditionally, a Party may take steps to warn, detain, dismiss, or exclude from its ports any sh ip that is found to be in violation but must immediately notify the country under whose flag the ship is registered (Article 11).

Parties must, through domestic laws, prohibit violations of the Convention and establish sanctions severe enough to discourage violations. 5 

## If a violation occurs w ithin the jurisdiction of a Party, that Party must either cause proceedings to be taken in accordance with its domestic laws or furnish any information or evidence it has showing a violation has occurred to the government under whose authority the ship concer ned is operating. If that government finds the

5 

### For vessels larger than 79 feet, EPA has prohibited th e discharge of tributyltin and other organotins under the Agency’s Vessel General Permit (see Section 6.2.3).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 435 evidence sufficient to enable proceedings to be brought, it must do so as soon as possible, in accordance with its laws, and notif y both the IMO and the reporting Party that it has done so. If the government does not take action within one year after receivi ng the information, it must so inform the Party that reported the alleged violation (Article 12).

Parties must make every effort to avoi d unduly detaining or delaying ships while conducting inspections or investig ating potential violations. If a ship is unduly detained or delayed, it is entitled to compensation for a ny loss or damage suffered (Article 13).

The Convention does not prejudice the rights or obligations of any country under customary international law as reflected in th e United Nations Convention on the Law of the Sea (Article 15).

Presently, the International Convention on the Control of Harmful Anti-Fouling Systems on Ships only regulates the use of organotin tribut yling (TBT) in antifouling coatings. Effective January 2003, new applications of antifouling coatings containing TBT were prohibited by the treaty, and as of January 2008, all vessels with an existing TBT an tifouling coating on their hulls are required to apply a protective coat ing over the TBT to prevent leaching.

Since the use of TBT has been prohibited, ve ssel operators have tu rned to anti-fouling systems that contain other potentia lly harmful pollutants, such as copper. Copper is not currently regulated under the International Convention on the Control of Harmful Anti-Fouling Systems on Ships; however, the treaty provides a system whereby Parties may propose that a specific anti-fouling system be regulated under the treaty. Through this mechanism, copper may one day be regulated under the treaty if parties to the treaty determine it is necessary.

6.1.3 International Convention for the Safety of Life at Sea (SOLAS)

The International Convention for the Safety of Life at Sea (SOLAS) is considered the most important international treat y concerning the safety of mercha nt ships. The first version was adopted in 1914 in response to the Titantic disaster and has been amended many times since then, most recently in 1974. The primary objective of SOLAS is to establish minimum standards for the construction, equipment, and operation of ships, in consideration of their safety. The responsibility for ensuring compliance rests with the individual flag st ates, although contracting governments do have limited authority to inspect sh ips of other contracting governments if there are clear grounds for believing the SOLAS re quirements are not being met. For additional information on SOLAS, please see the IMO’s discussion of the Convention at www.imo.org

While SOLAS does not directly regulate vesse l discharges, it does provide environmental benefits through its regulations and through adoption of the International Safety Management (ISM) Code, all of which assist in preventing sp ills and other accident al discharges. The ISM Code provides an international standard for safely managing and operating ships and forChapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 436 preventing pollution. In addition to other requirements, under the C ode, companies or individuals responsible for operating vessels must establish a safety and environmen tal-protection policy and ensure that the policy is implemented and maintain ed at all levels of the organization, both shipbased and shore-based. These operators must also create a safety management system, which is a structured and documented system that enables company personnel to effectively implement the company’s safety and environmental pr otection policy (ISM Code, Part A).

SOLAS could be used to address any of the pollutants of potential concern identified by EPA though this study, to the extent that the in dividual policies adopted by vessel operators address specific pollutants found in incidental discharges.

6.1.4 Boundary Waters Treaty

The Boundary Waters Treaty is an agreement the United States and Canada entered into in 1919 to govern the management of boundary wa ters. Among other things, the treaty provides that “boundary waters” – defined as “waters from main shore to main shore of the lakes and rivers and connecting waterways, or the portion thereof, along with th e internati onal boundary”
between the U.S. and Canada - “and waters fl owing across the boundary sh all not be polluted on either side to the injury of hea lth or property on the other” (Prelimi nary Article and Ar ticle IV.2).

The Treaty established the International Jo int Commission (IJC), composed of three commissioners from each country, to assist in the resolution of boundary water issues (Article III). Since 1919, the IJC has addr essed a variety of water-use and water-quality issues. The Treaty is a foundational backdrop for other bilate ral agreements between the United States and Canada, such as the Great Lakes Water Quality Agreement.

As a foundational agreement, the Boundary Wa ters Treaty does not directly regulate specific pollutants, which means it does not direc tly regulate specific poll utants in incidental discharges.

6.1.5 Great Lakes Water Quality Agreement

The Great Lakes Water Quality Agreement, first signed in 1972, and revised in 1978 and 1987, expresses the commitment of both the United States and Canada to restore and maintain the chemical, physical, and biological integrity of the waters of Great Lakes Basin Ecosystem. It also reaffirms the rights and obligations of both countries under the Boundary Waters Treaty. The Great Lakes Water Quality Agreement is primarily implemented through Section 118 of the
Clean Water Act.

One of the stated policies in the Agreement is the prohibition of discharges of toxic
substances in toxic amounts and the virtual elim ination of discharges containing any or all persistent toxic substances (Artic le II). The general objectives of the agreement are to ensure that the waters in the Great Lakes System are free from pollutants resulting from human activity,Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 437 such as substances that will se ttle to form sludge deposits or harm aquatic life or waterfowl; floating materials (e.g., debris, oil, scum, other i mmiscible substances); ma terials or heat that produce color, odor, taste, or other conditions that will interfere with beneficial uses or are toxic or harmful to human health or the environment; a nd nutrients that create growths of aquatic life that interfere with beneficial uses (Article III).

Vessel discharges are directly addressed through Annexes 4 (discharges of oil and hazardous polluting substances from vessels), 5 (discharges of vessel wastes), and 6 (review of pollution from shipping sources) of the Agreement. In all of these annexes, “vessel” is defined as “any ship, barge or other floating craft, whethe r or not self-propelled” (Annex 4(1)(e), Annex 5(1)(e)).

Annex 4 addresses discharges of oil and h azardous polluting substances from vessels. Within this annex, the term “discharge” include s, but is not limited to, any spilling, leaking, pumping, pouring, emitting, or dumping; it does not include unavoidabl e direct discharges of oil from a properly functioning vessel engine (Annex 4(1)(a)). The a nnex requires that each country adopt regulations to prevent di scharges of harmful quantities of oil and hazardous substances from vessels into the Great Lakes System. Specifically:

 Discharges of harmful quantities of oil or hazardous substances, including those contained in ballast water, must be pr ohibited and made subject to appropriate penalties.

 As soon as any person in charge, including a vessel owner/operator, becomes aware of a discharge, or probable discharge, of harmful quantities of oil or hazardous substances, he/she must immediately notify the appropriate agency in the jurisdiction where the discharge occurred. Fail ure to give this notice must be subject to appropriate penalties (Annex 4(2)).

A “harmful quantity of oil” is defined as “any quantity of o il that, if discharged from a ship that is stationary into clear calm water on a clear day, would produce a film or a sheen upon, or discoloration of, the surface of the water or ad joining shoreline, or would cause a sludge or emission to be deposited beneath the surface of the water or upon the adjoining shoreline” (Annex 4(1)).

Annex 4 also requires both countries to a dopt regulations for th e design, construction, and operation of vessels, as well as programs to ensure that merchant vessel personnel are trained in the use, handling, and stowage of oil and ab atement of oil pollution, thereby preventing the discharge of harmful quantities of oil or hazardous polluting substa nces. For oil, the regulations
must ensure that each vessel ha s a suitable means for containing sp ills of oil and oily wastes and retaining those wastes onboard for off-load at a reception facility. Oil loading, unloading, and bunkering systems must be suitably designed to minimize the possibili ty of failure (Annex 4(3)).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 438 For hazardous polluting substances, each count ry must adopt programs and measures to prevent discharges of harmful qua ntities of hazardous polluting substances ca rried as cargo. Such regulations include ensuring that all vessels have a suitable m eans of containing onboard spills caused by loading or unloading operations and have the capability of retaining onboard wastes accumulated during vessel operation for off-loading to a reception facility. The regulations must also provide for the identification of vessels ca rrying cargos of hazardous substances and for the
identification in vessel manifest s of all the hazardous substan ces those vessels are carrying (Annex 4(4)). A list of hazardous polluting substances and potential hazardous polluting substances can be found in Appendices 1 and 2 to Annex 10.

Additionally, under Annex 4, both c ountries must ensure that there are adequate facilities for the reception, treatment, and subsequent di sposal of oil and hazardous polluting substances from all vessels (Annex 4(5)).

Annex 5 addresses discharges of vessel wa stes, including garbage, sewage, and waste water. “Garbage” is defined as “all kinds of victual, domestic, and operational wastes, excluding fresh fish and parts thereof gene rated during the normal operation of the ship and liable to be disposed of continually or periodically.” “Was tewater” encompasses any water combined with other substances, “including ballast water and water used for washing cargo hold, but excluding water in combination with oil, hazardous po lluting substances, or sewage” (Annex 5(1)).

The agreement requires both countries to adopt regulations that will:

 Prohibit the discharge of garb age from vessels and make su ch discharges subject to appropriate penalties.

 Prohibit the discharge of wast ewater in harmful amounts or concentrations and make such discharges subject to appropriate penalties.

 Ensure that each vessel operating in boundary wa ters, and that has to ilet facilities, is equipped with a device to contain, incinerate, or treat sewage to an adequate degree. Appropriate penalties must be provided for failure to comply (Annex 5(2)).

Within the Great Lakes System, certain crit ical use areas may be designated where the discharge of wastewater or sewage will be limited or prohibited (Annex 5(3)). Both countries must take measures to ensure there are adequa te facilities for the reception, treatment, and subsequent disposal of garbage, wastewater , and sewage from vessels (Annex 5(5)).

Annex 6 calls on both the Canadian and U.S. Co ast Guards to review “services, systems, programs, recommendations, standards, and regula tions relating to shipping activities for the purpose of maintaining or improving Great Lake s water quality” (Annex 6(1)). The two Coast Guards must meet at least annually to consu lt on implementing the Agreement (Annex 6(2)).

Of the pollutants of potential concern iden tified by EPA earlier in this study, oil and grease are the pollutants most directly a ddressed under the Great Lakes Water QualityChapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 439 Agreement. The Agreement also addresses wast ewater, which may include some incidental discharges. Under the Clean Water Act, the Grea t Lakes National Program Office is tasked with developing and implementing specific action plans to carry out the responsibilities of the U.S. under the Great Lakes Water Quality Agreement. (33 U.S.C. § 1268(c)(1)(A)). EPA might be able to address incidental discharges through thes e action plans to the exte nt those discharges are “wastewater” as that term is defined in the Agreement.

Annex I lists a number of chemical s and pollutants that are specifi c objectives of the agreement, including metals such as arse nic, cadmium, chromium, copper, and nickel, among others. Annex I also provides standards for the concentration of total dissolved solid s, hydrogen sulfide, phosphorus, and other pollutant s in the Great Lakes.

6.1.6 St. Lawrence Seaway Regulations

In 1954, the United States statutorily create d the Saint Lawrence Seaway Development Corporation to construct, operate , and maintain the section of the St. Lawrence Seaway between
the Port of Montreal and Lake Er ie that falls within the territor ial limits of the United States (33 U.S.C. § 981). The mission of the wholly govern ment-owned corporation, which is under the direction and supervision of the Department of Transportation, is to improve the operation and maintenance of a deep-draft waterway in cooperation with a Ca nadian counterpart. 6



## The Department of Transporta tion’s regulations governing th e Seaway can be found at 33 CFR Part 401. The regulations define the St. La wrence Seaway as the “the deep waterway
between the Port of Montreal and Lake Erie a nd includ[ing] all locks, canals and connecting and contiguous waters that are part of the deep wate rway, and all other canals and works, wherever located, the management, administration and cont rol of which have been entrusted to the Corporation or the Manager” (33 CFR § 401.2(j)).

While the regulations are primarily geared toward maintaining and using the Seaway, they do include provisions designed to lessen the impacts of vessel polluti on to the Great Lakes, including a provision that prohibits the discharge of garbage, ashes, ordure, litter, or other materials into the Seaway (33 CFR § 401.59(d)). Th e regulations also prohibit any vessel from emitting sparks or excessive smoke, or from blowing boiler tubes (33 CFR § 401.59(a)). In addition, the regulations c ontain a blanket requirement that no di scharge is allowed that is not in

6 

### In addition to the authorities under its enabling statut e, 33 U.S.C. § 981 et seq., the St. Lawrence Seaway Development Corporation has authority to “operate, mainta in, improve or expand vessel traffic services consisting of measures for controlling or supervising vessel traffic or for protecting navigation and the marine environment” pursuant to the Ports and Waterways Safety Act of 1978, at 33 U.S.C. 1223–1225, 1229. The U.S. Coast Guard has this authority in all other navigable waters of the United States, except for the area under the jurisdiction of the Corporation.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 440 conformity with all applicable U.S. and Canadian regulations, except within certain areas of the Welland Canal, where no discharges are allowed at all (33 CFR § 401.59(b)).

Although ballast water is not a focus of th is study, it should be noted that the St. Lawrence Seawater Regulations also include prov isions relating to balla st water, including a recently passed regulation requiring all ocea ngoing vessels entering the Seaway to conduct saltwater flushing ( 

## Seaway Regulations and Rules: Periodi c Update, Various Categories, 73 FR 9950 (February 25, 2008)).

The St. Lawrence Seaway Regulations only regula te specific pollutants to the extent they
are found in ballast water.



## 6.2 F EDERAL 

## L AWS



## 6.2.1 Act to Prevent Pollution from Ships (APPS)

The Act to Prevent Pollution from Ships (APPS) is the United States law implementing Annexes I, II, V, and VI of MARPOL (Annex III is implemented through the Hazardous Materials Transportation Act). The U.S. Coast Guard has the primary authority to implement and enforce the majority of provisi ons within APPS. EPA was also given specific authorities in certain sections of APPS, the most extensive of which relate to MARPOL Annex VI. The Coast Guard’s implementing regulations, found at 33 CFR Part 151, are addressed below.

APPS applies to U.S.-registered ships regardle ss of where in the worl d they are operating. With respect to the implementation of Annexes I and II, APPS additionally applies to all foreignflagged ships operating in navigable U.S. waters . The implementation of Annex V applies to all U.S.-registered ships, as well as all foreign-fl agged ships in navigable U.S. waters or the
exclusive economic zone of the United States (33 U.S.C. § 1902(a)). Warship, naval auxiliary, and ships owned by the United States that are e ngaged in noncommercial service are exempted from the requirements of APPS, except for certain provisions implementing Annex V. 7 

## Ships that are specifically exempted fr om MARPOL, or the Antarctic Prot ocol, are also exempted from the requirements of APPS.

In addition to implementing the require ments of MARPOL, described above, APPS establishes a number of administrative requirements regarding inspections, penalties for violations, procedures for le gal actions, and public educati on requirements (33 U.S.C. §§ 1907, 1908, 1910, and 1915).

7 

### However, all surface ships and submersibles owned or operated by the Department of the Navy are required to comply with the special area requirements of Annex V. Unique vessels that cannot fully comply with the requirements of Annex V are permitted to discharge some types of garbage without rega rd to the requirements of Annex V. See 33 U.S.C. § 1902(d)(2).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 441 6.2.1.1 U.S. Coast Guard Implementing Regulations

The U.S. Coast Guard implements APPS th rough its regulations at 33 CFR Part 151. These regulations apply to every ship required to comply with Annex I, II, or V of MARPOL (33 CFR § 151.03). 8



## 6.2.1.1.1 Annex I Implementation—Prevention of Oil Pollution

The requirements of Annex I of MARPOL, pertaining to the prevention of oil pollution from ships, are implemented by the U.S. Co ast Guard though its regulations at 33 CFR §§ 151.09–151.29. This section of the regulations, with the exception of the o il pollution emergency plan requirements, 9 

## is applicable to ships that are operated under the authority of the United States and that engage in international voyages, are certificated for ocean service, are certificated for coastwise service beyond three nautical miles fr om land, or are operated at any time seaward of the outmost boundary of the territorial seas of the United States. The regulations also apply to ships operated under the authority of another countr y while in the navigable waters of the United States or while at a port or terminal unde r U.S. jurisdiction (33 CFR § 151.09(a)). The regulations do not apply to wars hips, naval auxiliary, or other ships owned or operated by a country when engaged in noncommercial service; Canadian or U.S. ships operating exclusively
on the Great Lakes or their connec ting tributary waters or on any internal waters of the United States or Canada; or any ships sp ecifically excluded by MARPOL.

The Coast Guard’s requirements for oil disc harges from ships other than oil tankers 10 

## are very similar to Annex I’s requirements. The Co ast Guard’s regulations apply to the same size ships regulated under MARPOL; however, the Coas t Guard also distingu ishes vessels depending on how far off shore they are operating:

 When more than 12 nautical miles from the nearest land, any discharge of oil or oily mixtures must meet the following conditions:

o The discharge must not originate from cargo pump room bilges.

o The discharge must not be mixed with oil cargo residues.

o The ship must not be within a special area.

8 

### On December 18, 2009, EPA finalized regulations to implement the air emi ssion requirements of APPS (which themselves implement MARPOL Annex VI). The final rule is not scheduled to appear in the Federal Register until the end of February 2010. To see a pre-publication copy of the rule, please visit EPA’s website at http://www.epa.gov/OMS/oceanvessels.htm#regs.

9 

### The shipboard oil pollution emergency plan requirements at 33 CFR §§ 151.26-151.29 apply to all U.S.- and foreign-operated oil tankers of 150 gt and above and all other ships of 400 gt and above. The same exceptions described in the text apply, with the additional exception that barges or other ships constructed or operated in such a manner that no oil in any form can be carried aboard ar e also exempted from the requ irements (33 CFR § 151.09(c)– (d)).

10 

### The requirements for oil tankers are found in a separate section of the regulations (33 CFR Part 157).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 442 o The ship must be proceeding en route

. 11



## o The oil content of the effluent withou t dilution must be less than 15 ppm.

o The ship must be operating oily-water separating equipment, a bilge monitor, a bilge alarm, or a combination of the three (33 CFR § 151.10(a)).

 When within 12 nautical miles from the ne arest land, any discharge of oil or oily mixtures must meet all of the above requirements, with the additional requirement thatthe oily-water separating equipment be equipped with a U.S. government- or IMOapproved 15 ppm bilge alarm (33 CFR § 151.10(b)).

Ships of 400 gt or above and oil tankers ar e prohibited from disc harging oil or oily mixtures while operating in a special area, as defined in 33 CFR § 151.13(a). However, if the discharge is of processed bilgewater from m achinery space bilges, ships of this size may discharge in special areas if all of the above requ irements are met and the ship is equipped with an automatic shut-off device that will engage wh en the oil content of the effluent exceeds 15 ppm (33 CFR § 151.13). Ships of 400 gt or less, other than oil tanke rs, may discharge in special areas only if the undiluted oil content of their effl uent is 15 ppm or less. If a ship cannot meet the discharge requirements, the oily mixtures must be retained onboard or di scharged to a reception facility (33 CFR § 151.10(f)).

As with MARPOL, these discharge requireme nts do not apply where the discharge is necessary to secure the safety of the ship or sa ve life at sea, or if th e discharge results from damage to the ship (provided reasonable precau tions were taken after the occurrence of the damage or discovery of the discharge to preven t or minimize the discharge, and the owner or master of the ship did not act with intent to cau se damage, or recklessly and with knowledge that damage would probably result) (33 CFR § 151.11).

The regulations also implement the repor ting, survey, certification, inspection and enforcement, recordkeeping, and planning requirements of Annex I, described above (33 U.S.C. §§ 151.15, 151.17, 151.19, 151.23, 151.25–151.28).

6.2.1.1.2 Annex II Implementation—Prevention of Pollution from Noxious Liquid Substances

The requirements of Annex II of MARPOL, pertaining to the discharges of noxious liquid substances from ships, are implemented by the U.S. Coast Guard primarily through its regulations at 33 CFR §§ 151.30–151.49, although some requirements are also at 46 CFR Parts

11 

### A ship not traveling en route may discharge oil and oily mixtures, provided it is equipped with a U.S. government-or IMO-approved 15 ppm bilge alarm and complies with other requirements of 33 CFR § 151.10. 33 CFR § 151.10(d).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 443 151 and 153. 12 

## Which regulations are applicable to a particular vessel depends on the specific substance(s) the ship is carrying (33 CFR § 151.31).

The primary regulations at 33 CFR §§ 151.30–151.49 are applicable to the same ships subject to the implementing regulations for Annex I (i.e., all ships operate d under the authority of the United States that are engaged in internat ional voyages, certificated for ocean service, certificated for coastwise service beyond 3 nautical miles from land, or operated seaward of the outermost boundary of the territorial sea of the Un ited States). These requirements also apply to ships operated under the authority of another countr y while in U.S. waters or while at a port or terminal under U.S. jurisdiction (33 CFR § 151.30(a)). The same ex emptions that apply to Annex I’s implementing regulations also apply here, w ith an added exemption for tank barges whose certificates are endorsed by the Coast Guard for a limited short protected coastwise route if the barge is constructed and certificated primarily for service on inland routes (33 CFR § 151.30(b)).

U.S. oceangoing ships are prohibited from carrying certain Category C and D NLS, identified at 33 CFR §§ 151.47–151.49, in cargo tanks unless those tanks have been endorsed through a Certificate of Inspection to carry those substances. Forei gn ships and ships traveling to foreign destinations must meet additional certification requireme nts (33 CFR §§ 151.33–151.35). Ships carrying Category C or D oil-like subs tances must also meet additional operating requirements, such as having monitoring and co ntrol equipment installe d and meeting damage stability requirements (33 CFR § 151.37).

To discharge NLS residue to the sea, the ship must be at least 12 nautical miles from the
nearest land. Additional depth restrictions and maximum ra tes of discharge also apply for particular types of residue (46 CFR § 153.1128). Di scharges of NLS residue from slop tanks are also subject to additional restri ctions (46 CFR § 153.1126). If a sh ip cannot meet these discharge requirements, the NLS residue must be retained onboard or discharged to a reception facility. If the NLS cargo or residue is being transferred at a port or terminal of the United States, the operator of the ship must notify the port or termin al at least 24 hours in advance of the name of the ship and the name, category, and volume of the NLS cargo that will be unloaded (33 CFR § 151.43).

6.2.1.1.3 Annex V Implementation – Prevention of Garbage Pollution from Ships

The requirements of Annex V of MARPOL, pe rtaining to garbage pollution from ships, are implemented by the Coast Guard through regulations found at 33 CFR §§ 151.51–151.77. These regulations apply to all ships of U.S. re gistry or nationality, all ships operated under the authority of the United States (including recrea tional and uninspected ve ssels), and all ships

12 

### Coast Guard regulations currently implement a prior version of Annex II. Parts 151 and 153 are currently under revision to implement revised Annex II, dated November 1, 2004. Navigation and Vessel Inspection Circular No. 03-06 contains guidance on the Coast Guard’s implementation of revised Annex II.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 444 operating in the navigable waters or the Exclus ive Economic Zone of the United States. They do not apply to warships, naval a uxiliary, other sh ips owned or operated by the United States when engaged in noncommercial service, or any sh ip specifically excluded by MARPOL (33 CFR § 151.51).

The regulations prohibit the discharge of garbag e into the navigable waters of the United States by any person onboard any ship unless the requireme nts of MARPOL are followed. Commercial ships are permitted to discharge bulk dry cargo residues into the Great Lakes provided certain requirements ar e met (33 CFR § 151.66). As with Annex V, the discharge of plastic or garbage mixed with pl astic into the sea or navigable waters of the United States is flatly prohibited (33 CFR § 151.67).

The Coast Guard’s regulations also impleme nt the recordkeeping, waste management plan, placard, inspection for compliance and enforcement, and reporting requirements of MARPOL (33 CFR §§ 151.55, 151.57, 151.59, 151.61, and 151.65).

As with MARPOL, oil and greas e are pollutants of potential concern found in incidental discharges that would be dire ctly regulated by APPS and the re levant implementing regulations. Like MARPOL, APPS and its relevant implemen ting regulations may indirectly regulate other pollutants found in incidental vesse l discharges, such as metals, to the extent that they are found in any of the noxious liquid substances or garbage categorized under Annex II and Annex V or the Coast Guard’s implementing regulations a nd are prevented from entering incidental discharge streams. As with MARPOL, APPS and the relevant implementing regulations only apply to those vessels that meet the size thresholds established in MARPOL.

6.2.2 Clean Water Act (CWA) §§ 311, 312/Oil Pollution Control Act

6.2.2.1 CWA § 311, Oil and Hazardous Substances

Clean Water Act (CWA) § 311 (Oil and Hazardous S ubstances Liability) states that it is U.S. policy that there should be no discharges of oil or hazardous substances into waters of the U.S., adjoining shorelines, into or upon the wate rs of the contiguous zone, and in certain other specified instances, except where permitted under MARPOL/APPS or where in quantities the president has, by regulation, determined not to be harmful (33 U.S.C. §§ 1321(b)(1)–(b)(3)). The term “discharge” excludes discharges in co mpliance with a National Pollutant Discharge Elimination System (NPDES) permit under CWA § 402; discharges anticip ated in the NPDES permitting process; and discharges incidental to mechanical removal authorized by the president to remove or mitigate a discharge (33 U.S.C. § 1321(a)(2)). A list of hazardous substances EPA has designated under the CWA can be found at 40 CFR § 116.1. 13

13 

### EPA’s regulations implementing § 311 are located at 40 CFR § 110–117.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 445 Any person in charge of a vessel or ons hore facility must immediately notify the appropriate federal agency upon di scovering any harmful discharge of oil or hazardous substance from the vessel or facility under their control. The federal agency will then notify appropriate state agencies. Any person in charge of a vessel or onshore facility who di scharges in violation of the CWA and fails to provide immediate notification to the appr opriate federal agency shall, upon conviction, be fined or imprisoned, or both (33 U.S.C. § 1321 (b)(5)). Owners or operators must respond immediately to any discharge or threat of discharge of oil (33 U.S.C. § 1321 (c)(5)).

This section of the CWA also requires the president to prepare and publish a National Contingency Plan (NCP) for the removal of oil and hazardous substances (33 U.S.C. § 1321(d)(1)). The NCP must include:

 an assignment of duties and responsibilities among federal departments and agencies;

 identification, procurement, maintenance, and storage of equipment and supplies;

 establishment of Coast Guard strike teams; a system of surveillance and notice;

 establishment of a national cen ter to provide coordination and direction for operations in carrying out the plan;

 procedures and techniques to be employe d in identifying, containing, dispersing, and removing oil and hazardous substances;

 a schedule of which chemicals and dispersants may be used in which waters to mitigate any spills;

 a system for states affected by a discha rge to act to remove the discharge; establishment of criteria a nd procedures to ensure imme diate and effective federal identification of and response to discharges or threats of discharges that will endanger public health;

 establishment of procedures and standards fo r removing a worst case discharge of oil;

 designation of federal offici als to act as on-scene coor dinators; establishment of procedures for the coordination of activities; and a fish and wildlife response plan (33 U.S.C. § 1321(d)(2)). The full text of the NCP can be found at 40 CFR Part 300.

6.2.2.2 Oil Pollution Control Act

The Oil Pollution Control Act of 1990 (OPA ), 33 U.S.C. §§ 2701–2762, was passed as an almost immediate response to the Exxon Valdez tanker accident, which caused more than 11 million gallons of crude oil to spill into Alaska’s Price William Sound. The OPA expanded theChapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 446 federal government’s authority to respond to oil spills, provided the money and resources necessary for the government to ex ercise its authority, and require d revisions to the National Oil and Hazardous Substances Pollution Contingency Plan to broaden coordination and preparedness planning requirements. The OPA also increase d penalties for regulatory noncompliance, broadened the response and enforcement authori ties of the federal government, and preserved state authority to establish laws governing oil spill prevention and response. Additionally, the OPA created the Oil Spill Liability Trust Fund to help fund some of the cleanup costs and repair damage resulting from oil discharges (discussi on on the exact requirements of the Fund has been omitted). The requirements of the OPA apply to all vessels, onshore facilities, offshore facilities, deepwater ports, and pipelines.

The OPA is implemented by both EPA and the U.S. Coast Guard. EPA regulations on oil spill prevention and response are found in 40 CFR Parts 112 and 300. U.S. Coast Guard regulations regarding oil spill prevention a nd response plans are located at 33 CFR §§ 155.1010– 155.2230 and 49 CFR §§ 130.1–130.33.

6.2.2.3 CWA § 312, Marine Sanitation Devices

The CWA also requires EPA, in consultation w ith the Coast Guard, to promulgate federal performance standards for marine sanitation de vices. These standards must be designed to prevent the discharge of untreat ed or inadequately treated se wage into or upon the navigable waters from vessels (33 U.S.C. § 1322(b)). Both the EPA and Coast Guard have promulgated regulations implementing this provision. The Co ast Guard’s regulations can be found at 33 CFR Part 159, while EPA’s can be found at 40 CFR Part 140.

Because discharges of sewage were exempt ed by Congress from this study, as such discharges are not incidental to the normal operation of a vessel, an in-depth discussion of this provision and its implementing regulations has been omitted.

6.2.3 Organotin Antifouling Paint Control Act

The Organotin Antifouling Paint Control Act of 1988, 33 U.S.C. §§ 2401–2410, prohibits the use of antifouling paints cont aining organotin such as tributyl tin (TBT) on vessels that are 25 meters or less in length, unless the vessel hull is aluminum or the paint is applied to an outboard motor (33 U.S.C. § 2403(b)). The term vessel is defined to include “every description of
watercraft or other artificial contrivance used, or capable of being used, as a means of transportation on water” (33 U.S.C. § 2402(11)).

The Act also prohibits the sale, purchase, a nd application of antifouling paint containing organotin unless the paint has been approved by EPA as being a qualified antifouling paint. Under the Act, “antifouling paint” includes any “coating, paint, or tr eatment that is applied to a
vessel to control fresh water or marine fouli ng organisms” (33 U.S.C. § 2402(2)). A qualifiedChapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 447 antifouling paint is one that ha s a release rate of not more than 4.0 micrograms per square centimeter per day (33 U.S.C. § 2402(6)).

As noted in Section 6.1.2, in September 2008 th e United States Senate gave its advice
and consented to ratification of the Interna tional Convention on the C ontrol of Harmful AntiFouling Systems on Ships. However, the United States will not deposit its instrument of ratification with the IMO until Congress adop ts the necessary implementing legislation. Implementing legislation is pending. See Clean Hull Act of 2009, H.R. 3618, 111th Congress (1st Session 2009). EPA has alr eady canceled all U.S. FIFRA re gistrations for TBT antifouling paints. The last cancellation became effectiv e December 31, 2005. Any current use of these products is dwindling because th ere are very limited or no stocks of the products remaining on the market. Also, the International Convention has made it difficult and undesirable for vessel owners/operators to use TBT antifouling paints.

Additionally, as discussed above , EPA has prohibited the use of TBT or other organotins as biocides on any vessel covere d by the Vessel General Permit.

The Organotin Antifouling Paint Control Act onl y regulates the use of organotin, it does not extend to other pollutants of potential risk that may be present in antifouling hull coatings. Although the Act banned new applications of an tifouling hull coatings containing organotin, organotin may still be present in residual quantities on older vessels.

6.2.4 National Invasive Species Act

The primary purpose of the National Inva sive Species Act of 1996 (NISA), which reauthorized and amended the Non-Indigenous A quatic Nuisance Prevention and Control Act of 1990, is to prevent, monitor, and control the unintentional introducti on and dispersal of nonindigenous species into waters of the United St ates through ballast water and other pathways (16 U.S.C. § 4701(b)). The voluntary guidelines and mandatory regulations required by NISA apply, with only few exceptions, to all vessels equi pped with ballast water tanks that operate in
waters of the United States. 14



## Because ballast water was specifically exempted from this study by P.L. 110–299, an indepth discussion of the ballast water requirements of NISA has been omitted. 15 

## In addition to ballast water guidelines, however , NISA requires the development of guidelines to prevent the spread of nonindigenous species from other vessel operations, such as hull fouling.

14 

### The Act requires that the Coast Guard and the Department of Defense implement ballast water management programs for seagoing vessels under their control (16 U.S.C. § 4713).

15 

### For the ballast water requirements, see the text of the Ac t at 16 U.S.C. §§ 4701–4751 as well as the Coast Guard’s regulations at 33 CFR Part 151, subparts C and D.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 448 For example, the Coast Guard’s regulations re quire that all vessels equipped with ballast water tanks that operate in the waters of the U.S. have fouling organisms removed from their hulls, piping, and tanks on a regular basis, and th at any removed substances be disposed of in accordance with local, state, and other fe deral regulations (33 CFR § 151.2035(a)(6)).

The National Invasive Species Act does not directly regulate any of the pollutants of potential concern discussed in this study; the Ac t is focused solely on preventing the spread of nonindigenous species.

6.2.5 Hazardous Materials Transportation Act

The Hazardous Materials Trans portation Act, 49 U.S.C. §§ 5101 et seq. , regulates the transportation of hazardous material in intersta te, intrastate, and foreign commerce. The Act, which implements MARPOL Annex III, includ es registration, reporting, and recordkeeping requirements and applies to any vessel involved in transporting hazardous ma terial in commerce.

The Act, and its implementing Hazardous Mate rials Regulations (HMR), 49 C.F.R. parts 171-180, apply to anyone who transports hazardou s material in commerce, causes hazardous material to be transported in commerce, is invol ved in any way in the design and manufacture of containers used to transport hazardous material , prepares or accepts hazardous material for transport in commerce, is responsible for the safety of transporting hazardous material in commerce, or certifies compliance with any requ irement under the Act (49 U.S.C. § 5103(b)).

Anyone transporting a hazardous material (inc luding a hazardous waste) by vessel must file a registration statement with the Department of Transporta tion (49 U.S.C. § 5108), and must also follow requirements addres sing personnel and personnel trai ning, inspections, equipment, and safety procedures (49 U.S.C. § 5106).

The Hazardous Materials Transportation Act doe s not directly regulate the discharge of any pollutants of potential concern. Instead, the requirements of the Act ensure that hazardous materials are transported safely and securel y, thereby lessening the likelihood that hazardous pollutants will contaminate incidental vessel discharges.

6.2.6 National Marine Sanctuaries Act

The National Marine Sanctuaries Act, 16 U.S. C. § 1431 et seq., authorizes the Secretary of Commerce to designate and protect areas of the marine environment that are of special national significance because of th eir conservation, recreational, ecological, historical, scientific, educational, cultural, archeological, or esthet ic qualities (16 U.S.C. § 1431(a)). The Act is implemented by the National Oceanic and At mospheric Administration (NOAA) through its regulations at 15 CFR Part 922.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 449 The National Marine Sanctuary Program cu rrently consists of 13 national marine
sanctuaries and one marine na tional monument: Thunder Bay (Gr eat Lakes), Stellwagen Bank (Massachusetts), Monitor (an archeological site off the coast of Virginia), Gray’s Reef (Georgia), the Florida Keys, Flower Garden Banks (Gulf of Mexico), Fagatele Bay (American Samoa), Hawaiian Islands/Humpback Whale, Papah ā naumoku ā kea National Monument, Channel Islands, Monterey Bay (California), Gulf of the Farall ones (California), Cordel l Bank (California), and the Olympic Coast (Washington).

Additional restrictions and requirements may be imposed on vessel ow ners/operators who operate in or around these areas. For example, NOAA’s regulations pert aining to the Hawaiian Islands/Humpback Whale National Marine Sanctuary prohibit the discharge or deposition of any material or other matter in the sanctuary, or outsi de the sanctuary if the discharge or deposit will subsequently enter and injure a humpback wh ale or humpback whale habitat, unless that discharge or deposition is carried out according to the terms or conditions of a federal or state permit (15 CFR § 922.184(a)(5)). Vessels operating in this area must also avoid coming within 100 yards of any humpback whale (except wh en authorized under the Marine Mammal Protection Act and Endangered Species Act) (15 CFR § 922. 184(a)(1)).

The National Marine Sanctuaries Act does not di rectly regulate by name the discharge of any of pollutants of potential concern. However, the additional restrictions and requirements developed for many of the specific sanctuaries in clude direct prohibitions on the discharge of certain materials. For example, the regulations specific to the Channel Is lands National Marine Sanctuary prohibit the discharge or deposition of “any material or other matter” except fish or fish parts, and water and “other biodegradable effluents incidental to vessel use.” (15 CFR § 922.72(a)(2)). The regulations gover ning the Gulf of the Farallone s National Marine Sanctuary prohibit the discharge “fro m within or into the Sanctuary, ot her than from a cruise ship, any water or other matter except: ... clean vessel deck wash down, clean vessel engine cooling water, clean vessel generator cooling water, clean bilge water, or anchor wash.” (15 CFR § 922.82(a)(2)(iii)).

6.2.7 Resource Conservation and Recovery Act

The Resource Conservation and Recove ry Act (RCRA), 42 U.S.C. § 6901–6992k, was
enacted in 1976 to amend the Solid Waste Disposal Act of 1965. RCRA was designed to minimize the hazards of waste disposal; conser ve resources through wast e recycling, recovery, and reduction; and ensure that waste management practices are protectiv e of human health and the environment. The RCRA requirements apply to vessels to the extent th at they create, carry, or dispose of solid or hazardous wastes.

By regulation, a “hazardous wast e” under RCRA is one that fa lls on any number of lists EPA has created, or one that exhibits at least one of the following characteristics: ignitibility, corrosivity, reactivity, or toxicity (40 CFR § 261.3). A “solid waste” is any material that has beenChapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 450 discarded; including any ma terial that has been abandoned or recy cled or is inherently waste-like (40 CFR § 261.2).

Subtitle C of RCRA establishes a “cradle- to-grave” system that addresses hazardous waste management from the moment of genera tion through ultimate disposal. The provisions of Subtitle C apply to all generators and transp orters of hazardous waste (42 U.S.C. §§ 6921–6939). A “generator” is someone “whose act or proces s produces hazardous waste...or whose act first causes a hazardous waste to become subject to regulation” (40 CFR § 26 0.10). A “transporter” is anyone “engaged in the offsite transportation of hazardous waste by air, rail, highway, or water” (40 CFR § 260.10). A generator of a hazardous waste is subject to the requirements of subtitle C on packaging, labeling, marking, placarding, storage, recordkeeping, and inspection (40 C.F.R. part 262, subpart C). Additionally, both generators and transporters are required to use a manifest system to ensure that all hazardous waste subject to transport arrives at the designated treatment, storage, or disposal facility ( 42 U.S.C. §§ 6922(a)(5), 6923(a)(3)).

Hazardous waste generated on public vessels (i .e., those vessels owned or chartered by the United States and engaged in noncommercial serv ice) is not subject to the storage, manifest, inspection, or recordkeeping requirements of RC RA until the waste is transferred to a shore facility, unless the waste is stor ed on the vessel for more than 90 days after the vessel is no longer in service or the waste is transferred to another public vessel within th e territorial waters
of the United States and is stored on that vessel for more than 90 da ys after the date of transfer (42 U.S.C. § 6939d). In addition, any "industrial di scharges which are point sources subject to [NPDES[ permits" are excluded from the defini tion of solid waste unde r RCRA (42 U.S.C. § 6903(27)).

RCRA's primary effect on study vessel disc harges is indirect; RCRA's extensive requirements concerning the handling of any h azardous waste generated, stored or transported
onboard the vessel ensure that such wastes do no t make their way into the study discharges. However, because study vessel discharges are not subject to NPDES permitting, they would not qualify for the "industrial point so urce discharge exclusion" a nd, thus, could be subject to applicable RCRA requirements.

6.2.8 Federal Insecticide, Fungicide, and Rodenticide Act

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. § 136–136y, provides the basis for the regulati on, sale, distribution, and use of pesticides in the United States.
FIFRA authorizes EPA to review an d register pesticides for specif ied uses, as well as suspend or cancel the registration of a pestic ide if subsequent information shows that continued use would pose unreasonable risks.

One of FIFRA’s primary requirements is that pe sticides be registered by EPA before they may be sold or distributed in the United States . To obtain a registration, a pesticide manufacturerChapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 451 must submit a registration application to EPA that includes a proposed label containing specific directions for use of the pesticid e. The application must also in clude or cite scientific data sufficient to support an EPA finding that the pesticide, when used according to label directions,
will not cause unreasonable adverse effects on the e nvironment (a risk benefit standard that takes into account the social, economic, and environmental costs and benefits as sociated with use of the pesticide). It is a violation of FIFRA to use a pesticide in a ma nner inconsistent with its label.

Pesticides may be registered as either ge neral use or restricted use. A general use pesticide may be applied by anyone, while a restricted use pesticide may only be applied by certified applicators (applicators specifically certified by EPA or a state to apply restricted use pesticides) or persons working under the dir ect supervision of a certified applicator.

Vessels that use FIFRA-registered products onboard or as antif ouling compounds must follow all FIFRA labeling requirements.

FIFRA governs the use of pestic ides, including thos e applied aboard ve ssels in the United States. Although FIFRA does not di rectly regulate vessel discharg es, the requirements of FIFRA require that pesticides are used in accordance with their label in structions, which may indirectly limit the quantity of pesticide related pollutants that end up in incidental vessel discharges.



## 6.3 A DDITIONAL 

## I NTERNATIONAL AND 

## F EDERAL 

## L AWS



## EPA has identified a number of international and federal laws that fall outside the scope of this study, but which merit mentioning for information purposes.

6.3.1 International Convention on the Preventi on of Marine Pollution by Du mping of Wastes and Other Matter

The International Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, commonl y referred to as the London Conve ntion, entered into force in 1975. The London Convention prohibits the dumping of certain hazardous ma terial and requires a permit for other identified materials and wa stes. In 1996, the IMO adopted a more stringent protocol, which took effect in 2006. The United States is a party to the original London
Convention but has not ratified th e 1996 protocol. The United Stat es implements the original London Convention through the Marine Protection, Research and Sa nctuaries Act, 33 U.S.C. §§ 1401–1445. The London Convention and Protocol do no apply, however, to the disposal into the
sea of matter incidental to or derive d from the normal operation of vessels.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 452 6.3.2 International Convention on Oil Pollution, Preparedness, Response and Cooperation

To emphasize the importance of effective prepar ation for combating o il spills, in 1990 the IMO adopted the International Convention on Oil Pollution, Preparedness, Response and Cooperation (OPRC). The OPRC, which entered into force in 1995 and has been ratified by the United States, establishes a global framework for international cooperation in responding to oil pollution. OPRC includes requirements such as onboard oil pollution emergency plans, the reporting and prompt investigation of sp ills, and coordinated response actions.

6.3.3 International Convention Relating to Int ervention on the High Seas in Cases of Oil Pollution Casualties

The International Convention Re lating to Intervention on the High Seas in Cases of Oil Pollution Causalities was adopted by the IMO in 1969. The Convention entered into force in 1975 and has been ratified by the United States. Th e purpose of the Convention is to affirm the right of coastal states to take such measures on the high seas as may be necessary to prevent, mitigate, or eliminate danger to th eir coastlines or related interests from spills of oil and other substances following marine accidents.

6.3.3.1 Intervention on the High Seas Act

The Intervention on the High Seas Act, 33 U.S.C. §§ 1471–1487, authorizes the Coast
Guard to intervene whenever ther e is a ship collision, stranding, or other in cident or occurrence that creates a grave and imminent danger to the coastline or related interests of the United States. This Act implements the International Conventio n Relating to Intervention on the High Seas in
Cases of Oil Pollution Casualties.

6.3.4 Comprehensive Environmental Response, Compensation, and Liability Act

The Comprehensive Environmental Respons e, Compensation, and Liability Act (CERCLA), 42 U.S.C. §§ 9601–9675, regulates the rel ease or substantial threat of release of hazardous substances (or those dangerous to public health or welfare) into the environment. The liability provisions of CERCLA are expressly app licable to releases from vessels. Additionally, CERCLA requires any person in charge of a vess el to immediately notif y the National Response Center as soon as he has knowledge of any releas e of a hazardous substance from that vessel in a quantity equal to or greater than a re portable quantity (42 U.S.C. §§ 9602, 9603(a)).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 453 6.3.5 CWA § 402, National Pollutant Disc harge Elimination System (NPDES)

In December 2008, EPA issued an NPDES general permit, pursuant to CWA § 402, that is applicable to all vessels operating in a capacity as a means of transportation (except
recreational vessels as define d in CWA § 502[25] and study vessels (except for their ballast water discharges) that have disc harges incidental to their normal operations into waters of the United States. The permit establishes technology-bas ed effluent limits for 26 different types of vessel discharges in the form of best manageme nt practices (BMPs), as well as water qualitybased effluent limitations. The permit also in cludes inspection, mon itoring, reporting, and recordkeeping requirements.

For study vessels, coverage under the gene ral permit is limited to ballast water discharges. For that reason, a lengt hy discussion of the permit fa lls outside the scope of P.L. 110–229. For more information about this permit, please visit: www.epa.gov/npdes/vessels.

6.3.6 Title XIV of the Consolidated Appr opriations Act, 2001—Certain Alaskan Cruise Ship Operations

Title XIV sets standards for sewage and graywater discharges from large cruise ships (those authorized to carry 500 passe ngers or more for hire) while ope rating within certain waters in Alaska. The law prohibits these large cruise ships from discharging untreated sewage while operating in particular waters, but allows the discharge of treated sewage and graywater if certain
conditions are met.

6.3.7 Toxic Substances Control Act

The Toxic Substances Control Act (TSC A), 15 U.S.C. §§ 2601–2695, was enacted in 1976 to provide EPA authority to collect inform ation regarding chemical substances and to regulate unreasonable risks from the manufacture, import, processing, dist ribution in commerce, or use or disposal of chemical substances in the United States. EPA implements TSCA through its regulations at 40 CFR Parts 700–766.

TSCA addresses the production, importation, di stribution in commerce, use, and disposal
of chemical substances and mixt ures of chemical substances ge nerally, and also specifically regulates the following chemical substances: pol ychlorinated biphenyls (PCBs), asbestos, radon, lead, and mercury. TSCA requires EPA to maintain an inventory of each chemical substance manufactured or processed in the United States . Chemical substances as defined under TSCA do not include substances regulated under other specified laws, such as food additives, pesticides, drugs, cosmetics, tobacco, nuclear material, and munitions. Chemi cal substances listed on the inventory are considered “exis ting,” and those not listed are considered “new.” Existing substances are subject to any re gulations or orders the Agency has issued for those substances.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## 454 New substances are subject to premanufacture no tice requirements, described in Section 5 of
TSCA.

EPA can collect information on chemical subs tances and chemical mixtures under TSCA, and EPA has the authority to regulate the use or di sposal of chemicals or chemical mixtures if EPA finds that activity presents an unreasonable risk of injury to health or the environment. TSCA would allow EPA to regulate chemicals c ontained in incidental discharges were the Agency to find it meets this standard.



## 6.4 A PPLICATION OF 

## L EGAL 

## A UTHORITIES TO 

## D ISCHARGES 

## I NCIDENTAL TO

THE 

## N ORMAL 

## O PERATION OF 

## S TUDY 

## V ESSELS



## The preceding subsections discussed a number of international treaties and domestic laws that have been adopted to address the envi ronmental impacts of vessel discharges. These subsections also include a summary of how each of the described treaties, statutes, and regulations would regulate specific incidental vessel discharges and specific vessels. The following tables provide additional information, in greater specifici ty, regarding the applicability
of each of the international treat ies and domestic laws to incidental vessel discharges.

Table 6-1 shows which international treaties and federal laws apply to the types of incidental discharges that might occur on study vessels. The purpose of this table is to summarize the preceding discussion and make clear which incidental discharg es are regulated or potentially regulated by existing intern ational and domestic laws. 16



## Table 6-2 shows which treaties, statutes, and regulations apply to certain size vessels. This table is not meant to imply that each cl ass of vessel shown is covered by a particular statute/treaty in all instances. Whether a partic ular law/treaty applies to a particular vessel depends on vessel-specific circumstances, such as the vessel’s size and class, as well as where that vessel is operating and what it is discharging. In many in stances the treaties/laws shown classify vessels by weight rather than length. For the purposes of this table, EPA estimated the length that would correspond w ith a given vessel weight.

16 

### Note that for many of the authorities listed, application may depend on vessel- or discharge-specific circumstances (e.g., at what concentration certain subs tances are present in the discharge).Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject toRegulation under Federal Law or a Binding International Obligation of the United StatesTable 6. 1. International Treaties and Federal Laws Applicable to DischargesIncidental to the Normal Operation of Vessels

Deck Washdown and Runoff & Above Water Line Hull Cleaning Bilgewater Shaft Packing Gland Effluent Ballast Water 1 Antifouling Leachate from Antifouling Hull Coatings Aqueous Film-Forming Foam (AFFF) Boiler /Economizer Blowdown Cathodic Protection Chain Locker Effluent Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil to Sea Interfaces Distillation and Reverse Osmosis Brine Elevator Pit Effluent Firemain Systems Fresh-Water Layup Gas Turbine Water Wash Graywater Motor Gasoline and Compensating Discharge Non-Oily Washwater Refrigeration and Air Condensate Discharge Seawater Cooling Overboard Discharge Seawater Piping Biofouling Prevention Boat Engine Wet Exhaust Sonar Dome Discharge Underwater Ship Husbandry Discharges Welldeck Discharges Graywater Mixed with Sewage Exhaust Gas Scrubber Washwater Discharge Fish Hold Refrigerated Seawater Cooling Systems and/or Ice Slurr y Dischar g esInternationalConvention for thePrevention of Pollutionfrom Ships (MARPOL)b,c, db, cb, cbbbbb, cBbbcbbbb, cb,hbbInternationalConvention on theControl of HarmfulAnti-Fouling Systemson ShipseeeInternationalConvention for theSafety of Life at Sea(SOLAS)*(*)SOLAS includes the ISM Code, which calls for a management system to minimize pollutants in vessel discharges. The specifics ofeach management systemvary by vessel.455Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject toRegulation under Federal Law or a Binding International Obligation of the United StatesTable 6.1. International Treatiesand Federal Laws Applicable to DischargesIncidental to the Normal Operation of Vessels456Boundary Waters Treaty/ Great Lakes WaterQuality Agreement†St. Lawrence SeawayRegulationsdAct to Prevent Pollutionfrom Ships (APPS)b,c, db, cb, cbbbbb, cBbbbbbb, cbbbCWA § 311: Oil &Hazardous Substances /Oil Pollution ControlActbbbbbbbbbBbbbbbbbbbOrganotin AntifoulingPaint Control Actea,ea,eHazardous MaterialsTransportation ActfffffffNational MarineSanctuaries ActggggggggggggggGgggggggggggggResource Conservationand Recovery Act(RCRA)ffffffffffFfffffffffToxic SubstancesControl Act (TSCA)ffffffffffFfffffffffFederal Insecticide,Fungicide, andRodenticide Act(FIFRA)aaaKey for Table 6.1:a = regulates pesticide constituents that may be found in dischargeb = discharge regulated by law/treaty to the extent that it contains oilc = discharge regulated by law/treaty to the extent that it prevents contamination by noxious liquid substancesd = discharge regulated by law/treaty to the extentthat it prevents contamination from garbagee = regulates antifouling constituents that may be found in dischargef = regulates toxic substances that may be found in dischargeg = application of law/treaty dependent on requirements specific to the vessel’s locationh = the discharge is regulated by this treaty, but the United States has not ratified the relevant annex†The Boundary Waters Treaty protects the boundary waters of the United States and Canada from pollution generally.Chapter 6 – Analysis of the Extent to which Incidental Discharges are currently subject to Regulation under Federal Law or a Binding Inte rnational Obligation of the United States



## Table 6.2. International Treaties and Federal Laws Applicable to Vessels (by Len gth)

Study Vessels Less Than 79 Feet in Length Study Vessels Greater Than 79 Feet in Length Nonstudy 

### Ve ssels Greater Than 79 F eet in Length

International Convention for the Prevention of Pollution from Ships (MARPOL 73/78)*

Annex I Xx x* x Annex II Xx x x Annex III X x x Annex V Xx x xInternational Convention on the Control of Harmful AntiFouling Systems on Ships X x x International Convention for the Safety of Life at Sea (SOLAS) Boundary Waters Treaty / Great Lakes Water Quality Agreement X x x St. Lawrence Seaway Regulations X x x Act to Prevent Pollution from Ships (APPS) Xx x x CWA § 311: Oil & Hazardous Substances X x x CWA § 312: Marine Sanitation Devices X x x Oil Pollution Control Act (OPA) Xx x x Organotin Antifouling Paint Control Act X
Hazardous Materials Tr ansportation Act X x x National Marine Sanctuaries Act X x x
Resource Conservation and Recovery Act (RCRA) X x x Toxic Substances Control Act (TSCA) X x x Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) X x x

Key for Table 6.2: x = law/treaty applicable to this vessel size xx = law/treaty applicable, but generally fe wer requirements than for larger vessels

* MARPOL treats oil tankers separately—those of 150 gt and abov e are subject to all of the requ irements of the treaty, while those smaller than 150 gt have less stringent requirements. About half of the tankers weighing 150 gt are larger than 79 feet.



## 457Chapter 7 – References



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Metcalf and Eddy, Inc. 1979. Wastewater Engineering. Boston, MA.

Mohr, S., R. Berghahn, W. Mailahn, R. Schmiediche, M. Feibicke, and R. Schmidt. 2009. Toxic and Accumulative Potential of the Antifouling Bi ocide and TBT Successor Irgarol on Freshwater Macrophytes: A Pond Mesocosm Study. Environ. Scr. Technol. (In Press).

Mohr, S., H. Schroder, M. Feibicke, R. Berghahn, W. Arp and A. Nicklisch. 2008. Long-term Effects of the Antifouling Booster Biocide Irgarol 1051 on Pe riphyton, Plankton and Ecosystem Function in Freshwater Pond Mesocosms. Aquat. Toxicol . 90: 109-120.

Mowka, E.J., Jr. 2009. The SeaWater Manual: Fundamentals of Water Chemistry for Marine Aquarists

. Instant Ocean. Available online at: ( http://www.instantocean.com/downloads/b asicsofs alt water/basicsofsaltwater.pdf

.

National Marine Fisheries Service (NMFS). 2009. Fisheries of the United States 2008 . NMFS Fisheries Statistics Division, Silver Springs, MD.



## 460Chapter 7 – References



### NOAA. 1991. Contaminant Trends in the Southern California Bight: Inventory and Assessment. NOAA Technical Memorandom, NOS ORCA 62, National Oceanic and Atmospheric Administration, National Ocean Service, Rockville, MD.

NOAA. 1994. Inventory of Chemical Concentrations in Coastal and Estuarine Sediments . NOAA Technical Memorandum, NOS ORCA 76, National Oceanic and Atmospheric Administration, National Ocean Service, Silver Springs, MD.

NMMA. 2009. 2005 U.S. Recreational Boat Registration Statistics. National Marine Manufacturers Association.

PRC Environmental Management, Inc. 1997. Report of Copper Loading to San Diego Bay, California. Prepared for California Regional Water Quality Control Board, San Diego Region and the San Diego Bay Interagency Wa ter Quality Panel.

Readman JW. 2006. Development, Occurrence and Regulation of Antifouling Paint Biocides: Historical Review and Future Trends. In: I.K. Konstantinou (Ed.) The Handbook of Environmental Chemistry: Antifouling Paint Biocides. Vol. 5: Water Pollution.

Research Systems Inc. 2003. Interactive Data Language (IDL), Version 6.0. Boulder, CO.

Rivera-Duarte, I., G. Rosen, D.B. Chadwick , L. Kear-Padilla, and A. Zirino. 2003. Speciation and Bioavailability of Copper in San Diego Ba y; Free Copper Ion Concentration as Main Vector to Study the Effect of Copper Leaching from Antifouling Paints. Presented at: International Symposium on Prevention of Pollution from Ship s and Shipyards, New Orleans, LA, November 5-7, 2003.

Schiff, K., D. Diehl, and A. Valkirs. 2003. Copper Emissions from Antifouling Paint on Recreational Vessels. Mar. Poll. Bull. 48(2004): 371–377.

Sekizawa, J.,S. Dobson, and R.J. Touch III. 2003. Diethyl Phthalate. Concise International Chemical Assessment Document 52. World Health Organization.

Sherwood Pumps, Marine Engine Cooling Water Pumps. 2009. Flow Performance

. ( http://www.sherwoodpumps.com/en-us/Products/E ngine+OEM+S o lutions/Flow+Performance/ )

Singhasemanon, N. 2008. Assessment of Antifouling Paint Use Indicators in Cal ifornia Marinas. CA Department of Pesticide Regulation. Presented at: CAHMPC Annual Conference, Ventura, CA.

Singhasemanon, N., E. Pyatt, and J. Bacey. 2009. Monitoring for Indicators of Antifouling Paint Pollution in California Marinas. EH08-05. California Environmental Protection Agency, Environmental Monitoring Branch, California Depa rtment of Pesticide Regulation, Sacramento, CA.

SPSS. 1996. SYSTAT, Version 6.1. Chicago, IL.

SWRCB. 1996. Chemistry, Toxicity and Benthic Community Conditions in Sediments of the San Diego Bay Region. Final Report. September 1996. State Wa ter Resources Control Board, National Oceanic and Atmospheric Administration, Califor nia Department of Fish and Game Marine Pollution Studies Laboratory, University of Santa Cruz, and Moss Landing Marine Laboratories.



## 461Chapter 7 – References



### Ten Hallers-Tjabbes, C.C., J.F. Kemp, and J.P. Boon. 1994. Imposex in Whelks ( Buccinum undatum ) from the Open North Sea: Relation to Shipping Traffic Intensities. Mar. Pollut. Bull. 28: 311-313.

TDC Environmental. 2004. Copper Sources in Urban Runoff and Shoreline Activities; Information Update. Prepared for the Clean Estuary Partnership.

Thomas, K., K. Raymond, J. Chadwick, and M. Waldoc k. 1999. The Effects of Short-term Changes in Environmental Parameters on the Release of Biocides from Antifouling Coatings: Cuprous Oxide and Tributyltin. Appl. Organomet. Chem. 13: 453-460.

Thomas, K.V., T.W. Fileman, J.W. Readman, a nd M.J. Waldock. 2001. Antifouling Paint Booster Biocides in the UK Coastal Environment and Potential Risks of Biological Effects. Mar. Pollut. Bull. 42(8): 677-688.

Thomas, K.V., M. McHugh, and M. Waldock. 2002. Antifouling Paint Booster Biocides in UK Coastal Waters: Inputs, Occurrence and Environmental Fate. Sci. Total Environ. 293: 117–127.

United Fishermen of Alaska. 2010. Comments on Draft Report To Congress: Study of Discharges Incidental to Normal Operation of Comm ercial Fishing Vessels and Other Non-Recreational Vessels Less than 79. (Docket ID: EPA-HQ-OW-2009-0828-0025.1.pdf), Washington, DC. Available at: www.regulations.gov

.

USCG. 2009. Marine Information for Safety and Law Enforcement (MISLE) Database . U.S. Coast Guard. Washington, D.C.

USEPA. 1976. Quality Criteria for Water. “Red Book.” EPA PB-263-943. U.S. Environmental Protection Agency. Washington, D.C. Available at http://www.epa.gov/waterscience/criteria/library/redbook.pdf

.

USEPA. 1986a. Ambient Water Quality Criteria for Bacteria -1986. EPA-440/5-84-002. U.S. Environmental Protection Agency. Washington, D.C. (January). Available at http://www.epa.gov/waterscience/beaches/files/1986crit.pdf

.

USEPA. 1986b. Quality Criteria for Water-1986. “Gold Book.” EPA 440/5-86-001. U.S. Environmental Protection Agency. Washington, D.C. (May). Available at http://www.epa.gov/waterscience/criteria/library/goldbook.pdf

.

USEPA. 1991. Technical Support Document for Wa ter Quality-Based Toxics Control . EPA/505/2-90- 001. U.S. Environmental Protection Agency. Washington, D.C.

USEPA. 1993. Guidance Specifying Management Measures fo r Sources of Nonpoint Pollution in Coastal Waters. Chapter 5: Management Measure for Marinas and Recreational Boating. EPA-840-B93-001c. U.S. Environmental Protection Agency. Washington, D.C.

USEPA. 1996. The Metals Translator: Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion. EPA 823-B-96-007. U.S. Environmental Protection Agency. Washington, D.C.



## 462Chapter 7 – References



### USEPA. 1997. Ecological Risk Assessment Guidance for Superfund: Process for Designing and Conducting Ecological Risk Assessments - Interim Final. EPA 540-R-97-006. U.S. Environmental Protection Agency. Washington, D.C. Available at http://www.epa.gov/oswer/riskasse ssment/ecorisk/ecorisk.htm

.

USEPA. 1999. Uniform National Discharge Standards for Vessels of the Armed Forces – Phase I Technical Development Document. EPA 821-R-99-001. U.S. Environmental Protection Agency. Washington, D.C. Available online at: http://unds.bah.com/TDD.pdf

.

USEPA. 2001. Nutrient Criteria Technical Manual, Coastal and Marine Waters, October, 2001. Chapter 9. U.S. Environmental Protection Agency. Washington, D.C.

USEPA. 2002. Total Maximum Daily Loads for Toxic Po llutants, San Diego Creek and Newport Bay, California. U.S. EPA Region IX. San Francisco, CA.

USEPA. 2003a. Irgarol: Updated Environmental Risk Assessment for Antifoulant Use. Memorandum from K. Montague and R. Petrie to D. Edwards through N. Cook, July 15, 2003. Office of Pesticide Programs, Antimicrobial Division, U.S. Environmental Protection Agency. Washington, D.C.

USEPA. 2003b. Technical Summary of Information Available on the Bioaccumulation of Arsenic in Aquatic Organisms . EPA-822-R-03-032. U.S. Environmental Protection Agency. Washington, D.C. (December).

USEPA. 2006. National Recommended Water Quality Criteria . U.S. Environmental Protection Agency. Washington, D.C. Available online at: http://www.epa.gov/waterscience/criteria/wqctable/index.html

.

USEPA. 2007. Aquatic Life Ambient Freshwater Quality Criteria – Copper; 2007 Revision. EPA-882-R07-001. U.S. Environmental Protection Agency. Washington, D.C. (February).

USEPA. 2008a. Economic Impact Analysis of the Recreational Vessel Permit . U.S. Environmental Protection Agency. Washington, D.C. (June).

USEPA. 2008b. Final Sampling Episode Report for Small Boat Engine Wet Exhaust Discharge from Compression Ignition Engines. U.S. Environmental Protection Agency. Washington, D.C. (August).

USEPA. 2008c. Cruise Ship Discharge Assessment Report . EPA842-R-07-005. U.S. Environmental Protection Agency. Washington D.C. (December). Available online at: http://www.epa.gov/owow/oceans/cruise_shi ps/cruise_ship_disch_assess_report.htm l

USEPA. 2008d. Final Issuance of NPDES Vessel General P ermit for Discharges Incidental to the Normal Operation of Vessels Fact Sheet (December) . Available at www.epa.gov/npdes/pubs/vessel_vgp_factsheet.pdf

.

USEPA. 2009. WaterSense Water-Saving Showerheads Fact Sheet. United States Environmental Protection Agency, Washington, DC. Available at http://www.epa.gov/watersense/docs/showerhead_factsheet508.pdf

.



## 463Chapter 7 – References



## 464 Valkirs, A.O., B.M. Davidson, L.L. Kear, R.L. Fransham, A.R. Zirino, and J.G. Grovhoug. 1994. Environmental Effects from In-Water Hull Cleaning of Ablative Copper Antifouling Coatings. Technical Document 2662. Naval Command, Cont rol and Ocean Surveillance Center, RDT&E Division, San Diego, CA.

Valkirs, A.O., P.F. Seligman, E. Haslbeck, and J.S. Caso. 2003. Measurement of Copper Release Rates from Antifouling Paint under Laboratory and In -situ Conditions: Implications for Loading Estimation to Marine Water Bodies. Mar. Pollut. Bull . 46: 763-779.

West Marine. 2008. Selecting Antifouling Paint. Available at http://www.westmarine.com/webapp/wcs/st ores/servlet/westadvisor/10001/-1/10001/Antifouling-Paint.htm.

WHOI. 1952. Marine Fouling and its Prevention. Contribution No. 580. Woods Hole Oceanographic Institution. United States Nava l Institute, Annapolis, MD.

Yebra, D.M., S. Kiil, and K. Dam-Johansen. 2004. Antifouling Technology – Past, Present and Future Steps towards Efficient and Environmentally Friendly Antifouling Coatings. Prog. Org. Coat. 50: 75-104.

Zirino, A. and P.F. Seligman. 2002. Copper Chemistry, Toxicity and Bi oavailability and its Relationship to Regulation in the Marine Environment. Technical Document 3140. Space and Naval Warfare Systems Center, San Diego, CA.Appendix A – List of Acronyms



# Appendix A List of Acronyms

AC.......................................... Air conditioning

AFC ....................................... Antifouling coating

AFFF ..................................... Aqueous film forming foam

AFS........................................ Antifouling hull systems

AIS......................................... Aquatic Invasive Species

ANOVA................................. Analysis of Variance

ASTM.................................... American Society for Testing and Materials

ATSDR.................................. Agency for Toxic Substances and Disease Registry

AWT...................................... Advanced Wastewater Treatment

BOD....................................... Biochemical oxygen demand

BLM ...................................... Biotic Ligand Model

BM ......................................... Benchmark

BMP....................................... Best management practice

BTEX..................................... Benzene, toluene, ethylbenzene, xylene

C............................................. Celsius

CCC....................................... Criteria Continuous Concentration

CFR ....................................... Code of Federal Register

CFU ....................................... Colony Forming Units

CMC...................................... Criteria Maximum Concentration

C-PORT ................................ Conference of Professional Operators for Response Towing

CRWQCB ............................. California Regional Water Quality Control Board

CSO ....................................... Combined sewer overflow

CSV........................................ Comma-separated value

COC....................................... Chain of custody

COD....................................... Chemical oxygen demand

CTR ....................................... California Toxics Rule

CWA...................................... Clean Water Act

DBP........................................ Di-n-butyl phthalate

A-1Appendix A – List of Acronyms



## DC.......................................... Direct current

DEHP

.................................... Bis(2-ethylhexyl) phthalate

DO.......................................... Dissolved oxygen

DOC....................................... Dissolved organic carbon

DOD....................................... Department of Defense

EDD ....................................... Electronic data deliverable

EPA........................................ Environmental Protection Agency

F ............................................. Fahrenheit

f

d 

## ............................................. Average dissolved fraction

FW ......................................... Fresh water

gpd ......................................... Gallons per day

gpm ....................................... Gallons per minute

GRT....................................... Gross register ton

HEM...................................... N-hexane extractable materials

HH ........................................ Human health

HPLC .................................... High performance liquid chromatography

HQ ......................................... Hazard quotient

ICCP...................................... Impressed current cathodic protection

IDL ........................................ Interactive Data Language

IQR........................................ Interquartile range

kw .......................................... Kilowatt

LCDR .................................... Lieutenant Commander

LCPL..................................... Landing craft personnel large

LNB ....................................... Lower Newport Bay

MA DEP................................ Massachusetts Department of Environmental Protection

MARPOL.............................. International Convention for the Prevention of Pollution
from Ships

MDL ...................................... Maximum daily load

MdR....................................... Marina del Rey

MF ......................................... Membrane filtration

MISLE................................... Marine Information for Safety and Law Enforcement

A-2Appendix A – List of Acronyms



## MPN ...................................... Most Probable Number

MS.......................................... Microsoft

MSD....................................... Marine Sanitation Device

MSIS...................................... Marine Safety Information System

MTBE.................................... Methyl tertiary butyl ether

ND.......................................... Not detected

NH3-N ................................... Ammonia (total, as nitrogen)

NMMA .................................. National Marine Manufac turers Association

NO3/NO2-N .......................... Nitrate/Nitrite (as nitrogen)

NOAA.................................... National Oceanic and Atmospheric Administration

NP .......................................... Nonylphenol

NPEC..................................... Nonylphenol polyethoxy carboxylate

NPEO .................................... Nonylphenol polyethoxylate

NRWQC................................ National Recommended Water Quality Criteria

NTU ....................................... Nephelometric Turbidity Units

O&G...................................... Oil and grease

OCPD .................................... Oceans and Coastal Protection Division

OPEO .................................... Octylphenol polyethoxylate

OWOW ................................. Office of Wetlands, Oceans, and Watersheds

PAH ....................................... Polycyclic aromatic hydrocarbon

PBT........................................ Persistent, bioaccumulative, and toxic chemical

PHQ....................................... Potential hazard quotient

P.L. ........................................ Public Law

POTW ................................... Publicly owned treatment works

PPCP ..................................... Pharmaceuticals and personal care product

ppt.......................................... Part(s) per thousand

PSU........................................ Practical salinity unit

P:T ......................................... Power to tonnage ratio

QA/QC .................................. Quality assurance/quality control

QAPP..................................... Quality Assurance Project Plan

QCW...................................... Quality Criteria for Water

A-3Appendix A – List of Acronyms



## RIB ........................................ Rigid inflatable boat

RL

.......................................... Reporting limit

RPD ....................................... Relative percent difference

RPM ...................................... Rotations per minute

RSW ...................................... Refrigerated seawater

SCCWRP .............................. Southern California Coastal Water Research Project

SDRWQCB... ........................San Diego Regional Water Quality Control Board

SGT-HEM............................. Silica Gel Treated n-hexane extractable materials

SH .......................................... Shellfish harvesting

SIYB ...................................... Shelter Island Yacht Basin

SWRCB................................. State Water Resources Control Board

SSO........................................ Sanitary sewer overflow

SVOC .................................... Semivolatile organic compound

SW ......................................... Salt water

TBT........................................ Tributyltin

TIC ........................................ Tentatively identified compound

TIE......................................... Toxicity identification and evaluation

TKN....................................... Total Kjeldahl Nitrogen

TMDL.................................... Total maximum daily load

TOC....................................... Total organic carbon

TP .......................................... Total phosphorus

TRC ....................................... Total residual chlorine

TSS ........................................ Total suspended solids

UK.......................................... United Kingdom

UNDS..................................... Uniform National Discharge Standards

U.S. ........................................ United States

U.S.C...................................... United States Code

USCG .................................... United States Coast Guard

USGS ..................................... United States Geological Survey

VGP ....................................... Vessel General Permit

VESDOC............................... Merchant Vessels of the United States

A-4Appendix A – List of Acronyms



## A-5 VOC....................................... Volatile organic compound

W+O ...................................... Water Quality Criteria for Human Health based on Water
and Organism Consumption

WHO ..................................... World Health Organization

WHOI.................................... Woods Hole Oceanographic Institute

WOD05.................................. World Ocean Database 2005

WTLUS ................................. Waterborne Transportation Li nes of the United StatesAppendix B – Additional Characteristics of the P.L. 110-299 Population



# Appendix B
Additional Characteristics of the P .L. 110 – 299 Vessel Population

This appendix provides additi onal details regarding study vesse ls. These details include additional information on vessel subcategories, gene ral information about vessels’ areas of operation (based upon their hailing port), and additional details regarding vessels ’ age and areas of operation. The discussion is based on data from the 139,814 vessels in the MISLE database iden tified as being within the study vessel population. These data have limitations as discussed in section B.6

.

B.1 Vessel Subcategories

Table B.1 presents the top five sub categories by each general vesse l service to provide insight into the various types of vessels included the categorie s. Except for utility vessels (for which the top five vessel classes are listed), vessel types are displayed for all other ve ssel service categories. Vessel class generally relates to the vessel construction or design whereas the type is a more detailed explanation of the vessels purpose and capabilities. 1 

## As shown in Table B.1 , fish catching vessels – which are the focus of the definition of commercial fishing vessels included by reference in P.L. 110-299 – account fo r the vast majority of commercial fish ing vessels recorded in MISLE.

Table B.1: Top Five Vessel Subcategories by Vessel Service ab



### Vessel Service Vessel Type/Class c 

### Number of Vessels Fish Catching Vessel 68,343 Fishing Catching/Processing Vessel 178 General 174 Motor Propelled Vessels 155 Commercial Fishing Vessel

Fishing Support Vessel 116 Other non-recreational vessels (l ess than 79 feet in length) General 6,954 Dry Cargo Barge 411 Deck Barge 295 Lash / Seabee Barge 36 Freight Barge

Container Barge 8 General 533 Fishing Support Vessel 23 Fish Catching Vessel 21 Container Ship 14 Freight Ship

Ro-Ro/Container 4 General 12,559 Charter Fishing Vessel 2,053 Excursion/Tour Vessel 1,233 Diving Vessel (Recreational) 305 Passenger Vessel

Water Taxi 298

1 

### In addition, although not shown in Table B.1 , a more detailed category exists in the database, vessel subtype . This field further breaks out the vessel types. For example, subtype fields that exist for fish catching vessels include trawlers, shrimpers, and whalers.



## B-1Appendix B – Additional Characteristics of the P.L. 110-299 Population



### Vessel Service Vessel Type/Class c 

### Number of Vessels General 145 Law Enforcement (Non-military) Vessel 47 Buoy/Lighthouse Tender 16 Search and Rescue Vessel 14 Public Vessel, Unclassified

Patrol Ship 10 Bulk Liquid Cargo (Tank) Barge 838 Bulk Liquefied Gas Barge 10 Dry Cargo Barge 7 General 7 Tank Barge

Integrated Tug and Barge (Barge) 4 General 102 Petroleum Oil Tank Ship 22 Gas Carrier 20 Chemical Tank Ship 14 Tank Ship

Bulk Liquid Cargo (Tank) Barge 1 Towing Vessel 7,372 Offshore 650 Research Ship 488 Barge 396 Utility Vessel

School Ship 60 a This table is based on operational, U.S. flagged commercial fishing vessels (all lengths) a nd other non-recreational vessel l ess than 79 feet, including vessels that have an unspecified length (zero or null). b “Unspecified” or “Miscellaneous Vesse l” subcategories were not included am ong the top five vessel subcategories.
c Vessel types are displayed for all vessel service categorie s except for utility vessels; the top five vessel classes are listed for utility vessels. Source:U.S. Coast Guard MISLE database, 2009



### B.1.1 Population of Vessels undergoing Discharge Analysis



## Table B.2 summarizes the population of specific vessel sub-types that were investigated and

samp led by EPA: commercial fishing vessels, water taxis/ferries, tour ve ssels, towing vessels, emergency boats, and vessels classified as recreati onal vessels that operate as non-recreational vessels 2



## . The vessel counts presented in the table provide rough estimates of the number of vessels that may be represented by each categor y of sampled vessels. 3



## EPA generally used the vessel service or current usage to categorize study vessels, however, the MISLE vessel classification generally refers to the category of vessel ba sed on its original construction. The MISLE vessel type field provides the more detail ed explanation of the vessels’ purpose and current
use. A more detailed vessel subtype category also exists in the MISLE database to further break out the
vessel types . For example, MISLE has subtype entries for trawlers, shrimpers, and whalers within the fish catching vessel type, allowing for the population of vessels within these spec ific subtypes to be
estimated.

2 

### EPA discusses the vessels sampled for this report in greater detail in Chapter 2 of this report.

3 

### EPA considers these estimates to be only approximate counts due to the potential misclassification of vessels in MISLE as well as some of the dataset’s ambiguous vessel classifications (e.g. categorizing a vessel as “general”).



## B-2Appendix B – Additional Characteristics of the P.L. 110-299 Population



## B-3 Table B.2: Total Number of Vessels in a Given Subtype which EPA Subsampled

Vessel Service Vessel Type Number of Vessels a 

### Percent of Vessel Type within Vessel Service Commercial Fishing Vessel 69,944 100.0% All Commercial Fishing Vessel 69,944 100.0% Passenger Vessels b 

### 20,953 100.0%
Water Taxi 298 1.4% Ferry 272 1.3%
Excursion/Tour Vessel 1,233 5.9% Utility Vessel 11,034 100.0% Towing Vessel (includes Tugboats) 7,751 70.2% Non-Recreational Vessel 69,870 100.0% Classified as Recreational (on the basis of vessel type) 1,624 2.3%

a Number of vessels accounts for all vessels less than 79 feet in length, including vessels of unspecified length (zero or null) b Most passenger vessels are listed as “general” passe nger vessels: out of the a pproximately 21,000 passenger vessels, nearly 13,000 are listed as “general” passenger vessels. Source: U. S. Coast Guard, MISLE database, 2009



## In addition to the specific vesse l types listed above, EPA sample d recreational vessels used in non-recreational service, in part to determine whether characteristics of their discharges differ from those of other types of vessels used in similar applications. The Clean Boating Act of 2008 covers vessels manufactured for recreational uses, unless they are inspected vessels used commercially.

Table B.3 provides examples of the most common vesse ls classified as r ecreationa l vessels in
MISLE but that are identified as operating in a non-recreational capacit y. Because the analysis presented throughout this section generally de fines the population of moratorium vessels on the basis of the vessel service rather than original ma nufacture purpose, the vesse l population estimate of generated for this
report may overestimates the number of vessels to whic h the moratorium in P.L. 110-299 applies. Most vessels manufactured primarily for pleasure are pe rmanently excluded from NPDES requirements by the Clean Boating Act 4 

## rather than the shorter-term moratorium in P.L. 110-299 as long those vessels meet the definition of a recreational vessel under the Clean Boating Act.

4 

### The Clean Boating Act, P.L. 110-288 defines the term ‘recrea tional vessel’ to mean any vessel that is— ‘‘(i) manufactured or used primarily for pleasure; or (ii) leased, rented, or chartered to a person for the pleasure of that person.” However, th e term recreational vessel excludes any vessel “that is subject to Coast Guard inspection and that is (i) engaged in commercial use or (ii) carries paying passengers.”.Appendix B – Additional Characteristics of the P.L. 110-299 Population



## Table B.3: Examples of Study Vessels in a No n-Recreational Vessel Service, Classified as
Recreational Vessels

Vessel Class Vessel Service Vessel Type Number of Vessels Recreational Passenger Vessel Passenger (Uninspected) 767

Recreational Commercial Fishing Vessel Commercial Fishing Vessel 232 Recreational Utility Vessel Research Vessel 22
Source: U. S. Coast Guard, MISLE database, 2009



## B.2 Vessel Geographical Area of Operation

EPA used MISLE data on hailing port of i ndividual vessel records to characte rize the geographical area of operation of vessels in the selected population. Although the hailing port does not account for the detailed traffic pattern s of a vessel or for the amount of time a given vessel spends in the listed port, it nevertheless can provide informati on on a vessel’s general area of operation. This may be particularly true of vessels that may have a fairly limited range of operation by virtue of their smaller
size or the nature of activities th ey engage in (e.g., tug boat that ope rates within a given port area). Out of the 139,814 vessels in the study vessel populati on, 76,956 MISLE vessel records had sufficiently
detailed information to determine their hailing state and general region of operation. 5



## Of the approximately 77,000 vessels records ha ving sufficiently detailed information to determine their state and genera l region of operation, 20,000 vessels provided one of the hailing ports
listed in Figure B.1 . As evidenced by the figure, certain port cities, such as Seattle, WA and Juneau, AK are predomi nantly commercial fishing centers, while New Orleans, LA and New York, NY are predominantly listed by other non-recr eational vessels. New Orleans, LA, is the most frequently cited hailing port with approximately 1,300 commercial fishing vessels and 3,8 00 other non-recreational
vessels less than 79 feet. These hailin g port distributions were used to inform estimates of vessels in a given water body for EPA’s screening level mode ling in Chapter 4 of this report.

5 

### For the remaining vessels, the hailing port information was either missing or too incomplete to be used in the analysis (e.g., only city name is provided).



## B-4Appendix B – Additional Characteristics of the P.L. 110-299 Population

Figure B.1: Approximate Number of Study Vessels for Hailing Ports Frequently Cited in MISLE

0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 New Orleans, LA

Seattle, WA

New York, NY

Houston, TX

San Francisco, CA

Juneau, AK

Miami, FL

Norfolk, VA

Boston, MA

Houma, LA

Cordova, AK

Homer, AK

Sitka, AK

Kodiak, AK

San Diego, CA

Portland, OR

Key West, FL

Ketchikan, AK

Gloucester, MA

Petersburg, AKHailing Port



### Approximate Number of Vessels Commercial Fishing Vessel
Other Non-Recreational Vessel

Note: This table is based on 76,956 operational, U.S. flagged commer cial fishing vessels and other non-recreational vessel less than 79 feet for which hailing port information is provided in MIS LE. EPA notes that the hailing port inform ation is only available for about half of the “study vessels” listed in
the MISLE database.

Source: U. S. Coast Guard, MISLE database, 2009



## Table B.4 presents the number of vessels by vessel service an d the nine ce nsus divisions, as displayed in Figure B.2 below. 6 

## The divisions are defined by the U.S. Census Bureau as standard geographical units for reporting data for aggregated states. Although not specifically designed for this purpose, the divisions tend to follow the major mari time trade axes and wate rways (e.g., coastwise, inland, Great Lakes, Pacific and Atlantic Oceans, Mississippi River, Gulf of Mexico) and therefore provide useful groupings for reporting vessel population estimates. The majority of approximately 70,000 vessels within the scope of P.L. 110-299 for wh ich MISLE provides a U.S. hailing port operate within the Pacific and South Atlantic divisions (28 and 25 percent of vessels, respectively). This regional distribution is driven in pa rt by the large concentration of co mmercial fishing vessels in the two regions primarily in Alaska with 6,560 vessels and Florida with 3,804 vessels.

6 

### In addition, separate vessel counts are provided for U.S. terr itories (Puerto Rico, US Virgin Islands, American Samoa, and Guam), Canadian provinces (Newfoundland and Labrador, New Brunswick, Quebec, Nova Scotia, Ontario, Alberta, and British Columbia), and for vessels that listed either another foreign hailing port or did not list a hailing port.



## B-5Appendix B – Additional Characteristics of the P.L. 110-299 Population



## Table B.4: Number of Study Vessels by Vessel Serv ic e and Census Division, based on Hailing Port
Information Provided in MISLE.

Census Division Commercial Fishing Vessel Freight Barge Freight Ship Passenger Vessel Public Vessel, Unclassified Tank Barge Tank Ship Utility Vessel Unspecified
New England 7,173 41 39 1,158 14 12 6 302 939

Middle Atlantic 1,585 466 27 1,414 4 8 7 645 1,016

East North Central 414 53 20 1,274 2 28 487 1,467

West North Central 45 181 7 175 4 1 538 172

South Atlantic 9,400 440 83 4,821 15 39 18 1,347 3,062

East South Central 1,606 21 2 378 3 1 479 261

West South Central 6,386 2,23 8 22 1,107 5 65 4 2,732 924

Mountain 59 11 1 142 24 81 Pacific 14,482 129 133 3,187 19 64 5 1,155 2,281 National Total 41,150 3,580 334 13,656 62 221 41 7,709 10,203

U.S.
Territories 230 8 1 353 3 8 46 129

Canadian
Province 3 2

Unknown / Other 28,561 4,42 8 433 6,942 557 694 138 3,279 17,043

This table is based on operational, U.S. flagged commercial fishing vessels and other non-recreational vessel less than 79 feet (including vessels of unspecified length) for which MISLE provides sufficiently detailed ha iling port information. Source: U. S. Coast Guar d, MISLE database, 2009



## B-6Appendix B – Additional Characteristics of the P.L. 110-299 Population

Figure B.2: Geographical Definitions of U.S. Census Divisions



## The geographical distribution of commercial fi shing vessels and other non-recreational vessels less than 79 feet is illustrated in the maps of Figure B.3 and Figure B.4 , respectively. Commercial fishing vessels tend to cluster excl usively along the coastlines. Non-recr eational vessels less than 79 feet
tend to be found on the ma jor U.S. shipping waterw ays such as the Mississi ppi river and the Great
Lakes.

B-7Appendix B – Additional Characteristics of the P.L. 110-299 Population

Figure B.3: Geographical Distribution of Comme rcial Fishing Vessels by Hailing Port State

Source: U. S. Coast Guard, MISLE database, 2009; based on subs et of operational, U.S. flagged commercial fishing vessels for wh ich MISLE provides a hailing port.



## B-8Appendix B – Additional Characteristics of the P.L. 110-299 Population

Figure B.4: Geographical Distribution of Study Vessels ( excluding Commercial Fishing Vessels) by Hailing Port State

Source: U. S. Coast Guard, MISLE database, 2009; based on subs et of operational, U.S. flagged other non-recreational vessels le ss than 79 feet in length (including vessels of unspecified length) for which MISLE provides a hailing port.


## Alaska and Florida both report a high number of commercial fishi ng vessels. These states have long coastal shorelines and the vessel density by miles of tidal shore lines is lower than in other states such as Mississippi, New Hampshire, and Massac husetts that have comparatively fewer miles of shoreline but access to large fishing grounds. Accordi ng to National Marine Fish eries Service data, for example, Massachusetts alone accoun ted for over half of fish landings recorded in New England states in 2007, by pound. 7 

## Figure B.5 illustrates these differences by s howing the density of commercial fishing vessels by m iles of tidal shor elines. The states represented in Figure B.5 account for 99 percent of commercial fishing vessels record ed in MISLE that report a hailing port.

7 

### Annual Commercial Landing Statistics database ( http://www.st.nmfs.noaa.gov/st1/commercial/lan d ings/annual_landings.html ), Accessed May 26, 2009.



## B-9Appendix B – Additional Characteristics of the P.L. 110-299 Population

Figure B.5: Density of Commercial Fishing Vessels in Coastal States, by Mile of Tidal Shoreline

0.0 0.5 1.0 1.5 2.0 2.5 3.0ALLAMSTXDCDEMDPAVACTMAMENHNJNYRIAKCAHIORWAFLGANCSCVessel Density(Number of Vessels / Mile of Tidal Shoreline) Commercial Fishing Vessel Density

Gulf Coast Mid Atlantic North Atlantic Pacific South Atlantic

Coastal states included above account for 99 percent of commercial fishing vessels recorded in MISLE,

Sources: U. S. Coast Guard, MISLE database, 2009; based on subs et of operational, U.S. flagged commercial fishing vessels for w hich MISLE provides a U.S. hailing port. Miles of tidal shorelin e from U.S. Geological Survey and National O ceanic Atmospheric Administration, National Atlas of the United States, Coastline and Shoreline. Miles include shoreline of the outer coast, offshore islands, sounds, and bays, as well as the tidal portion of rivers and
creeks.


## In contrast to commercial fishing vessels, whic h are found almost exclusively along U.S. coasts,
about a third of other non-recreatio nal vessels less than 79 feet in length for which MISLE provides hailing port information have a hailin g port located along inland waterways. Figure B.6 shows the density of these vessels by state, based on inland water area. Several inland and Great Lakes states (e.g., Missouri, Indiana, and Ke ntucky) ex hibit a high vessel density in relati on to their inland water areas, reflecting these states’ adjacency to key navigabl e waterways such as the Mississippi or Missouri Rivers. However, though a vessel lists a city or state as its hailing port, it is unlikely that all vessel operations are confined exclusively to those states waters for many vessels. Additionally, as most vessel traffic may take place on only a small set of navi gable waterways, vessel density in these navigable waters is likely to be even greater than implied by the state-wide numbers shown in Figure B.6 . Hence,
these are relative de nsities which likely depict which state waters ha ve higher vessel activity.

B-10Appendix B – Additional Characteristics of the P.L. 110-299 Population



## B-11 Figure B.6: Density Study Vessels (excluding Comme rcial Fishing Vessels) by State, by Water Area

0 2 4 6 8 10 12 14 16ILINMIMNOHWIALLAMSTXARAZCOIAIDKSKYMOMTNDNENMNVOKSDTNUTVTWVWYDCDEMDPAVACTMAMENHNJNYRIAKCAHIORWAFLGANCSCVessel Density(Number of vessels / square mile of inland water) Other non-Recreational Vessel Density (per water area)

Great Lakes Gulf Coast Inland Mid Atlantic N Atlantic Pacific S Atlantic

Sources: U. S. Coast Guard, MISLE database, 2009; based on subs et of operational, U.S. flagged other non-recreational vessels l ess than 79 feet in length (including vessels of unspecified length) fo r which MISLE provides a U.S. hailing port . State statistics on square miles of wat er obtained from U.S. Census, Statistical Abstract of the United States, 2008. The area in cludes inland, coastal, Great Lakes, and territorial waters.



## B.3 Other Vessel Characteristics: Construction and Propulsion

This section presents information on other variou s characteristics of study vessels that not only influence how vessels are used (e.g., for towing or icebreaking purposes vs. li ghter service), but may also affect the characteristics of discharges incide ntal to vessel operations. In particular, the section provides statistics on the ag e of the vessels (Section B.3.1 ), hull material (Section B.3.2 ), propulsion

me thod and fuel type (Section B.3.3 ), and, for self-propelled vesse ls, engine power rating (Section
B.3.4 ). As for other vessel statistics presented in this re port, the data are obtained from the USCG’s
MISLE database.Appendix B – Additional Characteristics of the P.L. 110-299 Population



### B.3.1 Vessel Age



## Figure B.7 and Figure B.8 present the distribution of study vesse ls by vessel construction date or

age. Figure B.7 summarizes the information across the entire selected population whereas details for
each vess el service cate gory are provided in Figure B.8

. As seen from both figures, nearly half of the vessels fall within the age range of 25 to 50 year s. The average age of vessels acros s all service categories is 33 years.

Vessel age is one of the factors that generally determines the t ype and performance of equipment
used onboard vessels and the char acteristics of discharges from the equipment. However, EPA recognizes that older vessels often have equipment whic h is rebuilt or replaced. For example, if an older vessel replaces its engine, the engi ne effluent will be influenced by the type and performance of the engine, not by the vessel’s age. Freight ships and tank ships tend to have been in service longer than passenger vessels and generally ha ve a greater level of rebuildi ng and replacement of original equipment.

Figure B.7: Distribution of Study Vessels by Age, in Years

Less than 5 years
9.9%

10-25 years
23.6%

25-50 years
48.6% 50-100 years
17.7% 100 or more years
0.3%

Note: This table is based on operational, U.S. flagged commerc ial fishing vessels and other non -recreational vessel less than 7 9 feet (including vessels of unspecified length).

Vessel age was either not reported or an invalid age (i.e. less than zero) was reported fo r approximately 43,000 vessels.

Source: U. S. Coast Guard, MISLE database, 2009



## B-12Appendix B – Additional Characteristics of the P.L. 110-299 Population

Figure B.8: Distribution of Study Vessels by Age and Vessel Service

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

100 or more years 256 146 2 7 36 50 15
50-100 years 17,231 10,921 173 305 2,669 81 19 2,246 817
25-50 years 47,208 26,715 3,514 144 7,954 31 102 25 4,111 4,612
10-25 years 22,892 11,049 290 35 4,525 10 84 1,148 5,751
Less than 5 years 9,603 3,125 321 19 2,502 13 50 5 920 2,648 All Vessels Commercial Fishing
Vessel Freight Barge Freight Ship Passenger
Vessel Public Vessel, Unclassified Tank Barge Tank Ship Utility Vessel Unspecified

Note: This table is based on operational, U.S. flagged commerc ial fishing vessels and other non -recreational vessel less than 7 9 feet (including vessels of unspecified length).

Vessel age was either not reported or an invalid age (i.e. less than zero) was reported fo r approximately 43,000 vessels.

Source: U. S. Coast Guard, MISLE database, 2009



### B.3.2 Hull Material Type



## Figure B.9 and Figure B.10 present the distribution of vessels by type of hull ma terial type. Figure B.9 provides a summary across all ve ssel servic e cate gories whereas Figure B.10 presents the information disaggreg ated by each category of vesse l service.

The three most common hull material types are fiberglass, wood, and steel in order of most common usage. Commercial fishing ve ssels with wood hulls account for ov er three quarters of the total number of wood hulled vessels, although wood is also us ed in the hulls of a signi ficant share of freight ships and passenger vessels less than 79 feet in length. The type of hull ma terial affects the type of antifoulant coatings that are applied a nd has implications on vessel discha rges and receiving water quality. For example, steel hulls often have an anti-corrosive as well as anti-foulant hull coatings. The type of

B-13Appendix B – Additional Characteristics of the P.L. 110-299 Population



## hull material m ay also affect the frequency with which certain maintenance procedures such as hull inspections are conducted.

Figure B.9: Number of Study Vessels by Hull Material Type

Aluminum

6.9%

Concrete
0.2%

Fiberglass
35.6%

Steel
24.2% Wood
29.1%

Plastic: MSIS Legacy
3.4% Glass
0.5%

Rubber
0.04% Plastic: Non-Reinforced
0.1%

Note: This table is based on operational, U.S. flagged commerc ial fishing vessels and other non -recreational vessel less than 7 9 feet (including vessels of unspecified length).

Hull material type was not reporte d for approximately 43,000 vessels.

Source: U. S. Coast Guard, MISLE database, 2009



## B-14Appendix B – Additional Characteristics of the P.L. 110-299 Population

Figure B.10: Distribution of Study Vessel s by Hull Material and Vessel Service

0% 20% 40% 60% 80% 100%

Wood 28,226 21,474 87 285 5,002 1 2 6 510 859

Steel 23,524 7,805 4,391 224 1,633 25 323 43 7,082 1,998

Rubber 34 1 10 2 21

Plastic: Non-Reinforced 98 58 2 2 36
Plastic: MSIS Legacy 3,318 1,875 22 9 684 1 10 717

Glass 463 310 1 33 16 103
Fiberglass 34,536 19,433 20 38 8,022 16 4 408 6,595

Concrete 213 137 2 2 36 1 35

Aluminum 6,704 2,211 15 36 2,698 15 4 8 778 939 All Vessels Commercial Fishing
Vessel Freight Barge Freight Ship Passenger
Vessel Public Vessel, Unclassified Tank Barge Tank Ship Utility Vessel Unspecified

Note: This table is based on operational, U.S. flagged commerc ial fishing vessels and other non -recreational vessel less than 7 9 feet (including vessels of unspecified length).

Approximately 43,000 vessels reported in MISLE do not have a hull material or have a ma terial other than the primary materials listed above.

Source: U. S. Coast Guard, MISLE database, 2009



### B.3.3 Propulsion Method and Type



## Figure B.11 presents the number and percentage of vessels by vessel service and propulsion
method . A vessel is characterized as self-propelle d if the vessel uses self-contained engines and other machinery to propel the vessel (wind-driven ve ssels are also included in this category). Non-self propelled vessels are generally propelled by a separate towing vessel e.g. a barge or mobile offshore drilling unit is prope lled by a tugboat.

Overall, within the selected subset of the st udy vessel population for which data are available in MISLE, 70 percent of vessels are se lf-propelled. The fraction of self -propelled vessels by service type varies from a low of 4 to 5 percent for freight barg es and tank barges, to approximately 80 percent for commercial fishing vessels, freight ships, passenger vessels, and utility vessels. Most self-propelled vessels recorded in MISLE are prop elled by either diesel motors (66.5 percent) or gasoline motors (26.9 percent).

B-15Appendix B – Additional Characteristics of the P.L. 110-299 Population



## Self-propelled vessels that use mechanical propu lsion methods have certain types of equipment such as an engine, propeller shaft, and propulsion fuel tanks, which w ould affect the characteristics of discharges under normal operations. Discharges from these vessels may be more likely to have higher concentrations of oil, grease, organic compounds, and metals due to their use of lubricants, fuels and machinery.

Figure B.11: Distribution of Study Vessels by Propulsion Method15,6867,6961583,892499875942,33610,98354,25861012348858,698 32017,06116,392

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

C

ommer c i a l F

i s h i n g Ves s el Freig ht

B

arg

e Freight Ship

Pa

s senger Vessel

Publ i c V

e s s el

, Uncl a ssified

Ta n k

Ba

rge Ta n k Ship

Uti li t y V

e s se

l Unspec i fi e d

Vessel ServicePercent of Vessels Self-Propelled Non Self-Propelled

Note: This table is based on operational, U.S. flagged commerc ial fishing vessels and other non -recreational vessel less than 7 9 feet (including vessels of unspecified length).

Source: U. S. Coast Guard, MISLE database, 2009



### B.3.4 Horsepower Ahead



## Figure B.12 and Figure B.13 display the distribution of st udy vessels by horsepower ahead. Horsepower ahead represents the rated power of a vessel’s engine in forward motion (as opposed to horsepower astern ) and is expressed as the workaccomplished per unit of time (e.g., 1 hp = 550 footpounds of work per second). This po wer is transferred to the propulsi on mode (e.g., jet or propeller) to create thrust and determines the vessel’s speed at a ny given weight, or the wei ght that can be moved at any given speed. Figure B.12 summarizes the information across all vesse ls within the selected population whereas Figure B.13 presents the inform ation by vessel service category. Vessel power

B-16Appendix B – Additional Characteristics of the P.L. 110-299 Population



## rating may determ ine the amount and characteristics of discharges from operat ing vessels by affecting the size, type, and complexity of onboard propulsion equipment.

As evidenced by the two figures, nearly 62 perc ent of all vessels have a horsepower ahead ranging between 100 and 500. The average value across a ll vessels is 411 horsepow er. The utility vessel and public vessel service categories have the highest proportion of vesse ls with a horsepower rating of 1,000 or greater. This is expected given the type of activities conducted by vessels in these service categories, e.g., towing and ice break ing. While not reflected in the fi gure, the MISLE data suggests a general relationship between vessel size and horsepower rating, within a given catego ry of vessels.

Figure B.12: Distribution of Study Vessels by Horsepower Ahead

Less than 100 horsepower
12.2%

100-500 horsepower
61.8% 500-1,000 horsepower
18.8% 1,000-5,000 horsepower
7.1% 5,000 or more horsepower
0.1%

Note: This table is based on operational, U.S. flagged commerc ial fishing vessels and other non -recreational vessel less than 7 9 feet (including vessels of unspecified length).

MISLE does not report horsepower ahead for appr oximately 114,000 non-recreational study vessels.

Source: U. S. Coast Guard, MISLE database, 2009



## B-17Appendix B – Additional Characteristics of the P.L. 110-299 Population

Figure B.13: Distribution of Study vessels by Horsepower Ahead and Vessel Service

0% 20% 40% 60% 80% 100%

5,000 or more horsepower 28 21 2 1 2 2
1,000-5,000 horsepower 1,831 443 1 5 642 1 1 711 27
500-1,000 horsepower 4,886 1,732 4 16 1,808 2 6 2 1,174 142
100-500 horsepower 16,041 8,748 13 54 4,473 4 1 19 1,159 1,570
Less than 100 horsepower 3,167 1,364 4 9 1,059 2 2 10 111 606 All Vessels Commercial Fishing
Vessel Freight Barge Freight Ship Passenger
Vessel Public Vessel, Unclassified Tank Barge Tank Ship Utility Vessel Unspecified

Note: This table is based on operational, U.S. flagged commerc ial fishing vessels and other non -recreational vessel less than 7 9 feet (including vessels of unspecified length).

Approximately 114,000 vessels reported in MISLE have no horsepower ahead value or a value of zero.

Source: U. S. Coast Guard, MISLE database, 2009



## B.4 Distribution of the Study Vessel Universe ve rsus the Recreational Vessel Univers e

While the analysis presented in this section ge nerally focuses on the subset of study vessels, a comparison of those vessels to the overall population is pertinent to understanding how discharges may differ between these vessels. At the same time, co mparison of estimates provided in different sources also helps verify the population estimate derived from MISLE data. As discusse d later in this section, the MISLE database appears to provide reasonabl y accurate data for larg er recreational vessels; however, the database does not appear to provide accu rate information for recr eational vessels less than
25 feet.

A comparison of the geographical distribution of the selected ve ssel population to that of the overall MISLE vessel universe (inc luding all operational, U.S. fla gged vessels) highlights some key

B-18Appendix B – Additional Characteristics of the P.L. 110-299 Population



## differences. As discussed below in this section, recreational vessels less th an 25 feet are not well represented in MLSE; h ence, the values presented in these tables do not accurately reflect vessel
numbers of these smaller vessels. As reflected in Figure B.14 below, several states that have hailing ports with a high percentage of the study vessel population account fo r a comparatively low percentage
of

the total universe of vessels. C onversely, States, such as California, with the largest number of vessels overall have comparatively fewer vessels in the population of commercial fishing vessels and nonrecreational vessels less than 79 f eet. The difference is generally at tributable to the geographical distribution of recreational vessels ( Figure B.15 ) as larger recreational vessel s tend to be concentrated in
certain states due to the states ’ longer coastlines, highe r population or income , and/or a longer boating season. For these states, one can expect consider ably greater numbers ofrecreational versus nonrecreational vessels. The relative shares of non-recreational and recreation vessel categories are
illustrated in Figure B.16 which summarizes the overall vessel universe by state and vessel service category, based on information provided in MISLE.

Figure B.14: Geographical Dist ribution of MISLE Vessel Univ erse by Hailing Port State

Source: U. S. Coast Guard, MISLE database, 2009; based on operational, U.S. flagged ve ssels for which MISLE provides a hailing port. Note that MLSE does not provide accurate estimates for smaller recreational vessels.



## B-19Appendix B – Additional Characteristics of the P.L. 110-299 Population



## B-20 Figure B.15: Geographical Dist ribution of Recreational V essels by Hailing Port State

Source: U. S. Coast Guard, MISLE database, 2009. Note that MLSE does not provide accurate estimates for smaller recreational ve ssels.Appendix B – Additional Characteristics of the P.L. 110-299 PopulationFigure B.16 Comparison of the Number of MLSE recorded (Larger) Recreational vessels to Study Vessels by State010,00020,00030,00040,00050,00060,00070,00080,00090,000 AK AL AR AZ CA CO CT DC DE FL GA HI IA ID IL IN KS KY LA MA MD ME MI MN MO MS MT NC ND NE NH NJ NM NV NY OH OK OR PA RI SC SD TN TX UT VA VT WA WI WV WYState

Number of VesselsRecreational VesselCommercial Fishing VesselOther Non-Recreational VesselNote: The hailing port state was either not listed or a foreign port was listed for approximately 285,000 and 6,000 vessels, respectively. All vessels are included withineach of the three vessel service categories,regardless of length.The data likely only includes larger recreational vessels capturedin MISLE and is therefore a gross underestimate of the totalpopulation of recreational vessels.Source: U. S. Coast Guard, MISLE database, 2009B-21Appendix B – Additional Characteristics of the P.L. 110-299 Population



## Study vessels represent a very small share of the total number of vessels operating on U.S. waters is evidenced by comparisons of the estimat ed number of study vessels (139,814 vessels) to the
national statistics on recreational vessels. While the number of recreational vessels reported in MISLE is large (700,000 vessels), the actual number of recreational vessel s found on U.S. waters is known to be significantly greater, or about 17 million. This is becau se industry estimates indicate a much larger
number of recreational vessels than are captured in MISLE, particular ly for smaller vessels less than
26 feet.

In its 2008 Recreational Boating Statistical Abstract , the National Marine Manufacturers Association (NMMA) estimates that there are approximately 16.9 millio n recreational vessels in the U.S., including 13 million registered and/or documen ted boats and more than 4 million non-registered boats. This is a significantly great er estimate than the number of vessels documented in MISLE, which
records the characteristics of 722,522 recreational vessels. The diffe rence is accounted for by stateregistered vessels that are not s ubject to documentation requirements 8 

## , hence, they are captured by NMMA but not by MLSE. Figure B.17 illustrates the distribution of vessels by service and length, this
tim e including additional recreational vessels captured in industry estimates (NMMA, 2009). Figure
B.18 compares recreational vessels reported by MLSE and NMMA across the various census regions are
covered in MISLE. As shown in these figures, there are a significantly greater number of sm all recreational vessels (less than 26 feet in length) than suggested by MISLE data alone. While MISLE grossly underestimates the number of recreational vessels below 26 f eet, it appears to provide more reliable estimates for larger recreational vessel (MISLE over-represents th e number of recreational
vessels in the 40 to 65 feet le ngth category, while it accounts fo r 55 percent and 73 percent of recreational vessels recorded by N MMA in the 26 to 40 feet and gr eater than 65 feet categories, respectively). Across all size cate gories with the excep tion of vessels greater than 65 feet, nonrecreational vessels account for a relatively small fr action of the total universe of domestic vessels operating in U.S. waters.

8 

### Additional state boating regulations require that non-documente d vessels, including smaller recreational vessels less than five tons, register with state authorities. While vessel regist ration requirements under State boating regulations vary, many states require that vessels of any size e quipped with primary or secondary propulsion be registered; in some cases, nonmotored vessels above 15 feet in length must also be registered. See additional discussion under Section B.5.



## B-22Appendix B – Additional Characteristics of the P.L. 110-299 Population



## B-23 Figure B.17: Distribution of Vessels by Service Category and Length (in feet), Accounting for MISLE AND NMMA
Estimates of Recreational Vessels

47,045 34,598 65,146

306,214 95,754 8,206

5,063,722 5,999,044 249,494 3,038

1,052 12,509 34,915 234,082

-27,842

-20%

0% 20% 40% 60% 80% 100%

< 16 16 - 26 26 - 40 40-65 > 65

Vessel Length (in feet)Number of Vessels NMMA Additional Recreational Vessels

MISLE Recreational Vessels

MISLE Non-recreational Vessels

Source: U. S. Coast Guard, MISLE database, 2009 and NMMA 2007 Recreational Boating Statistical Abstract.

An additional 43,351 vessels are included in MISLE but do not ha ve length information. These vessels are therefore excluded fro m the figure.Appendix B – Additional Characteristics of the P.L. 110-299 PopulationFigure B.18: Recreational Vessels as Reported in MISLE and as Estimated by NMMA0500,0001,000,0001,500,0002,000,0002,500,000 New England Middle Atlantic East North Central West North Central South Atlantic East South Central West South Central Mountain Pacific New England Middle Atlantic East North Central West North Central South Atlantic East South Central West South Central Mountain Pacific New England Middle Atlantic East North Central West North Central South Atlantic East South Central West South Central Mountain PacificCensus Division

Number of VesselsMISLENMMALess than 26 ft26 - 65 ft65 ft or greater05001,0001,5002,0002,5003,0003,500NewEnglandMiddleAtlanticEastNorthCentralWestNorthCentralSouthAtlanticEastSouthCentralWestSouthCentralMountain PacificYellow bars represent NMMA data while blue bars represent MISLE dataSource: U. S. Coast Guard, MISLE database, 2009 andNMMA 2007 Recreational Boating Statistical AbstractB-24Appendix B – Additional Characteristics of the P.L. 110-299 Population



## B.5 Vessels Documented, Inspected, and/or State Registered

The MISLE database classifies vessels as docum ented, inspected, and/or state registered. These classifications are used to identify the types of requirements to which a given vessel is subject. According to a Coast Guard representative, genera lly only vessels that ar e not documented at the national level are state registered. 9 

## On the other hand, based on the MISL E dataset, nearly all (4,982) of the 5,259 inspected vessels are also either documented or state registered.

In order to be classified as a documented vessel, the vessel “must meas ure at least five tons and, with the exception of certain oil spill response vessels, must be who lly owned by a citizen of the U.S.” 10


## According to a Coast Guard representative, “ documentation provides conclusive evidence of nationality for international purposes, provides for unhindered commerce between the states, and admits vessels to certain restricted trades, such as coastwise trade and the fisheries.”

A vessel is listed as inspected in MISLE when the vessel is s ubject to inspection requirements under one of several U.S. Coast Guard regulations. A ccording to a Coast Guard representative, certain U.S. vessels (e.g. passenger vessels that meet thres hold size and passenger require ments) are required to undergo safety and security inspec tions, which includes inspections on a vessel’s machinery, hull, safety equipment, and proper documents, before they can operate commercially in U.S. waters. 11



## A vessel is listed as state registered when the vessel is registered by a state authority. Only
vessels that are not documented at the national level are state register ed. Although each state sets its own registration requirements and therefor e these requirements can vary from state to state, generally, any undocumented vessel that is self-propelled (meaning that machinery is used to propel the vessel) must be registered with the state.

Table B.5 , below, presents the number of study vessels – by vessel service – classified as
docum ented, inspected or state registered in MISLE. As seen within Table B.5 , overall, approximately 36 percent of vessels reporting in MISLE are doc umented, 4 percent of ve ssels are in spected, and 26 percent of vessels are state registered, although the fractions of vessels in each class varies across the vessel service categories.

9 

### Approximately 1,200 vessels are listed as both documented and state-registered.

10 

### Source: Personal email communication with Harold Krevait of the U.S. Coast Guard. April 22, 2009. Note, however that fishing vessels with only a “registry” endorsement on their certification of documentation do not have to be wholly owned by U.S. citizens but may be under majority control by U.S. in terest (Personal communication with Division Chief, Fishing Vessel Safety Division (CG-5433), Fishing Vessel Safety Program, May 26, 2009).

11 

### Source: Personal email communication with Harold Krevait of the U.S. Coast Guard. April 22, 2009.



## B-25Appendix B – Additional Characteristics of the P.L. 110-299 Population



## Table B.5: Number of Study Vessels Documented , Inspected, and State Registered, by Vessel
Service

Total (1) 

### Documented (2) 

### Inspected (2) 

### State Registered

Vessel Service Number Number Percent of Total Number Percent of Total Number Percent of Total Commercial Fishing Vessel 69,944 (3) 

### 27,770 (3) 

### 39.7% 3 0.0% 22,438 (1) 

### 32.1% Freight Barge 8,016 811 10.1% 1 0.0% 48 0.6% Freight Ship 768 211 27.5% 14 1.8% 40 5.2% Passenger Vessel 20,953 10,613 (4) 

### 50.7% 4,968 23.7% 4,044 19.3% Public Vessel, Unclassified 622 22 3.5% 3 0.5% 21 3.4% Tank Barge 923 116 12.6% 49 5.3% 10 1.1% Tank Ship 179 24 13.4% 15 8.4% 8 4.5% Utility Vessel 11,034 6,008 54.4% 199 1.8% 1,020 9.2% Unspecified 27,375 4,183 15.3% 7 0.0% 9,030 33.0% All Vessels 139,814 49,758 35.6% 5,259 3.8% 36,659 26.2% Note: This table is based on operational, U.S. flagged commerc ial fishing vessels and other non -recreational vessel less than 7 9 feet. Source: U. S. Coast Guar d, MISLE database, 2009 (1) Total number of other non-recreational vessels (other than comme rcial fishing vessels) includes all vessels less than 79 feet i n length and vessels of unspecifi ed length (zero or null). (2) “Documented” and “Inspected” are not mutually ex clusive categories. The num ber of documented vessel includes inspected vessels. (3) The U.S. Coast Guard’s Fishing Vessel Sa fety Program generally uses a figure of 80,000 as the approximate number of commercial fishing vessels, includ ing about 20,000 documented vessels and 60,000 state-registered vessels. In 2007, the states reported a total of over 58,000 vessels that fish commercially and are registered in their jurisdictions. 12 (4) 3,904 passenger vessels are both documented and inspected.



## As described in Chapter 1, MISLE also incl udes additional vessels not subject to the documentation, inspection, or state registration require ments; information for these vessels was obtained through other Coast Guard activities such as non-mandatory inspections or inci dent investigations.

B.6 Uncertainty

The analysis presented in this section draws largely on national-level data collected by the U.S.
Coast Guard. Several factors contribute to uncer tainty in the estimates and findings presented:

 Scope . Some vessels may not be captured in the database due to the procedures by which vessels are identified and entered into the database . Data coverage is belie ved to be relatively good for vessels subject to documentation or inspection requirements (e.g., vessels engaged in coastwise trade or passenger vessels), but more incomplete for smaller vessels. The absence of information on the smaller, undocum ented, uninspected vessels which were not manufactured or used for pleasure may lead EPA to under-estimate the size of the study vessels population. Conversely, categ ories used to classify vesse ls in MISLE may be broader than vessels that would otherwise be consid ered “in scope” for this study; for example, passenger vessels may include vessels that woul d meet the Clean Boating Act definition of recreational vessel, depending on their use.

12 

### Source: Personal communication with Division Chief, Fishing Vessel Safety Division (CG-5433), Fishing Vessel Safety Program, May 26, 2009.



## B-26Appendix B – Additional Characteristics of the P.L. 110-299 Population



##  Completeness . Analyses of vessel characteristics were lim ited by the information provided for a vessel or the manner in which the information is entered. For example, the hailing port or horsepower ahead is provided for a only subset of vessels in the database. To the extent that the absence of the info rmation is unevenly distribu ted among the vessel population, distributions drawn from the data may provide a biased understanding of the characteristics of the vessel population.

 Accuracy . Even when vessel data are populated, there may be issues with the accuracy of the information. For example, the status of vessels no longer operational (i.e., out of service) may not have been properly updated or vessel ty pes may be misclassified. These errors are difficult to detect and may lead to ina ccurate estimates of the actual population.

Uncertainty related to the scope of the data used in the analysis is discussed in greater detail below. Where possible, EPA compar ed findings drawn from the MISLE data to information from other sources, such as NMMA and NOAA, to ascertain and quantify the magnitude of the error on the population estimate. This review suggests that MI SLE under-represents the population of recreational vessels smaller than about 25 feet in length and may similarly under-represent small non-recreational vessels. For larger recreati onal vessels, however, the number of vessels reported in MISLE is close, or for some size classes even greater than, the num ber estimated by NMMA. Based on this comparison, it is apparent that MISLE is significantly limited in terms of its ch aracterization of the universe of small
recreational vessels 13 

## . Since the analysis focuses more specifi cally on non-recreational vessels, however,
EPA does not consider these limitations to be critic al. In general, EPA believes that national vessel databases such as MISLE provide adequate coverage for the subset of study ve ssels, since a significant fraction of these vessels can be expe cted to be larger than about 25 f eet in length, and useful data on the physical and operational characteris tics of the study vessel population.

While MISLE constitutes the most comprehensive and readily available na tional-level data sets on vessels, it is important to note that the MISLE data base covers a subset of vessels that are either required to be documented under federal regulations (e .g., at least five net tons ) or vessels known to the U.S. Coast Guard through vessel inspections or incide nt investigations. Genera lly, the five ton tonnage threshold means that only those vessels more th an about 25 feet in length are covered.

Unlike recreational vessels, there is no alternate national-level da ta source that would provide recent and comprehensive figures for the number of co mmercial fishing vessel by size category to allow EPA to assess MISLE coverage for these vessels . The MISLE database reports a total of 69,944 commercial fishing vessels nationall y. This number does not include all state-registered vessels that commercially fish, but is generally comparable with industry totals reported in other sources. For example, Hoovers reports that 25,000 commercial fish ing vessels have combined annual revenue of $4 billion. An additional 55,000 small, undecked vessels are also used to catch wild fish for economic gain, though the report notes that industry im pact of these undecked vessels is “negligible.” The total number of commercial fishing vesse ls reported in Hoovers w ould therefore be around 80,000. 14 

## Additionally, the U.S. Coast Guard’s Fishing Vessel Safety Pr ogram generally uses a figure of 80,000 as the

13 

### EPA notes that MISLE is not designed or managed to provide accurate estimates of the small recreational vessel universe.

14 

### (Source: http://www.hoovers.com/commercial-fishing , accessed 05/01/2009).



## B-27Appendix B – Additional Characteristics of the P.L. 110-299 Population



## B-28 approximate number of commerci al fishing vessels, including about 20,000 documented vessels and 60,000 state-registered vessels. 15



## No separate inventory of othe r non-recreational vessels less th an 79 feet could be found to evaluate the coverage of these vess els in MISLE. It is therefore not possible to ascertain the extent to which MISLE under represent smaller utility vessels and other non-recreational vessels.

EPA also compared the number of commercial fishing vessels identified in MISLE with the number of vessels holding fishing permit licenses in New England, as obtain ed from NOAA’s regional office, and with separate state-registered vess el estimates provided by the U.S. Coast Guard. Table B.6 presents the count of permitted fishing vessels within NOAA’ s New England division permitted vessel
list and the count of commercial fi shing vessels within MISLE that listed a New England hailing state. The table also provides estimates of the number of stat e-registered vessels used in commercial fisheries. As seen in the table, the MISLE dataset contains nearly double the number of commercial fishing vessels as permitted in NOAA’s New England division. This difference may be due to the slightly different scopes of the NOAA and MISLE dataset. NOAA’s dataset only incl udes permit holders of NOAA Fisheries Northeast Region 16 

## 2008 Vessel permits, whereas the MISLE dataset includes vessels that may not have fishery permits for that year (such as fishing support vessels) in addition to those that would hold permits. Additionally, as mentioned in the introduction to this section, it is possible that some of the commercial fishing vessels that Coast Gu ard considers to be operat ional were not actively engaged in fishing activities duri ng 2008. With regards to numbers pr ovided in MISLE as compared to state-registered vessel estimates, th e MISLE data seem to slightly unde r-represent the vessels registered in New England states. Overall, however, comparis on of commercial fishing vessel estimates across sources suggests that MISLE may adequately repr esent the population of th ese vessels despite the vessels’ relatively small size and potentially higher probability of being excluded from the database

scope.

15 

### Personal communication with Division Chief, Fishing Vessel Safety Division (CG-5433), Fishing Vessel Safety Program, May 26, 2009.

16 

### Our table specifically compares the New England division data.Appendix B – Additional Characteristics of the P.L. 110-299 Population



## Table B.6: Comparison Among NOAA, State-registered and MISLE New England Region Commercial Fishing Vessel Populations

Number of Vessels State NOAA a 

### State-registered b 

### MISLE
CT 77 256 284
MA 1,514 2,006 2,492
ME 1,535 6,508 3,725
NH 196 0 231
RI 335 630 438
VT 0 0 3 New England Total 3,657 9,400 7,173 a Although NOAA’s Northeast Region Vessel and Permit Listing documents 5,227 vessels, only 3,657 of these vessels list a principal ha iling state in the New England region. b. Some of the state registered fishing vessels reported by states for 2007 are also included in the reported MISLE numbers. 17 Source: National Oceanic and Atmospheric Admi nistration (NOAA) New England Commercial Fishing Permit Listing, 2009, U. S. Coas t Guard, MISLE database, 2009, and Personal Communication with U.S. Coast Guard personnel, May 2009.

17 

### Personal communication with Division Chief, Fishing Vessel Safety Division (CG-5433), Fishing Vessel Safety Program, May 26, 2009.



## B-29Appendix C – Public Law 110-299 (S. 3298) and Public Law 110-288 (S. 2766)



# Appendix C Public Law 110-299 (S. 3298) a nd Public Law 110-288 (S. 2766)

Public Law 110-299 (S. 3298)



# One Hundred Tenth Congress of the United States of America

AT THE SECOND SESSION

Begun and held at the City of Washington on Thursday, the third day of January, two thousand and eight



# An Act

To clarify the circumstances during whic h the Administrator of the Environmental Protection Agency and applicable States may require permits for discharges from ce rtain vessels, and to require the Administ rator to conduct a study of discharges incidental to the normal operation of vessels.



### Be it enacted by the Senate and House of Representa tives of the United States of America in Congress assembled,

SECTION 1. DEFINITIONS.



### In this Act: (1) A DMINISTRATOR 

### .—The term ‘‘Administrator’’ means the Administrator of the Environmental Protection Agency. (2) C OVERED VESSEL 

### .—The term ‘‘covered vessel’’ means a vessel that is— (A) less than 79 feet in length; or (B) a fishing vessel (as defined in section 2101 of title 46, United States Code), regardless of the length of the vessel. (3) O THER TERMS 

### .—The terms ‘‘contiguous zone’’, ‘‘discharge’’, ‘‘ocean’’, and ‘‘State’’ have the meanings given the terms in section 502 of the Federal Water Pollution Control Act (33 U.S.C. 1362).

SEC. 2. DISCHARGES INCIDENTAL TO NORMAL OPERATION OF VESSELS. 

### (a) N O 

### P ERMIT 

### R EQUIREMENT 

### .—Except as provided in subsection (b), during the 2-year period beginning on the date of enactment of this Act, the Administrator, or a State in the case of a permit program approved under section 402 of the Federal Water Pollution Control Act (33 U.S.C. 1342), shall not require a permit under that section for a cove red vessel for— (1) any discharge of effluent from properly functioning marine engines; (2) any discharge of laundry, shower, and galley sink wastes; or (3) any other discharge incidental to the normal operation of a covered vessel. (b) E XCEPTIONS 

### .—Subsection (a) shall not apply with respect to— (1) rubbish, trash, garbage, or other su ch materials discha rged overboard; (2) other discharges when the vessel is operating in a capacity other than as a means of transportation, such as when— (A) used as an energy or mining facility;



## C-1Appendix C – Public Law 110-299 (S. 3298) and Public Law 110-288 (S. 2766)



## C-2 (B) used as a storage facility or a seafood processing facility; (C) secured to a storage facility or a seafood processing facility; or (D) secured to the bed of the ocean, the contiguous zone, or waters of the United States for the purpose of mineral or oil exploration or development; (3) any discharge of ballast water; or (4) any discharge in a case in which the Administrator or State, as appropriate, determines that the discharge— (A) contributes to a violation of a water quality standard; or (B) poses an unacceptable risk to human health or the environment.

SEC. 3. STUDY OF DISCHARGES INCIDENTAL TO NORMAL OPERATION OF VESSELS. 

### (a) I N 

### G ENERAL 

### .—The Administrator, in consultation with the Secretary of the department in which the Coast Guard is operating and the heads of other interested Federal agencies, shall conduct a study to evaluate the impacts of— (1) any discharge of effluent from properly functioning marine engines; (2) any discharge of laundry, shower, and galley sink wastes; and (3) any other discharge incidental to the normal operation of a vessel. (b) S COPE OF 

### S TUDY 

### .—The study under subsection (a) shall include— (1) characterizations of the nature, type , and composition of discharges for— (A) representative si ngle vessels; and (B) each class of vessels; (2) determinations of the volumes of those discharges, including average volumes, for— (A) representative si ngle vessels; and (B) each class of vessels; (3) a description of the locations, including the more common locations, of the discharges; (4) analyses and findings as to the nature and ex tent of the potential effects of the discharges, including determinations of whether the discharges pose a risk to human health, welfare, or the environment, and the nature of those risks; (5) determinations of the benefits to human heal th, welfare, and the environment from reducing, eliminating, controlling, or mitigating the discharges; and (6) analyses of the extent to which the discharges are currently subject to regulation under Federal law or a binding international obligation of the United States. (c) E XCLUSION 

### .—In carrying out the study under subsection (a), the Administrator shall exclude— (1) discharges from a vessel of the Armed Forces (as defined in section 312(a) of the Federal Water Pollution Control Act (33 U.S.C. 1322(a)); (2) discharges of sewage (as defined in section 312(a) of the Federal Water Pollution Control Act (33 U.S.C. 1322(a)) from a vessel, other than the discharge of graywater from a vessel operating on the Great Lakes; and (3) discharges of ballast water. (d) P UBLIC 

### C OMMENT 

### ; R EPORT 

### .—The Administrator shall— (1) publish in the Federal Register for public comment a draft of the study required under subsection (a); (2) after taking into account any comments receiv ed during the public comment period, develop a final report with respect to the study; and (3) not later than 15 months after the date of enactment of this Act, submit the final report to— (A) the Committee on Transportation and Infrastructure of the House of Representatives; and (B) the Committees on Environment and Public Works and Commerce, Science, and Transportation of the Senate.

Speaker of the House of Representatives. Vice President of the United Stat es and President of the Senate.Appendix C – Public Law 110-299 (S. 3298) and Public Law 110-288 (S. 2766)



## Public Law 110-288 (S. 2766)



# One Hundred Tenth Congress of the United States of America

AT THE SECOND SESSION

Begun and held at the City of Washington on Thursday, the third day of January, two thousand and eight



# An Act

To amend the Federal Water Pollution Control Act to address certain discharges incidental to the normal operation of a recreational vessel.



### Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. SHORT TITLE. 

### This Act may be cited as the ‘‘Clean Boating Act of 2008’’.

SEC. 2. DISCHARGES INCIDENTAL TO THE NORMAL OPERATION OF RECREATIONAL VESSELS. 

### Section 402 of the Federal Water Pollution Control Act (33 U.S.C. 1342) is amended by adding at the end the following: ‘‘(r) D ISCHARGES 

### I NCIDENTAL TO THE 

### N ORMAL 

### O PERATION OF 

### R ECREATIONAL 

### V ESSELS 

### .—No permit shall be required under this Act by the Administrator (or a State, in the case of a permit program approved under subsection (b)) for the discharge of any graywater, bilge water, cooling water, weather deck runoff, oil water separator effluent, or effluent from properly functioning marine engines, or any other discharge that is incidental to the normal operation of a vessel, if the discharge is from a recreational vessel.’’.

SEC. 3. DEFINITION. 

### Section 502 of the Federal Water Pollution Control Act (33 U.S.C. 1362) is amended by adding at the end the following: ‘‘(25) R ECREATIONAL VESSEL 

### .— ‘‘(A) I N

GENERAL 

### .—The term ‘recreational vessel’ means any vessel that is— ‘‘(i) manufactured or used primarily for pleasure; or ‘‘(ii) leased, rented, or chartered to a person for the pleasure of that person. ‘‘(B) E XCLUSION 

### .—The term ‘recreational vessel’ does not include a vesse l that is subject to Coast Guard inspection and that— ‘‘(i) is engaged in commercial use; or ‘‘(ii) carries paying passengers.’’.

SEC. 4. MANAGEMENT PRACTICES FOR RECREATIONAL VESSELS. 

### Section 312 of the Federal Water Pollution Control Act (33 U.S.C. 1322) is amended by adding at the end the following: ‘‘(o) M ANAGEMENT 

### P RACTICES FOR 

### R ECREATIONAL 

### V ESSELS 

### .— ‘‘(1) A PPLICABILITY 

### .—This subsection applies to any discharge, other than a discharge of sewage, from a recreational vessel that is— ‘‘(A) incidental to the normal operation of the vessel; and ‘‘(B) exempt from permitting requirements under section 402(r). ‘‘(2) D ETERMINATION OF DISCHARGES

SUBJECT TO MANAGEMENT PRACTICES 

### .— ‘‘(A) D ETERMINATION 

### .— ‘‘(i) I N GENERAL 

### .—The Administrator, in



## C-3Appendix C – Public Law 110-299 (S. 3298) and Public Law 110-288 (S. 2766)



### consultation with the Secretary of the departme nt in which the Coast Guard is operating, the Secretary of Commerce, and intere sted States, shall determine the discharges incidental to the normal operation of a recreational vessel for wh ich it is reasonable and practicable to develop management practices to mitigate adverse impacts on the waters of the United States. ‘‘(ii) P ROMULGATION 

### .—The Administrator shall promulgate the determinations under clause (i) in accordance with section 553 of titl e 5, United States Code. ‘‘(iii) M ANAGEMENT PRACTICES 

### .—The Administrator shall develop management practices for recreational vessels in any case in which the Administrator determines that the use of those practices is reasonable and practicable. ‘‘(B) C ONSIDERATIONS 

### .—In making a determination under subp aragraph (A), the Administrator shall consider— ‘‘(i) the nature of the discharge; ‘‘(ii) the environmental effects of the discharge; ‘‘(iii) the practicability of using a management practice; ‘‘(iv) the effect that the use of a management practice would have on the operation, operational capability, or safety of the vessel; ‘‘(v) applicable Federal and State law; ‘‘(vi) applicable international standards; and ‘‘(vii) the economic costs of the use of the management practice. ‘‘(C) T IMING 

### .—The Administrator shall— ‘‘(i) make the initial determinations under subparagraph (A) not later than 1 year after the date of enactment of this subsection; and ‘‘(ii) every 5 years thereafter— ‘‘(I) review the determinations; and ‘‘(II) if necessary, revise the determinations based on any new informatio n available to the Administrator. ‘‘(3) P ERFORMANCE

STANDARDS FOR MANAGEMENT PRACTICES 

### .— ‘‘(A) I N GENERAL 

### .—For each discharge for which a management practice is developed under paragraph (2), the Administrator, in consultation with the Secretary of the department in which the Coast Guard is operating, the Secretary of Commerce, other interested Federal agencies, and interested States, shall promulgate, in accordance with section 553 of title 5, United States Code, Federal standards of performance for each management practice required with respect to the discharge. ‘‘(B) C ONSIDERATIONS 

### .—In promulgating standards under this paragraph, the Administrator shall take into account the considerations described in paragraph (2)(B). ‘‘(C) C LASSES 

### , TYPES 

### , AND SIZES OF VESSELS 

### .—The standards promulgated under this paragraph may— ‘‘(i) distinguish among cla sses, types, and size s of vessels; ‘‘(ii) distinguish between new and existing vessels; and ‘‘(iii) provide for a waiver of the applicability of the standards as necessa ry or appropriate to a particular class, type, age, or size of vessel. ‘‘(D) T IMING 

### .—The Administrator shall— ‘‘(i) promulgate standards of performance for a management practice under subparagraph (A) not later than 1 year after the date of a determination under paragraph (2) that the management practice is reasonable and practicable; and ‘‘(ii) every 5 years thereafter— ‘‘(I) review the standa rds; and ‘‘(II) if necessary, revise the standards, in accordance with subparagraph (B) and based on any new information available to the Administrator. ‘‘(4) R EGULATIONS FOR THE USE OF MANAGEMENT PRACTICES 

### .— ‘‘(A) I N GENERAL 

### .—The Secretary of the department in which the Coast Guard is operating shall promulgate such regulations governing the design, construction, installation, and use of management practices for recrea tional vessels as are necessary to meet the standards of performance promulgated under paragraph (3). ‘‘(B) R EGULATIONS 

### .— ‘‘(i) I N GENERAL 

### .—The Secretary shall promulgate the regulations under this paragraph as soon as practicable after the Administrator promulgates standards with respect to the practice under paragraph (3), but not later than 1 year after the date on which the Administrator promulga tes the standards. ‘‘(ii) E FFECTIVE DATE 

### .—The regulations promulgated by the Secretary under this paragraph shall be effective upon promulgation unless another effective date is specified in the regulations. ‘‘(iii) C ONSIDERATION OF TIME 

### .—In determining the effective date of a regulation promulgated under this paragraph, the Secretary shall consider the period of time necessary to communicate the existence of the regulation to persons affected by the regulation.



## C-4Appendix C – Public Law 110-299 (S. 3298) and Public Law 110-288 (S. 2766)



## C-5 ‘‘(5) E FFECT OF OTHER LAWS 

### .—This subsection shall not affect the application of section 311 to discharges incidental to the normal operation of a recreational vessel. ‘‘(6) P ROHIBITION RELATING TO RECREATIONAL VESSELS 

### .— After the effective date of the regulations promulgated by the Secretary of the department in which the Coast Guard is operating under paragraph (4), the owner or operator of a recreational vessel shall neither operate in nor discharge any discharge incidental to the normal operation of the vessel into, the waters of the United States or the waters of the contiguous zone, if the owner or operator of the vessel is not using any applicable management practice meeting standards established under this subsection.’’.

Speaker of the House of Representatives. Vice President of the United Stat es and President of the Senate.Appendix D – List of Target Analytes



# Appendix D
L ist of Target Analytes

Analytical Class Analyte Name Analytical Method CAS Number Pathogens E. Coli by MF EPA 1603 NA Pathogens E. Coli by MPN IDEXX Colilert 18 Quanti-Tray or Multiple Tube Fermentation NA Pathogens Enterococci by MF EPA 1600 NA Pathogens Enterococci by MPN IDEXX Enterolert Quanti-Tray or ASTM D6503-99 NA Pathogens Fecal Coliform by MF MF-SM9222D NA Pathogens Fecal Coliform by MPN Multiple Tube Fermentation NA
Classicals Biochemical Oxy gen Demand (BOD) SM 5210 B 20th NA

Classicals Chemical Oxygen Demand (COD) Chemical Oxygen Demand by HACH NA
Classicals Conductivity A2510B NA
Classicals Dissolved Organic Carbon (DOC) SM5310 B NA
Classicals Dissolved Oxygen SM 4500-O G NA
Classicals Hexane Extractabl e Material (HEM) USEPA-1664A NA
Classicals pH SM 4500-H B NA
Classicals Salinity SM 2520 A NA
Classicals Silica Gel Treated HEM (SGT-HEM) USEPA-1664A 68334-30-5
Classicals Sulfide SM4500S2D 18496-25-8
Classicals Temperature SM 2550 NA
Classicals Total Organic Carbon (TOC) SM5310 B NA
Classicals Total Residual Chlorine SM 4500-Cl G NA
Classicals Total Suspended Solids (TSS) SM 2540 D 20th NA
Classicals Turbidity EPA 180.1 NA

Metals Aluminum, Dissolved EPA200.7 7429-90-5

Metals Aluminum, Dissolved EPA200.8 7429-90-5

Metals Aluminum, Total EPA200.7 7429-90-5

Metals Aluminum, Total EPA200.8 7429-90-5

Metals Antimony, Dissolved EPA200.8 7440-36-0

Metals Antimony, Total EPA200.8 7440-36-0

Metals Arsenic, Dissolved EPA200.7 7440-38-2

Metals Arsenic, Dissolved EPA200.8 7440-38-2

Metals Arsenic, Total EPA200.7 7440-38-2

Metals Arsenic, Total EPA200.8 7440-38-2

Metals Barium, Dissolved EPA200.8 7440-39-3

Metals Barium, Total EPA200.7 7440-39-3

Metals Barium, Total EPA200.8 7440-39-3

Metals Beryllium, Dissolved EPA200.8 7440-41-7

Metals Beryllium, Total EPA200.8 7440-41-7

Metals Cadmium, Dissolved EPA200.7 7440-43-9

Metals Cadmium, Dissolved EPA200.8 7440-43-9

Metals Cadmium, Total EPA200.7 7440-43-9

Metals Cadmium, Total EPA200.8 7440-43-9

Metals Calcium, Dissolved EPA200.7 7440-70-2

Metals Calcium, Total EPA200.7 7440-70-2

Metals Chromium, Dissolved EPA200.7 7440-47-3

Metals Chromium, Dissolved EPA200.8 7440-47-3

Metals Chromium, Total EPA200.7 7440-47-3

Metals Chromium, Total EPA200.8 7440-47-3



## D-1Appendix D – List of Target Analytes

Analytical Class Analyte Name Analytical Method CAS Number

Metals Cobalt, Dissolved EPA200.8 7440-48-4

Metals Cobalt, Total EPA200.8 7440-48-4

Metals Copper, Dissolved EPA200.7 7440-50-8

Metals Copper, Dissolved EPA200.8 7440-50-8

Metals Copper, Total EPA200.7 7440-50-8

Metals Copper, Total EPA200.8 7440-50-8

Metals Iron, Dissolved EPA200.7 7439-89-6

Metals Iron, Total EPA200.7 7439-89-6

Metals Lead, Dissolved EPA200.7 7439-92-1

Metals Lead, Dissolved EPA200.8 7439-92-1

Metals Lead, Total EPA200.7 7439-92-1

Metals Lead, Total EPA200.8 7439-92-1

Metals Magnesium, Dissolved EPA200.7 7439-95-4

Metals Magnesium, Total EPA200.7 7439-95-4

Metals Manganese, Dissolved EPA200.7 7439-96-5

Metals Manganese, Dissolved EPA200.8 7439-96-5

Metals Manganese, Total EPA200.7 7439-96-5

Metals Manganese, Total EPA200.8 7439-96-5

Metals Nickel, Dissolved EPA200.7 7440-02-0

Metals Nickel, Dissolved EPA200.8 7440-02-0

Metals Nickel, Total EPA200.7 7440-02-0

Metals Nickel, Total EPA200.8 7440-02-0

Metals Potassium, Dissolved EPA200.7 2023695

Metals Potassium, Total EPA200.7 2023695

Metals Selenium, Dissolved EPA200.7 7782-49-2

Metals Selenium, Dissolved EPA200.8 7782-49-2

Metals Selenium, Total EPA200.7 7782-49-2

Metals Selenium, Total EPA200.8 7782-49-2

Metals Silver, Dissolved EPA200.8 7440-22-4

Metals Silver, Total EPA200.8 7440-22-4

Metals Sodium, Dissolved EPA200.7 7440-23-5

Metals Sodium,Total EPA200.7 7440-23-5

Metals Thallium, Dissolved EPA200.8 7440-28-0

Metals Thallium, Total EPA200.8 7440-28-0

Metals Vanadium, Dissolved EPA200.8 7440-62-2

Metals Vanadium,Total EPA200.8 7440-62-2

Metals Zinc, Dissolved EPA200.7 7440-66-6

Metals Zinc, Dissolved EPA200.8 7440-66-6

Metals Zinc, Total EPA200.7 7440-66-6

Metals Zinc, Total EPA200.8 7440-66-6 Nonylphenols Bisphenol A MS004 NA
Nonylphenols Nonylphenol dec aethoxylate (NP10EO) MS006 NA
Nonylphenols Nonylphenol diethoxylate (NP2EO) MS004 NA
Nonylphenols Nonylphenol dod ecaethoxylate (NP12EO) MS006 NA

Nonylphenols Nonylphenol heptadecaethoxylate (NP17EO) MS006 NA

Nonylphenols Nonylphenol heptaethoxylate (NP7EO) MS006 NA
Nonylphenols Nonylphenol hex adecaethoxylate (NP16EO) MS006 NA
Nonylphenols Nonylphenol hexaethoxylate (NP6EO) MS006 NA
Nonylphenols Nonylphenol monoethoxylate MS004 NA
Nonylphenols Nonylphenol nonaethoxylate (NP9EO) MS006 NA
Nonylphenols Nonylphenol oc taethoxylate (NP8EO) MS006 NA
Nonylphenols Nonylphenol oct odecaethoxylate (NP18EO) MS006 NA



## D-2Appendix D – List of Target Analytes

Analytical Class Analyte Name Analytical Method CAS Number Nonylphenols Nonylphenol pen decaethoxylate (NP15EO) MS006 NA
Nonylphenols Nonylphenol pentaethoxylate (NP5EO) MS006 NA
Nonylphenols Nonylphenol tetr adecaethoxylate (NP14EO) MS006 NA
Nonylphenols Nonylphenol tetraethoxylate (NP4EO) MS006 NA
Nonylphenols Nonylphenol trid ecaethoxylate (NP13EO) MS006 NA
Nonylphenols Nonylphenol triethoxylate (NP3EO) MS006 NA
Nonylphenols Nonylphenol und ecaethoxylate (NP11EO) MS006 NA
Nonylphenols Octylphenol MS004 NA
Nonylphenols Octylphenol dec aethoxylate (OP10EO) MS006 NA
Nonylphenols Octylphenol di ethoxylate (OP2EO) MS006 NA
Nonylphenols Octylphenol dode caethoxylate (OP12EO) MS006 NA
Nonylphenols Octylphenol he ptaethoxylate (OP7EO) MS006 NA
Nonylphenols Octylphenol he xaethoxylate (OP6EO) MS006 NA
Nonylphenols Octylphenol n onaethoxylate (OP9EO) MS006 NA
Nonylphenols Octylphenol oc taethoxylate (OP8EO) MS006 NA
Nonylphenols Octylphenol pe ntaethoxylate (OP5EO) MS006 NA
Nonylphenols Octylphenol tetraethoxylate (OP4EO) MS006 NA
Nonylphenols Octylphenol triethoxylate (OP3EO) MS006 NA
Nonylphenols Octylphenol unde caethoxylate (OP11EO) MS006 NA
Nonylphenols Total Nonylphenol Polyethoxylates MS006 NA
Nonylphenols Total Nonylphenols MS004 NA
Nonylphenols Total Octylphenol Polyethoxylates MS006 NA

Nutrients Ammonia As Nitrogen (NH3 -N) Ammonia by 4500-NH3 7664-41-7

Nutrients Nitrate/Nitrite (NO3/NO2-N) EPA353.2 NA

Nutrients Total Kjeldahl Nitrogen (TKN) EPA351.2 NA

Nutrients Total Phosphorus Total Phosphorus by 365.4 7723-14-0
SVOC 1,2-Diethyl-Cyclobutane SVOCs by EPA 625 NA
SVOC 1,2-Diphenyl hydrazine SVOCs by EPA 625 122-66-7
SVOC 1,6-dimethylnaphthalene SVOCs by EPA 625 575-43-9
SVOC 1-methylnaphthalene SVOCs by EPA 625 90-12-0
SVOC 2,4,5-Trichlorophenol SVOCs by EPA 625 95-95-4
SVOC 2,4,6-Trichlorophenol SVOCs by EPA 625 88-06-2
SVOC 2,4-Dichlorophenol SVOCs by EPA 625 120-83-2
SVOC 2,4-Dimethylphenol SVOCs by EPA 625 105-67-9
SVOC 2,4-Dinitrophenol SVOCs by EPA 625 51-28-5
SVOC 2,4-Dinitrotoluene SVOCs by EPA 625 121-14-2
SVOC 2,6,10,14-Tetramethyl Pentadecane SVOCs by EPA 625 1921-70-6
SVOC 2,6-Dinitrotoluene SVOCs by EPA 625 606-20-2
SVOC 2-Butoxy ethanol SVOCs by EPA 625 NA
SVOC 2-Chloronaphthalene SVOCs by EPA 625 91-58-7
SVOC 2-Chlorophenol SVOCs by EPA 625 95-57-8
SVOC 2-Cyclopenten1-one SVOCs by EPA 625 NA
SVOC 2-Hydroxy-Benzaldehyde SVOCs by EPA 625 90-02-8
SVOC 2-Mercaptobenzothiazole SVOCs by EPA 625 149-30-4
SVOC 2-Methylnaphthalene SVOCs by EPA 625 91-57-6
SVOC 2-Naphthalenecarboxaldehyde SVOCs by EPA 625 NA
SVOC 2-Nitroaniline SVOCs by EPA 625 88-74-4
SVOC 2-Nitrophenol SVOCs by EPA 625 88-75-5
SVOC 3,3'-Dichlorobenzidine SVOCs by EPA 625 91-94-1
SVOC 3,6-Dimethylundecane SVOCs by EPA 625 NA

SVOC 3-Methyl-2-Heptanone SVOCs by EPA 625 NA

SVOC 3-Methyl-Benzaldehyde SVOCs by EPA 625 620-23-5
SVOC 3-Methyl-Butanoic Acid SVOCs by EPA 625 NA



## D-3Appendix D – List of Target Analytes

Analytical Class Analyte Name Analytical Method CAS Number

SVOC 3-Methylphenol SVOCs by EPA 625 NA

SVOC 3-Nitroaniline SVOCs by EPA 625 99-09-2
SVOC 3-Phenyl-2-Propenal SVOCs by EPA 625 104-55-2
SVOC 4,6-Dinitro-2-Methylphenol SVOCs by EPA 625 534-52-1
SVOC 4-Bromophenyl Phenyl Ether SVOCs by EPA 625 101-55-3
SVOC 4-Chloro-3-Methylphenol SVOCs by EPA 625 59-50-7
SVOC 4-Chloroaniline SVOCs by EPA 625 106-47-8
SVOC 4-Chlorophenyl Phenyl Ether SVOCs by EPA 625 7005-72-3
SVOC 4-Methyl-Pentanoic Acid SVOCs by EPA 625 NA
SVOC 4-Nitrobenzenamine SVOCs by EPA 625 100-01-6
SVOC 4-Nitrophenol SVOCs by EPA 625 100-02-7
SVOC 5-Butyl-Hexadecane SVOCs by EPA 625 NA
SVOC Acenaphthene SVOCs by EPA 625 83-32-9
SVOC Acenaphthylene SVOCs by EPA 625 208-96-8
SVOC Acetophenone SVOCs by EPA 625 98-86-2
SVOC Anthracene SVOCs by EPA 625 120-12-7
SVOC Atrazine SVOCs by EPA 625 1912-24-9
SVOC Benzeneacetic Acid SVOCs by EPA 625 NA

SVOC Benzenepropanoic Acid SVOCs by EPA 625 NA

SVOC Benzidine SVOCs by EPA 625 92-87-5
SVOC Benzo(A)Anthracene SVOCs by EPA 625 56-55-3
SVOC Benzo(A)Pyrene SVOCs by EPA 625 50-32-8
SVOC Benzo(B)Fluoranthene SVOCs by EPA 625 205-99-2
SVOC Benzo(G,H,I)Perylene SVOCs by EPA 625 191-24-2
SVOC Benzo(K)Fluoranthene SVOCs by EPA 625 207-08-9
SVOC Benzothiazole SVOCs by EPA 625 95-16-9
SVOC Bicyclo[2.2.1]Heptane,1,7,7-Trimethyl- SVOCs by EPA 625 NA
SVOC Biphenyl a SVOCs by EPA 625 92-52-4
SVOC Bis (2-Chloroisopropyl)Ether SVOCs by EPA 625 108-60-1
SVOC Bis(2-Chloroethoxy)Met hane SVOCs by EPA 625 111-91-1
SVOC Bis(2-Chloroethyl)Ether SVOCs by EPA 625 111-44-4
SVOC Bis(2-Chloroisopropyl) Ether SVOCs by EPA 625 39638-32-9
SVOC Bis(2-Ethylhexyl) Phthal ate SVOCs by EPA 625 117-81-7
SVOC Butyl Benzyl Phthalate SVOCs by EPA 625 85-68-7
SVOC Caprolactam SVOCs by EPA 625 105-60-2
SVOC Carbazole SVOCs by EPA 625 86-74-8
SVOC Cholesterol SVOCs by EPA 625 NA
SVOC Chrysene SVOCs by EPA 625 218-01-9
SVOC Cyclohexadecane SVOCs by EPA 625 NA
SVOC Dibenz(A,H)Anthracene SVOCs by EPA 625 53-70-3
SVOC Dibenzofuran SVOCs by EPA 625 132-64-9
SVOC Diethyl Phthalate SVOCs by EPA 625 84-66-2
SVOC Dimethyl Phthalate SVOCs by EPA 625 131-11-3
SVOC Di-N-Butyl Phthalate SVOCs by EPA 625 84-74-2
SVOC Di-N-Octyl Phthalate SVOCs by EPA 625 117-84-0
SVOC Dodecane SVOCs by EPA 625

SVOC Eicosane SVOCs by EPA 625 112-95-8
SVOC Fluoranthene SVOCs by EPA 625 206-44-0
SVOC Fluorene SVOCs by EPA 625 86-73-7
SVOC Heneicosane SVOCs by EPA 625 629-94-7
SVOC Heptadecane SVOCs by EPA 625 629-78-7
SVOC Hexachlorobenzene SVOCs by EPA 625 118-74-1
SVOC Hexachlorobutadiene a SVOCs by EPA 625 87-68-3



## D-4Appendix D – List of Target Analytes

Analytical Class Analyte Name Analytical Method CAS Number

SVOC Hexachlorocyclopentadiene SVOCs by EPA 625 77-47-4
SVOC Hexachloroethane SVOCs by EPA 625 67-72-1
SVOC Hexadecanoic Acid SVOCs by EPA 625 NA
SVOC Indeno(1,2,3-Cd)Pyrene SVOCs by EPA 625 193-39-5
SVOC Indole SVOCs by EPA 625 NA
SVOC Isophorone SVOCs by EPA 625 78-59-1
SVOC Isopropylbenzene-4,Methyl-1 SVOCs by EPA 625 99-87-6
SVOC M-Cresol SVOCs by EPA 625 108-39-4
SVOC Naphthalene SVOCs by EPA 625 91-20-3
SVOC N-Hexadecane SVOCs by EPA 625 544-76-3
SVOC Nitrobenzene SVOCs by EPA 625 98-95-3
SVOC N-Nitroso Di-N-Propylamine SVOCs by EPA 625 621-64-7
SVOC N-Nitrosodimethylamine SVOCs by EPA 625 62-75-9
SVOC N-Nitrosodiphenylamine SVOCs by EPA 625 86-30-6
SVOC Nonadecane SVOCs by EPA 625 629-92-5
SVOC Nonanoic Acid SVOCs by EPA 625 NA
SVOC N-Pentadecane a SVOCs by EPA 625 629-62-9
SVOC N-Tetradecane a SVOCs by EPA 625 629-59-4
SVOC O-Cresol SVOCs by EPA 625 95-48-7
SVOC Octadecane SVOCs by EPA 625 NA
SVOC P-Cresol SVOCs by EPA 625 106-44-5
SVOC Pentachlorophenol SVOCs by EPA 625 87-86-5
SVOC Phenanthrene SVOCs by EPA 625 85-01-8
SVOC Phenol SVOCs by EPA 625 108-95-2
SVOC Pyrene SVOCs by EPA 625 129-00-0
SVOC Triethyl Phosphate SVOCs by EPA 625 NA

VOC (2-Methyl-1-Propenyl)-Benzene VOCs by EPA 624 NA

VOC (E)-2-Butenal VOCs by EPA 624 NA

VOC 1,1,1,2-Tetrachloroethane VOCs by EPA 624 630-20-6
VOC 1,1,1-Trichloroethane VOCs by EPA 624 71-55-6
VOC 1,1,2,2-Tetrachloroethane VOCs by EPA 624 79-34-5
VOC 1,1,2-Trichloroethane VOCs by EPA 624 79-00-5
VOC 1,1-Dichloroethane VOCs by EPA 624 75-34-3
VOC 1,1-Dichloroethene VOCs by EPA 624 75-35-4
VOC 1,1-Dichloropropene VOCs by EPA 624 563-58-6
VOC 1,2,3,4-Tetrahydro-5-Methylnaphthalene VOCs by EPA 624 2809-64-5
VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene VOCs by EPA 624 1680-51-9
VOC 1,2,3,4-Tetrahydronaphthalene VOCs by EPA 624 119-64-2
VOC 1,2,3-Trichlorobenzene VOCs by EPA 624 87-61-6
VOC 1,2,3-Trichloropropane VOCs by EPA 624 96-18-4
VOC 1,2,4-Trichlorobenzene VOCs by EPA 624 120-82-1
VOC 1,2,4-Trimethylbenzene VOCs by EPA 624 95-63-6
VOC 1,2-Dibromo-3-Chloropropane VOCs by EPA 624 96-12-8
VOC 1,2-Dibromoethane VOCs by EPA 624 106-93-4
VOC 1,2-Dichlorobenzene VOCs by EPA 624 95-50-1
VOC 1,2-Dichloroethane VOCs by EPA 624 107-06-2
VOC 1,2-Dichloropropane VOCs by EPA 624 78-87-5
VOC 1,3,5-Trimethylbenzene VOCs by EPA 624 108-67-8
VOC 1,3-Dichlorobenzene VOCs by EPA 624 541-73-1
VOC 1,3-Dichloropropane VOCs by EPA 624 142-28-9
VOC 1,3-Methylnaphthalene VOCs by EPA 624 NA
VOC 1,4-Dichlorobenzene VOCs by EPA 624 106-46-7
VOC 1,7-Methylnaphthalene VOCs by EPA 624 NA



## D-5Appendix D – List of Target Analytes

Analytical Class Analyte Name Analytical Method CAS Number

VOC 1-Ethyl-3-Methyl-Benzene VOCs by EPA 624 NA

VOC 1-Methyl-2-(1-Methylethyl)-Benzene VOCs by EPA 624 NA

VOC 1-Methyl-4-(1-Methylidene) -Cyclohexane VOCs by EPA 624 NA

VOC 1-Methylnaphthalene b VOCs by EPA 624 90-12-0
VOC 2- Heptanone VOCs by EPA 624 NA
VOC 2,2-Dichloropropane VOCs by EPA 624 594-20-7
VOC 2,3-Dihydro-4-Methyl-1h-Indene VOCs by EPA 624 824-22-6
VOC 2,6-Dimethylnaphthalene VOCs by EPA 624 581-42-0
VOC 2-Butanone VOCs by EPA 624 78-93-3
VOC 2-Butenal VOCs by EPA 624 NA

VOC 2-Ethyl-1,3,5-Trimethyl-Benzene VOCs by EPA 624 NA

VOC 2-Ethyl-1,4-Dimethyl-Benzene VOCs by EPA 624 2039-89-6
VOC 2-Ethyl-1-Hexanol VOCs by EPA 624 104-76-7
VOC 2-Hexanone VOCs by EPA 624 591-78-6
VOC 2-Methylnaphthalene b VOCs by EPA 624 91-57-6
VOC 4-Chlorotoluene VOCs by EPA 624 106-43-4
VOC 4-Isopropyltoluene VOCs by EPA 624 99-87-6
VOC 4-Methyl-2-Pentanone VOCs by EPA 624 108-10-1
VOC Acetone VOCs by EPA 624 67-64-1
VOC Benzaldehyde VOCs by EPA 624 100-52-7
VOC Benzene VOCs by EPA 624 71-43-2
VOC Benzocycloheptatriene VOCs by EPA 624 NA
VOC Benzofuran VOCs by EPA 624 271-89-6
VOC Biphenyl VOCs by EPA 624 92-52-4
VOC Bromobenzene VOCs by EPA 624 108-86-1
VOC Bromochloromethane VOCs by EPA 624 74-97-5
VOC Bromodichloromethane VOCs by EPA 624 75-27-4
VOC Bromoform VOCs by EPA 624 75-25-2
VOC Bromomethane VOCs by EPA 624 74-83-9
VOC Carbon Disulfide VOCs by EPA 624 75-15-0
VOC Carbon Tetrachloride VOCs by EPA 624 56-23-5
VOC Chlorobenzene VOCs by EPA 624 108-90-7
VOC Chloroethane VOCs by EPA 624 75-00-3
VOC Chloroform VOCs by EPA 624 67-66-3
VOC Chloromethane VOCs by EPA 624 74-87-3
VOC Chlorotoluene VOCs by EPA 624 25168-05-2
VOC Cis-1,2-Dichloroethene VOCs by EPA 624 156-59-2
VOC Cis-1,3-Dichloropropene VOCs by EPA 624 10061-01-5
VOC Cyclohexane VOCs by EPA 624 110-82-7
VOC Dibromochloromethane VOCs by EPA 624 124-48-1
VOC Dibromomethane VOCs by EPA 624 74-95-3
VOC Dichlorodifluoromethane VOCs by EPA 624 75-71-8
VOC Dimethoxymethane VOCs by EPA 624 NA
VOC Ethylbenzene VOCs by EPA 624 100-41-4
VOC Fluorotrimethylsilane VOCs by EPA 624 420-56-4
VOC Hexachlorobutadiene VOCs by EPA 624 87-68-3
VOC Isopropylbenzene VOCs by EPA 624 98-82-8
VOC Limonene VOCs by EPA 624 000138-86-3
VOC M-,P-Xylene (Sum Of Isomers) VOCs by EPA 624 NA
VOC Methyl Acetate VOCs by EPA 624 79-20-9
VOC Methyl Tertiary Butyl Ether (MTBE) VOCs by EPA 624 1634-04-4
VOC Methylcyclohexane VOCs by EPA 624 108-87-2
VOC Methylene Chloride VOCs by EPA 624 75-09-2



## D-6Appendix D – List of Target Analytes



## D-7 Analytical Class Analyte Name Analytical Method CAS Number

VOC Naphthalene b VOCs by EPA 624 91-20-3
VOC N-Butylbenzene VOCs by EPA 624 104-51-8
VOC Nonanal VOCs by EPA 624 124-19-6
VOC N-Pentadecane VOCs by EPA 624 629-62-9
VOC N-Propylbenzene VOCs by EPA 624 103-65-1
VOC N-Tetradecane VOCs by EPA 624 629-59-4
VOC O-Xylene VOCs by EPA 624 95-47-6
VOC Sec-Butylbenzene VOCs by EPA 624 135-98-8
VOC Styrene VOCs by EPA 624 100-42-5
VOC Sulfur Dioxide VOCs by EPA 624 2025884
VOC Tert-Butylbenzene VOCs by EPA 624 98-06-6
VOC Tetrachloroethene VOCs by EPA 624 127-18-4
VOC Tetrahydrofuran VOCs by EPA 624 109-99-9
VOC Toluene VOCs by EPA 624 108-88-3
VOC Trans-1,2-Dichloroethene VOCs by EPA 624 156-60-5
VOC Trans-1,3-Dichloropropene VOCs by EPA 624 10061-02-6
VOC Trichloroethene VOCs by EPA 624 79-01-6
VOC Trichlorofluoromethane VOCs by EPA 624 75-69-4
VOC Trichlorotrifluoroet hane VOCs by EPA 624 76-13-1
VOC Trimethylsilanol VOCs by EPA 624 1066-40-6
VOC Vinyl Acetate VOCs by EPA 624 108-05-4
VOC Vinyl Chloride VOCs by EPA 624 75-01-4

a Also measured analytically as a VOC using EPA Method 624. For the purposes of this report, th is compound has been classified as a VOC to keep with other similar compounds.

b Also measured analytically as a SVOC using EPA Method 625. For the purposes of this report, this compound has been classified as an SVOC to keep with other PAHs. NA = Not Applicable.

### Appendix E – Analyte Concentrations and Summary Statistics from Ambient Water Samples



## E-1 

# Appendix E
A nalyte Concentrations and Summa ry St atisti cs from Ambient Water Samples

Analyte - Ambient Water b ,c #Waters Screening BM Non Detects Det. Limit(s) Min. Mean Median Max.

A cetone 10 0.9 2.81 2.25 9.2 n/a 2 5

A luminum, Dissolved 16 3.1 218.9 38.6 870 n/a 2 6.2

A luminum, Total 16 29.2 653.9 357.5 3950 87 0

A mmonia As Nitrogen (NH3-N) 15 0.02 0.15 0.066 0.93 1.2 6 0.04, 0.05

A rsenic, Dissolved 17 1 8.09 2 30 36 8 1, 4

A rsenic, Total 17 1 8.19 2.9 28.9 0.018 8 1

, 4
Barium, Dissolved 10 14.2 39.04 34.55 65.2 n/a 0
Barium, Total 10 13.3 45.96 33.9 96.3 1000 0 Biochemical Oxygen Demand (BOD) 14 0.479 2.68 1.35 9.3 30 4 1, 4 Calcium, Dissolved 17 23000 104382 72100 310000 n/a 0 Calcium, Total 17 23000 107876 71100 320000 n/a 0 Chemical Oxygen Demand (COD) 15 10 298.3 72 1700 n/a 3 2 0 Conductivity 15 0.2215 10.49 7.18 38.2 n/a 0
Copper, Dissolved 17 1.5 4.88 2.5 24.2 3.1 a 7 5 Copper, Total 17 1.8 5.74 4 23.3 1300 7 5 Dissolved Organic Carbon (DOC) 17 1 4.66 4.4 8.5 n/a 1 3 Dissolved Oxygen 15 1 6.69 6.5 12.33 n/a 0

E. Coli 9 5 3236 130 24196 130 1 10

Enterococci 9 5 1387 333 5099 33 1 10

Fecal Coliform 8 5 6452 220 44000 14 1 10
Iron, Total 10 50 812.2 382 4180 300 2 100 Magnesium, Dissolved 17 6000 304644 172000 1100000 n/a 0 Magnesium, Total 17 6000 306001 168000 1100000 n/a 0 Manganese, Dissolved 17 0.5 11.71 3.7 106 n/a 7 1, 2.5, 6.7, 17 Manganese, Total 17 1.25 60.54 43 165 100 2 2.5, 13

Nickel, Dissolved 17 2.3 4.60 5 7.2 8.2 a 7 1 0
Nickel, Total 17 2.4 5.81 5 16.7 610 7 10 Nitrate/Nitrite (NO3/NO2-N) 15 0.025 0.36 0.097 1.5 n/a 6 0.05 pH 16 6.90 7.41 7.26 8.18 n/a 0
Potassium, Dissolved 10 3600 72198 60700 175000 n/a 0
Potassium, Total 10 3470 71119 59750 174000 n/a 0 Salinity 14 0.1 6.06 3.85 22.4 n/a 0

Selenium, Dissolved 17 1 22.51 5 100 5 a 7 2

, 1 0 Selenium, Total 17 1 22.71 5 93.9 170 10 2, 10 Sodium, Dissolved 10 17600 1446690 1009500 3630000 n/a 0 Sodium,Total 10 17400 1459630 1160000 3680000 n/a 0 Temperature 16 8.8 20.07 21.575 29.37 n/a 0 Total Kjeldahl Nitrogen (TKN) 15 0.05 1.00 0.587 4.7 n/a 3 0.1 Total Organic Carbon (TOC) 13 2 6.12 5.1 19 n/a 0 Total Phosphorus 15 0.0125 0.20 0.059 2 0.1 6 0.025, 0.05 Total Suspended Solids (TSS) 17 5 22.13 15 98 n/a 1 10 Turbidity 16 0.03 32.01 17.5 186 n/a 0
Vanadium, Dissolved 10 0.5 0.94 0.5 2.3 n/a 6
Vanadium,Total 10 0.5 2.90 1.6 9.3 n/a 5 1, 2.5, 10
Zinc, Dissolved 17 3.4 19.32 11.4 116 81 4 10
Zinc, Total 17 2.9 10.98 10.6 23.9 7400 4 10

### Appendix E – Analyte Concentrations and Summary Statistics from Ambient Water Samples



## E-2 Note: (a) Screening benchmark (BM) is below detection limit(s) (b) Analytes not listed in this table were not detected. (c) Surrounding Ambient water (als o used as service water on select vessels for deck washdown, firemain systems, or other services as specified in Chapter 3) was tested for the follo wing classes of pollutants: pathogens, dissolved and total metals, the socalled ‘classical pollutants’, nutrient and nutrient related parameters, VOCs and SVOCs (see Appendix D).Appendix F – Analyte Concentrations and Su mmary Statistics from Source Water Samples



## F-1 

# Appendix F
A nalyte Concentrations and Summary St atisti cs from Source Water Samples

Analyte - Source Water b ,c #Waters Screening BM Non Detects Min. Mean Median Max. Det. Limit(s)

Al u minum, Dissolved 1 11 6.3 64.94 17.1 310 n/a 50

1 11 8.6 64.06 27.5 250 87 50 A luminum, Total

5 10 0.02 0.18 0.041 0.731 1.2 0.04,0.05 A mmonia As Nitrogen (NH3-N)
Barium, Dissolved 7 0 11.4 29.14 29 58.5 n/a

7 0 11.9 29.07 30.1 56.9 1000 Barium, Total

8 2 a 0.55 1.25 7.84 5.65 18 2.5, 5 Bromodichloromethane
Calcium, Dissolved 0 11 1450 28496 29600 88000 n/a

0 11 1280 28409 29700 88000 n/a Calcium, Total Chemical Oxygen Demand (COD) 6 11 5 11.55 10 28.6 n/a 10, 20

8 0 0.05 18.56 16 57.2 5.7 Chloroform Conductivity 10 0.159 33.39 0.4075 330.4 n/a 0

Copper, Dissolved 11 2.4 16.11 6.2 65 3.1 a 2 5
Copper, Total 11 2.5 20.55 8.7 82 1300 2 5

Dibromochloromethane 8 0.9 3.38 2.45 10 0.4 a 3 2.5, 5
Dissolved Oxygen 10 2.07 6.87 6.96 11.72 n/a 0
Magnesium, Dissolved 11 250 6815 7100 19000 n/a 2 500, 1000
Magnesium, Total 11 350 6855 7300 19000 n/a 2 1000
Manganese, Dissolved 11 0.5 6.00 1.25 33 n/a 6 1, 2.5
Manganese, Total 11 1 9.30 5.4 37 100 1 2.5
Nitrate/Nitrite (NO3/NO2-N) 11 0.025 1.26 1.6 2.4 n/a 1 0.05
pH 11 6.61 7.37 7.08 8.45 n/a 0
Potassium, Dissolved 7 1000 3077 3340 5220 n/a 2 2000, 3000
Potassium, Total 7 1000 3003 2840 5270 n/a 1 2000
Sodium, Dissolved 7 16100 56057 24300 140000 n/a 0
Sodium,Total 7 11500 55143 24100 144000 n/a 0
Temperature 10 5.47 20.42 21.16 31.16 n/a 0
Total Kjeldahl Nitrogen (TKN) 10 0.05 0.66 0.401 1.8 n/a 1 0.1 Total Organic Carbon (TOC) 8 1.5 3.21 2.35 10.4 n/a 3 3
Total Phosphorus 10 0.025 0.30 0.363 0.52 0.1 2 0.05

Total Residual Chlorine 10 0.05 0.46 0.415 1.3 0.0075 a 3 0.1
Turbidity 11 0.5 5.89 2 19.3 n/a 2 1
Zinc, Dissolved 11 4.1 154.8 25.3 1200 81 0
Zinc, Total 11 4.1 145.3 25.1 1100 7400 0

Note: (a) Screening benchmark (BM) is below detection limit(s) (b) Analytes not listed in this table were not detected. (c) Source and service water was tested for the following classe s of pollutants: pathogens, dissolved and total metals, the so -called ‘classical pollutants’, nutrient and nutrient rela ted parameters, VOCs and SVOCs (see Appendix D).Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix GSUPPORTING INFORMATION FOR EPA’SSCREENING-LEVEL WATER QUALITYMODELAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)DischargeTypeFlowRate(m3/day)Known InformationAssumptionsCalculationsFire BoatDeckWash0.011 deck wash per month50 gallons per washAll deck washes done pierside50 gal per month/30 days = 1.67 gal/dayFire BoatGeneratorEngine1.821 generatorInboard diesel engine2 gpm cooling water flowrate4 hours operation when firecall1 fire call per day2 gal per minute X 240 min per day = 480 gal/dayFire BoatPropulsionEngine36.342 propulsion engines420 hp inboard engine20 gpm cooling water flow4 hours operation when firecall20 gal per minute X240 min per day X2 engines = 9600gal/dayFishing(Gillnetter)Fish Hold1.521.5 tons of ice per offload1 offload per day1.5 tons of ice (or 1524 kg) X 1kg/L X 1offload/day = 1524 liters/dayFishing(Gillnetter)Fish Hold0.0850 lbs (25.2 liters) if iceper offloadoffloads daily75.6 liters/dayFishing(Gillnetter)Fish Hold0.701.75 tons of ice peroffloadOffload dailyIce tank holds 50% fish,35% ice, 15% air(0.61tons of ice or 691.48liters of ice)691.47 liters/dayFishing(Gillnetter)PropulsionEngine14.9320 gpm cooling water flowrate1200 hours per year inoperation20 gal/min X 60 min/hour X 1200 hours/365 days= 3945 gal/dayG-1Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Fishing(Gillnetter)PropulsionEngine14.931 Caterpillar 350hp20 gpm cooling water flowrate1200 hours per year inoperation20 gal/min X 60 min/hour X 1200 hours/365 days= 3945 gal/dayFishing(Gillnetter)PropulsionEngine14.9320 gpm cooling water flowrate1200 hours per year inoperation20 gal/min X 60 min/hour X 1200 hours/365 days= 3945 gal/dayFishing(Gillnetter)PropulsionEngine14.9320 gpm cooling water flowrate1200 hours per year inoperation20 gal/min X 60 min/hour X 1200 hours/365 days= 3945 gal/dayFishing(Lobster Boat)Fish Hold2.83Used average of knownLongliner fish hold flowratesFishing(Longliner)BilgeWater0.451 manual pump12v bilge pump at 20 gpm10 minutes per pump out2 pump outs per day20 gal per min X 10 min X 2 pump/day = 120gal/dayFishing(Longliner)Fish Hold4.068 tons of ice per offloadOffload every 2 daysTanks are full at offload8 tons of ice (or 8128 kg) X 1kg/L X 1 offload/ 2days = 4064 liters/dayFishing(Longliner)Fish Hold1.59Fish hold tank is 8X10X4ft (9.06 m3)Emptied at each offloadIce tank holds 50% fish,35% ice, 15% air(3.17 m3of ice)Offloads 1 every 2 days9.06 m3X 35% X 1 offload/2 days = 1.59 m3/dayFishing(Purse Seiner)Fish Hold31.71Fish hold tank is8X20X20 ft (90.6 m3)Emptied at each offloadice tank holds 50% fish,35% ice, 15% air(3.17 m3of ice)offloads daily90.6 m3X 35% = 31.71 m3/dayG-2Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Fishing(Purse Seiner)Fish Hold15.66fish hold tank A is15X10X6 ft (25.5 m3)fish hold tank A is15X8X6 ft (20.4 m3)holds 60,000 lbs of fish(27215 kg)emptied at each offloaddensity of fish is 0.9 kg/Loffloads daily27215 kg / 0.9kg/L = 30,239 L of fish (30.24 m3of fish)45.9 m3tank - 30.24 m3of fish = 15.66 m3of holdwater15.66 m3of hold water X = 15.66 m3/dayFishing(Purse Seiner)Fish Hold18.36tank holds about85,000lbs of fish(42,840 liters of fish)holding tank is 70% fish,30% water offloads daily42,840 liters of fish X 30 / 70 = 18,360 Liters/dayFishing(Purse Seiner)Fish Hold10.20fish hold tank is 1200 ft3(33.99 m3)emptied at each offloadholding tank is 70% fish,30% water offloads daily33.99 m3X 30% = 10.2 m3/dayFishing(Purse Seiner)Fish Hold5.34fish hold tank is 630 ft3(17.84 m3)emptied at each offloadholding tank is 70% fish,30% water offloads daily17.84 m3 X 30% = 5.34 m3/dayFishing(Purse Seiner)Fish HoldClean1.3330 minute washgarden hose flow rate is11.67 gpm11.67 gal per min X 30 min X 1 wash/day = 350.1gal/dayFishing(Purse Seiner)Fish HoldClean2.3330 minute washgarden hose flow rate is11.67 gpm11.67 gal per min X 30 min X 1 wash/day = 350.1gal/dayFishing(Purse Seiner)Fish HoldClean3.3330 minute washgarden hose flow rate is11.67 gpm11.67 gal per min X 30 min X 1 wash/day = 350.1gal/dayFishing(Purse Seiner)Fish HoldClean0.04tanks are cleaned 1 permonth30 minute washgarden hose flow rate is11.67 gpm11.67 gal per min X 30 min X 1 wash/30 days =11.67gal/dayFishing(Purse Seiner)Fish HoldClean3.334 month season30 minute washgarden hose flow rate is11.67 gpm11.67 gal per min X 30 min X 1 wash/day = 350.1gal/dayFishing(Purse Seiner)GeneratorEngine1.4117,000 hours over 15years2 gpm cooling flow2 gal/min X 60 min/hr X 17000hrs/15 years/365days = 372.6 gal/dayG-3Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Fishing(Purse Seiner)PropulsionEngine16.591 Cummin 350hp inboarddiesel engine4000 hours in 3 years20 gpm cooling flow20 gal/min X 60 min/hr X 4000hrs/3 years/365days = 4383.6 gal/dayResearchPropulsionEngine0.031 200hp gas outboardengine5 years old250 hours of use1 gpm cooling water flowrate1 gal per minute X 250 hours/ 5 years of use X 1engines X 365 days/year = 8.22 gal/dayResearchPropulsionEngine0.152 225 hp gas outboardengine5 years old600 hours of use1 gpm cooling water flowrate1 gal per minute X 600 hours/ 5 years of use X 2engines X 365 days/year = 39.45 gal/dayFishing(Shrimp Trawler)BilgeWater2.845 min per pump out1 pump out every day150 gal/min bilge pumprate150gpm, 5 min per pumpout, once a day: 750 gal/day150 gal per min X 5 min per day = 750 gal/minFishing(Shrimp Trawler)DeckWash0.661 deck wash per day15 minute deck wash withgarden hosegarden hose flow rate is11.67 gpm11.67 gal per min X 15 min X 1 wash/day =175.05 gal/dayFishing(Shrimp Trawler)DeckWash0.76200 gallons per day200 gal/ dayFishing(Shrimp Trawler)DeckWash0.151 deck wash per offload10 minute deck wash withgarden hose1 offload every 3 daysGarden hose flow rate is11.67 gpm11.67 gal per min X 10 min X 1 wash/ 3 days =38.9 gal/dayFishing(Shrimp Trawler)Fish Hold0..22Holding tank hold 3000lbsof shrimpDensity of fish is 0.9 kg/literHolding tank is 70%shrimp,30% waterOffloads 1 every 3 days1360 kg of fish / 0.9kg/L = 1512 liters of fish1512 X 30%/70% = 648L of ice slurry648L / 3 days = 216 L/dayFishing(Shrimp Trawler)Fish Hold2.12Holding tank is 1500 ft3Generally half full atoffloadHolding tank is 70%shrimp,30% waterOffloads 1 every 3 days1500 ft3X 30% X 1/2 full X 1offload/3 days = 75ft3/dayG-4Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Fishing(Shrimp Trawler)Fish HoldClean0.1315 minute hose down aftereach offloadOffloads 1 every 3 daysGarden hose flow rate is11.67 gpm11.67 gal per min X 15 min X 1 wash/ 3 day X =33.66 gal/dayFishing(Shrimp Trawler)Fish HoldClean0.1315 minute hose down aftereach offloadOffloads 1 every 3 daysGarden hose flow rate is11.67 gpm11.67 gal per min X 15 min X 1 wash/ 3 day X =33.66 gal/dayFishing(Shrimp Trawler)DeckWash0.081 deck wash per offload60 gallons per wash1 offload every 3 days60 gal every 3 days X year = 20 gal/dayFishing(Shrimp Trawler)DeckWash0.041 deck wash per offload30 gallons per wash2 offload every 3 days30 gal every 3 days X year = 20 gal/dayFishing(Shrimp Trawler)Fish Hold1.77Used average of knowntrawler fish hold flow ratesFishing(Shrimp Trawler)Fish Hold1.425000 gallon tank75% full at offloadHolding tank is 70%shrimp,30% waterOffloads 1 every 3 days5000 gal X 30% X 3/4 full X 1offload/3 days =375 gal /dayFishing(Shrimp Trawler)Fish HoldClean0.1315 minute hose down aftereach offloadOffloads 1 every 3 daysGarden hose flow rate is11.67 gpm11.67 gal per min X 15 min X 1 wash/ 3 day X =33.66 gal/daySupply BoatDeckWash0.05Cleaned with hose15 minute per deckwashGarden hose flow rate is11.67 gpm1 wash every 2 weeks11.67 gal per min X 15 min X 1 wash/14 days=12.5 gal/dayG-5Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Fishing(Tender Vessel)Fish Hold32.823 tanks of 2700 ft3each(229.4 m3total)holds 325,000 lbs of fish(147417 kg of fish)emptied at offloaddensity of fish is 0.9 kg/Loffloads 1 every 2 days147417 kg / 0.9kg/L = 163,797 L of fish (163.8m3of fish)229.4 m3tank - 163.8 m3of fish = 65.6 m3of holdwater65.6 m3of hold water X 1 offload/ 2 days =32.82m3/dayFishing(Tender Vessel)Fish Hold18.43holds 170,000 lbs of fish(77,110 kg of fish)emptied at offloaddensity of fish is 0.9 kg/Lholding tank is 70% fish,30% wateroffloads 1 every 2 days77,110 kg / 0.9kg/L = 85678 L of fish (86 m3offish)86 m3of fish X 30% / 70% X 1 offload / 2 days =18.43 m3/dayFishing(Tender Vessel)Fish Hold6.81fish hold tank is 1600 ft3(45.3 m3)holding tank is 70% fish,30% wateroffloads 1 every 2 days(480ft3),45.3 m3X 30% X 1 every 2 days = 6.81m3/dayFishing(Tender Vessel)Fish HoldClean0.3830 minute wash after eachoffload1 offload every 2 daysgarden hose flow rate is11.67 gpm after eachoffload, I offload/2days11.67 gal per min X 30 min X 1 wash/2 days =100.95gal/dayFishing(Tender Vessel)Fish HoldClean0.3830 minute wash after eachoffload1 offload every 2 daysgarden hose flow rate is11.67 gpm after eachoffload, I offload/2days11.67 gal per min X 30 min X 1 wash/2 days =100.95gal/dayTour BoatBilgeWater0.055 min to pump bilge1 pump per week12v bilge pump at 20 gpm20 gal per min X 5 min X 1 pump/7 days = 14.3gal/dayTour BoatBilgeWater0.03pumped very rarely12v bilge pump at 20 gpmrarely defined as 1 pumpevery 2 weeks5 min to pump bilge20 gal per min X 5 min X 1 pump/14 days = 7.2gal/dayG-6Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Tour BoatDeckWash0.061 deck wash per week10 minute deck wash witha garden hosegarden hose flow rate is11.67 gpm11.67 gal per min X 10 min X 1 wash/7 days =16.67 gal/dayTour BoatDeckWash0.221 deck wash per day5 minute deck wash withgarden hosegarden hose flow rate is11.67 gpm11.67 gal per min X 5 min X 1 wash/1 days =58.35 gal/dayTour BoatGeneratorEngine5.402 45kw 76hp inboarddiesel engineheat exchange system6 hours per day ofoperation2 gpm cooling flow2 gal per minute X 360 min per day X 2 engines=1440 gal/dayTour BoatGeneratorEngine2.202 27kw 46hp inboarddiesel enginesraw water cooled4500 hours used in last 5years2 gpm cooling flow2 gal per minute X 900 hours/year X 2 engines =591.78 gal/dayTour BoatPropulsionEngine27.251 catapillar 86hp dieselinboard engine20 years oldheat exchanger6 hours per day ofoperation20 gpm cooling flow20 gal per min X 360 min per day X = 7200gal/dayTour BoatPropulsionEngine54.512 catapilar 275 dieselinboard enginesheat exchange system6 hours per day ofoperation20 gpm cooling flow20 gal per min X 360 min per day X 2 engines =14400 gal/dayTour BoatPropulsionEngine44.802 catapilar 275 dieselinboard enginesraw water cooled9000 hours operated inlast 5 years20 gpm cooling flow20 gal per min X 1800 hours per year X 2 engines= 11836 gal/dayTow/SalvageBilgeWater0.052 min per pump out1 pump out every 3 days12v bilge pump at 20 gpm20 gal per min X 2 min X 1 pump/3 days = 13gal/dayG-7Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Tow/SalvageBilgeWater2.7360 gal per minute flowrate5 second per pump out1 pump out every 10minutes60 gal per minute X 12 min/day = 720 gal/dayTow/SalvageDeckWash0.031 deck wash per week50 gallons per wash50 gal per wash/7 days per week = 7.14 gal/dayTow/SalvageDeckWash0.031 deck wash per week50 gallons per wash50 gal per wash/7 days per week = 7.14 gal/dayTow/SalvageDeckWash0.0125 gallons per wash1 deck wash every 2 weeks25 gal per wash/14 days = 1.79 gal/dayTow/SalvageDeckWash0.022 deck washes per week20 gallons per wash20 gal per wash/3.5 days = 5.7 gal/dayTow/SalvageDeckWash0.031 deck wash per week50 gallons per wash50 gal per wash/7 days per week = 7.14 gal/dayTow/SalvagePropulsionEngine0.151 225 hp evinrude etechoutboard1 year old engine with 243hoursraw water cooled1 gpm cooling water flowrate1 gal per min X 243 hours/year = 39.95 gal/dayTow/SalvagePropulsionEngine0.911 suzuki 225 hp outboardengineoperates 4 hours per day1 gpm cooling water flowrate1 gal per min X 4 hours/day = 240 gal/dayTow/SalvagePropulsionEngine0.562 suzuki 175hp gasoutboard engines1800 hours operated inlast 4 years1 gpm cooling water flowrate1 gal per min X 450 hours/year X 2 engines =147.95 gal/dayTow/SalvagePropulsionEngine2.881 cummin inboard 380hpdiesel engine463 hours in last 2 years20 gpm cooling water flowrate20 gal per min X 231.5 hours/year = 761.1 gal/dayTow/SalvagePropulsionEngine0.262 yamaha 150hp outboardgas engines420 hours operated in last2 years1 gpm cooling water flowrate1 gal per min X 210 hours/year X 2 engines =69.04 gal/dayG-8Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Fishing(Trawler)BilgeWater2.84used average of knownshrimp trawler bilge flowrates150 gal per min X 5 min per day = 750 gal/minFishing(Trawler)DeckWash0.34used average of knownshrimp trawler deck washflow ratesFishing(Trawler)Fish Hold1.77used average of knownshrimp trawler fish holdflow ratesFishing(Trawler)Fish HoldClean0.1315 minute hose down aftereach offloadoffloads 1 every 3 daysgarden hose flow rate is11.67 gpm11.67 gal per min X 15 min X 1 wash/ 3 day X =33.66 gal/dayFishing(Troller)DeckWash0.47125 gal per power wash1 wash per day125 gal/dayFishing(Troller)Fish Hold4.16fish hold tank is 12x10x7ft3(23.8 m3)emptied at each offloadtank is offloaded at halffullice tank holds 50% fish,35% ice, 15% airoffloads daily23.8m3X 35% X 50% = 4.16 m3/dayFishing(Troller)Fish Hold0.79600 gallon ice boxemptied at each offloadice tank holds 50% fish,35% ice, 15% airoffloads daily600 gal X 35% = 210 gal/dayFishing(Troller)Fish Hold1.58160 ft3tank (4.53 m3tank)ice tank holds 50% fish,35% ice, 15% airoffloads daily4.53 m3 X 35% = 1.58 m3/dayFishing(Troller)Fish Hold5.595.5 tons of ice per offload1 offload per daytank holds 5.5 tons of ice(5588.3kg of ice or 6141liters of ice) and 11,000 offish, discharged at eachoffload, offloads daily,5.5 tons of ice (5588.3 kg) X 1kg/L = 5588.29L/dayG-9Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Fishing(Troller)Fish HoldClean0.381 deck wash per offload15 minute deck wash withgarden hose1 offload dailygarden hose flow rate is11.67 gpm11.67 gal per min X 15 min = 100.95 gal/dayFishing(Troller)Fish HoldClean1.382 deck wash per offload15 minute deck wash withgarden hose1 offload dailygarden hose flow rate is11.67 gpm11.67 gal per min X 15 min = 100.95 gal/dayTugboatDeckWash0..381 deck wash per 2 weekswith garden hose2 hours per deck washgarden hose flow rate is11.67 gpm11.67 gal per min X 120 min X 1 wash/14 days =100 gal/dayTugboatDeckWash0.141.5 deck washes per week15 minutes per deck washgarden hose flow rate is11.67 gpm11.67 gal per min X 22.5 min X 1 wash/7 days =37.8 gal/dayTugboatDeckWash0.171.5 deck washes per weekwith garden hose15-20 minutes per deckwashgarden hose flow rate is11.67 gpm11.67 gal per min X 17.5 min X 1.5 wash/7 days =43.76 gal/dayTugboatDeckWash0.141 deck wash per 2 weekwith garden hose45 minutes per deck washgarden hose flow rate is11.67 gpm11.67 gal per min X 45 min X 1 wash/14 days =37.51 gal/dayTugboatDeckWash0.141 deck wash per weekwith garden hose15-30 minutes per deckwashgarden hose flow rate is11.67 gpm11.67 gal per min X 22.5 min X 1 wash/7 days =37.51 gal/dayTugboatDeckWash0.192 deck washes per weekwith garden hose15 minutes per deck washgarden hose flow rate is11.67 gpm11.67 gal per min X 15 min X 2 washes/7 days =50.01 gal/dayG-10Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)TugboatDeckWash0.00Uses pressure washer at 2gallons per wash1 wash every month2 gal per wash X 1 wash every month = 0.067gal/dayTugboatDeckWash0.05garden hose flow rate is11.67 gpm1 deck washes per 2 weekswith garden hose15 minutes per deck wash(use data of sister vessel)11.67 gal per min X 15 min X 1 wash/14 days=12.5 gal/dayTugboatDeckWash0.051 deck washes per 2weeks with garden hose15 minutes per deck washgarden hose flow rate is11.67 gpm11.67 gal per min X 15 min X 1 wash/14 days=12.5 gal/dayTugboatGraywater- Laundry0.22front load washer16 loads per weekfront load washer uses 25gal/load25 gal/load X 16 loads/week = 57.14 gal/dayTugboatGraywater- Laundry0.22front load washer16 loads per weekfront load washer uses 25gal/load25 gal/load X 16 loads/week = 57.14 gal/dayTugboatGraywater- Laundry0.11standard washer5 loads per weekstandard washer uses 40gal/load40 gal/load X 5 loads/week = 28.57 gal/dayTugboatGraywater- Laundry0.22front load washer4 crewfront load washer uses 25gal/load4 loads of laundry per crewper week25 gal/load X 16 loads/week = 57.14 gal/dayTugboatGraywater- Laundry0.13standard washer6 loads per weekstandard washer uses 40gal/load40 gal/load X 5 loads/week = 34.29 gal/dayTugboatGraywater- Laundry0.021 load per weekhas standard washerstandard washer uses 40gal/load40 gal/load X 1 loads/week = 6.86 gal/dayTugboatGraywater- Shower0.163 crew17.2 gal per shower0.8 showers per person perday3 crew X 17.2 gal per shower X 0.8 showers perperson per day = 41.28 gal/dayTugboatGraywater- Shower0.163 crew17.2 gal per shower0.8 showers per person perday3 crew X 17.2 gal per shower X 0.8 showers perperson per day = 41.28 gal/dayG-11Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)TugboatGraywater- Shower0.265 crew17.2 gal per shower0.8 showers per person perday5 crew X 17.2 gal per shower X 0.8 showers perperson per day = 68.8 gal/dayTugboatGraywater- Shower0.214 crew17.2 gal per shower0.8 showers per person perday4 crew X 17.2 gal per shower X 0.8 showers perperson per day = 55.04 gal/dayTugboatGraywater- Shower0.214 crew17.2 gal per shower0.8 showers per person perday4 crew X 17.2 gal per shower X 0.8 showers perperson per day = 55.04 gal/dayTugboatGraywater- Shower0.163 crew17.2 gal per shower0.8 showers per person perday3 crew X 17.2 gal per shower X 0.8 showers perperson per day = 41.28 gal/dayTugboatGraywater- Sink0.113 crew30 min of sink use per crewper week2.2 gal per min in standardsink2.2 gal per min X 3 crew X 30 min/7days = 28.29gal/dayTugboatGraywater- Sink0.113 crew30 min of sink use per crewper week2.2 gal per min in standardsink2.2 gal per min X 3 crew X 30 min/7days = 28.29gal/dayTugboatGraywater- Sink0.185 crew30 min of sink use per crewper week2.2 gal per min in standardsink2.2 gal per min X 5 crew X 30 min/7days = 47.14gal/dayTugboatGraywater- Sink0.144 crew30 min of sink use per crewper week2.2 gal per min in standardsink2.2 gal per min X 4 crew X 30 min/7days = 37.71gal/dayTugboatGraywater- Sink0.144 crew30 min of sink use per crewper week2.2 gal per min in standardsink2.2 gal per min X 4 crew X 30 min/7days = 37.71gal/dayG-12Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)TugboatGraywater- Sink0.113 crew30 min of sink use per crewper week2.2 gal per min in standardsink2.2 gal per min X 3 crew X 30 min/7days = 28.29gal/dayTugboatShaftWater0.01operates 5 days/week10 mL/min constant drip(3.8 gal/day drip)3.8 gal per day X 5 days/week = 2.71 gal/dayTugboatShaftWater0.01operates 5 days/week10 mL/min constant drip(3.8 gal/day drip)3.8 gal per day X 5 days/week = 2.71 gal/dayTugboatShaftWater0.01operates 5 days/week10 mL/min constant drip(3.8 gal/day drip)3.8 gal per day X 5 days/week = 2.71 gal/dayTugboatShaftWater0.01operates 5 days/week10 mL/min constant drip(3.8 gal/day drip)3.8 gal per day X 5 days/week = 2.71 gal/dayTugboatShaftWater0.01operates 5 days/week10 mL/min constant drip(3.8 gal/day drip)3.8 gal per day X 5 days/week = 2.71 gal/dayTugboatShaftWater0.01operates 5 days/week10 mL/min constant drip(3.8 gal/day drip)3.8 gal per day X 5 days/week = 2.71 gal/dayTugboatShaftWater0.01operates 5 days/week10 mL/min constant drip(3.8 gal/day drip)3.8 gal per day X 5 days/week = 2.71 gal/dayTugboatShaftWater0.01operates 5 days/week10 mL/min constant drip(3.8 gal/day drip)3.8 gal per day X 5 days/week = 2.71 gal/dayWater TaxiBilgeWater0.132000 gal per hour pump1 minute per pump outbilge pump operates whenengine is turned on33.33 gal per min X 1 min per pump out X 1 pumpout/day =33.2 gal/dayG-13Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Water TaxiBilgeWater0.132000 gal per hour pump1 minute per pump outbilge pump operates whenengine is turned on33.33 gal per min X 1 min per pump out X 1 pumpout/day =33.2 gal/dayWater TaxiBilgeWater0.132000 gal per hour pump1 minute per pump outbilge pump operates whenengine is turned on33.33 gal per min X 1 min per pump out X 1 pumpout/day =33.2 gal/dayWater TaxiDeckWash0.011 deck washes per monthwith garden hose10 minutes per deck washgarden hose flow rate is11.67 gpm11.67 gal per min X 10 min X 1 wash/30 days =3.89 gal/dayWater TaxiDeckWash0.011 deck washes per monthwith garden hose10 minutes per deck washgarden hose flow rate is11.67 gpm11.67 gal per min X 10 min X 1 wash/30 days =3.89 gal/dayWater TaxiDeckWash0.091 deck washes every weekwith garden hose15 minutes per deck washgarden hose flow rate is11.67 gpm11.67 gal per min X 15 min X 1 wash/7 = 25gal/dayWater TaxiDeckWash0.021 deck washes per monthwith garden hose12.5 minutes per deckwashgarden hose flow rate is11.67 gpm11.67 gal per min X 12.5 min X 1 wash/30 days=4.86 gal/dayWater TaxiGeneratorEngine9.082 21.5kw diesel generatorsheat exchange systemoperates 10 hours/day2 gal per min cooling flow2 gal per minute X 600 min per day X 2 engines =2400 gal/dayWater TaxiGraywater- Sink0.28100 passengers wash theirhands/dayfaucet flow rate is 2.2gal/min20 seconds per wash100 passengers/day X 20 second/wash X 2.2gal/min = 73.34 gal/dayG-14Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.1: Vessel-Specific FlowCalculations by Discharge TypeVessel Class(Vessel Subclass)FlowDischargeKnown InformationAssumptionsCalculationsRateType(m3/day)Water TaxiPropulsionEngine33.182 95hp diesel inboardengines20,000 hours of operationin 15 years20 gal per min cooling flow1200 gal per hour X 2 engines X 1,333 hours/year= 8765 gal/dayWater TaxiPropulsionEngine18.571 caterpillar 220hp dieselinboard4475 hours of operation in3 years20 gal per min cooling flow1200 gal per hour X 1,492 hours/year = 4905gal/dayWater TaxiPropulsionEngine90.852 John Deer 25hp inboarddiesel enginesoperates 10 hours/day20 gal per min cooling flow1200 gal per hour X 2 engines X 10 hrs/day =24,000 gal/dayWater TaxiPropulsionEngine16.591 90hp diesel inboardengine20,000 hours of operationin 15 years20 gal per min cooling flow1200 gal per hour X 1,333 hours/year = 4382gal/dayG-15Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.2: Percent of Vesselsby Vessel Class and Discharge Type Discharging in the HarborVessel ClassVesselSubclassDischargeNumber ofSampledVesselswithoutDischargeSystem orProcess(A)Number ofSampledVessels witha NoDischargeSystem(B)Number ofSampled VesselsthatDischargedOutsideU.S. Waters(C)Number ofSampledVessels thatDischargein theHarbor1(D)Total Numberof SampledVessels(E=A+B+C+D)Percent ofVesselswithDischarge(D/E)Fire BoatNADeck Wash00011100%Fire BoatNAEngine Effluent00011100%Fire BoatNAFire Main00011100%Fire BoatNAGenerator Effluent00011100%FishingGillnetterDeck Wash005050%FishingGillnetterEngine Effluent0104580%FishingGillnetterFish Hold0014580%FishingLobster BoatFish Hold00011100%FishingLonglinerBilge0111333%FishingLonglinerFish Hold00033100%FishingLonglinerFish Hold Clean00033100%FishingPurse SeinerEngine Effluent0302540%FishingPurse SeinerFish Hold00055100%FishingPurse SeinerFish Hold Clean00055100%FishingPurse SeinerGenerator Effluent1202540%FishingShrimpingBilge00551050%FishingShrimpingDeck Wash00281080%FishingShrimpingFish Hold02081080%FishingShrimpingGraywater0001010100%FishingTender VesselFish Hold00033100%FishingTender VesselFish Hold Clean0012367%FishingTrawlerDeck Wash00281080%FishingTrawlerFish Hold02081080%FishingTrawlerFish Hold Clean03241040%FishingTrollerDeck Wash2031617%G-16Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelG-17Appendix G.2: Percent of Vesselsby Vessel Class and Discharge Type Discharging in the HarborVessel ClassVesselSubclassDischargeNumber ofSampledVesselswithoutDischargeSystem orProcess(A)Number ofSampledVessels witha NoDischargeSystem(B)Number ofSampled VesselsthatDischargedOutsideU.S. Waters(C)Number ofSampledVessels thatDischargein theHarbor1(D)Total Numberof SampledVessels(E=A+B+C+D)Percent ofVesselswithDischarge(D/E)FishingTrollerFish Hold00066100%FishingTrollerFish Hold Clean4002633%ResearchNAEngine Effluent00022100%Supply BoatNADeck Wash00011100%Tour BoatNABilge1002367%Tour BoatNADeck Wash1002367%Tour BoatNAEngine Effluent00033100%Tour BoatNAFire Main00033100%Tour BoatNAGenerator Effluent1002367%Tow/SalvageNABilge1302633%Tow/SalvageNADeck Wash00066100%Tow/SalvageNAEngine Effluent0105683%TugboatNADeck Wash00099100%TugboatNAFire Main00099100%TugboatNAGraywater0306967%TugboatNAShaft Water0108989%Water TaxiNABilge0103475%Water TaxiNADeck Wash00044100%Water TaxiNAEngine Effluent00044100%Water TaxiNAGenerator Effluent3001425%Water TaxiNAGraywater3001425%(1) - The percentage of vessels discharging to the harbor weredetermined based on field observations of sampled vessels. As aconservative estimate, sampledvessel classes with no information available were assumed to discharge in the harbor.Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 1 Total Loading Rate Fishing Harbor Vessel Scenario 2 Total Loading

Rate Large Metropolitan Harbor Vessel Scenario 3 Total Loading Rate Recreational Harbor Units

Bacteria E. Coli by MF 8,860,000,000 44,300,000,000 7,380,000,000 CFU/day
Bacteria E. Coli by MPN 3,570,000,000 16,000,000,000 2,880,000,000 MPN/day
Bacteria Enterococci by MF 5,000,000,000 25,000,000,000 4,170,000,000 CFU/day
Bacteria Enterococci by MPN 1,010,000,000 891,000,000 547,000,000 MPN/day
Bacteria Fecal Coliform by MF 27,500,000,000 81,500,000,000 20,300,000,000 CFU/day
Bacteria Fecal Coliform by MPN 10,000,000,000 50,000,000,000 8,330,000,000 MPN/day
Bacteria Total Coliforms by MPN 42,900,000,000 214,000,000,000 35,800,000,000 MPN/day

Classicals Biochemical Oxygen Demand (BOD) 635 481 392 lb/day

Classicals Chemical Oxygen Demand (COD) 1,840 1,310 1,100 lb/day
Classicals Dissolved Oxygen 25.6 37.4 41.3 lb/day

Classicals Hexane Extractable Material (HEM) 11.4 19.1 17.5 lb/day

Classicals Silica Gel Treated HEM (SGT-HEM) 13.2 20.7 20.8 lb/day
Classicals Sulfide 0.0152 0.0285 0.0203 lb/day

Classicals Total Organic Carbon (TOC) 239 185 147 lb/day
Classicals Total Residual Chlorine 0.403 0.730 0.565 lb/day

Classicals Total Suspended Solids (TSS) 231 207 186 lb/day

Nutrients Ammonia As Nitrogen (NH3-N) 8.52 6.07 5.07 lb/day

Nutrients Nitrate/Nitrite (NO3/NO2- N) 0.127 0.203 0.102 lb/day

Nutrients Total Kjeldahl Nitrogen (TKN) 97.8 68.5 59.0 lb/day
Nutrients Total Phosphorus 13.8 8.91 7.74 lb/day
Metals Aluminum, Dissolved 2.01 1.70 1.64 lb/day
Metals Aluminum, Total 2.55 2.70 2.60 lb/day
Metals Antimony, Dissolved 0.0000217 0.000111 0.0000470 lb/day
Metals Antimony, Total 0.0000711 0.000348 0.000137 lb/day
Metals Arsenic, Dissolved 1 

### 0.0190 0.0285 0.0256 lb/day
Metals Arsenic, Total 1 

### 0.0279 0.0359 0.0315 lb/day
Metals Barium, Dissolved 0.0326 0.0747 0.0666 lb/day
Metals Barium, Total 0.0368 0.0895 0.0709 lb/day
Metals Cadmium, Dissolved 0.0000294 0.0000433 0.0000306 lb/day
Metals Cadmium, Total 0.000749 0.000657 0.000551 lb/day
Metals Calcium, Dissolved 653 561 528 lb/day
Metals Calcium, Total 647 566 534 lb/day
Metals Chromium, Dissolved 0.00195 0.00447 0.00424 lb/day
Metals Chromium, Total 0.00514 0.00890 0.00713 lb/day



## G-18Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 1 Total Loading Rate Fishing Harbor Vessel Vessel Scenario 2 Scenario 3

Total Loading Total Loading

Rate Large Units Rate Metropolitan Recreational Harbor Harbor
Metals Cobalt, Dissolved 0.0000745 0.000184 0.0000776 lb/day
Metals Cobalt, Total 0.000148 0.000262 0.000108 lb/day
Metals Copper, Dissolved 2.88 4.97 2.75 lb/day
Metals Copper, Total 0.158 0.179 0.165 lb/day
Metals Iron, Dissolved 0.0161 0.0465 0.0145 lb/day
Metals Iron, Total 0.376 0.819 0.600 lb/day
Metals Lead, Dissolved 0.00176 0.00338 0.00340 lb/day
Metals Lead, Total 0.0108 0.0154 0.0142 lb/day
Metals Magnesium, Dissolved 1,980 1,500 1,390 lb/day
Metals Magnesium, Total 1,910 1,470 1,360 lb/day
Metals Manganese, Dissolved 0.120 0.230 0.255 lb/day
Metals Manganese, Total 0.148 0.296 0.321 lb/day
Metals Nickel, Dissolved 0.00854 0.0140 0.0133 lb/day
Metals Nickel, Total 0.00987 0.0165 0.0145 lb/day
Metals Potassium, Dissolved 56.0 105 113 lb/day
Metals Potassium, Total 56.1 105 112 lb/day
Metals Selenium, Dissolved 1 

### 0.0215 0.0412 0.0443 lb/day
Metals Selenium, Total 1 

### 0.0244 0.0440 0.0471 lb/day
Metals Silver, Dissolved 0.0000276 0.0000221 0.0000138 lb/day
Metals Silver, Total 0.0000519 0.0000415 0.0000259 lb/day
Metals Sodium, Dissolved 1,240 2,460 2,750 lb/day
Metals Sodium,Total 1,440 2,880 3,260 lb/day
Metals Thallium, Dissolved 0.0000144 0.0000710 0.0000120 lb/day
Metals Thallium,Total 0.000000157 0.000000785 0.000000131 lb/day
Metals Vanadium, Dissolved 0.00101 0.00201 0.00227 lb/day
Metals Vanadium,Total 0.00130 0.00269 0.00254 lb/day
Metals Zinc, Dissolved 0.310 0.295 0.259 lb/day
Metals Zinc, Total 0.758 0.613 0.516 lb/day Nonylphenols Bisphenol A 0.00000886 0.0000177 0.0000213 lb/day

Nonylphenols Nonylphenol decaethoxylate (NP10EO) 0.00191 0.00338 0.00314 lb/day

Nonylphenols Nonylphenol dodecaethoxylate (NP12E O) 0.00152 0.002 70 0.00255 lb/day

Nonylphenols Nonylphenol heptadecaethoxylate (NP17EO) 0.0000955 0.000170 0.000167 lb/day

Nonylphenols Nonylphenol heptaethoxylate (NP7EO) 0.00122 0.00210 0.00177 lb/day

Nonylphenols Nonylphenol hexadecaethoxylate (NP16EO) 0.000209 0.000362 0.000357 lb/day

Nonylphenols Nonylphenol hexaethoxylate (NP6EO) 0.000866 0.00147 0.00117 lb/day



## G-19Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 1 Total Loading Rate Fishing Harbor Vessel Vessel Scenario 2 Scenario 3

Total Loading Total Loading

Rate Large Units Rate Metropolitan Recreational Harbor Harbor

Nonylphenols Nonylphenol nonaethoxylate (NP9EO) 0.00173 0.00300 0.00276 lb/day

Nonylphenols Nonylphenol octaethoxylate (NP8EO) 0.00159 0.00269 0.00239 lb/day

Nonylphenols Nonylphenol octodecaethoxylate (NP18EO) 0.0000505 0.0000818 0.0000832 lb/day

Nonylphenols Nonylphenol pendecaethoxylate (NP15EO) 0.000398 0.000684 0.000675 lb/day

Nonylphenols Nonylphenol pentaethoxylate (NP5EO) 0.000525 0.000860 0.000596 lb/day

Nonylphenols Nonylphenol tetradecaethoxylate (NP14EO) 0.000708 0.00124 0.00121 lb/day

Nonylphenols Nonylphenol tetraethoxylate (NP4EO) 0.000233 0.000390 0.000173 lb/day

Nonylphenols Nonylphenol tridecaethoxylate (NP13EO) 0.00109 0.00191 0.00184 lb/day

Nonylphenols Nonylphenol triethoxylate (NP3EO) 0.000131 0.000226 0.0000944 lb/day

Nonylphenols Nonylphenol undecaethoxylate (NP11E O) 0.00194 0.003 43 0.00321 lb/day

Nonylphenols Octylphenol decaethoxylate (OP10EO) 0.0000690 0.000254 0.0000836 lb/day

Nonylphenols Octylphenol dodecaethoxylate (OP12EO) 0.0000 413 0.000122 0. 0000383 lb/day

Nonylphenols Octylphenol heptaethoxylate (OP7EO) 0.00000302 0.0000151 0.00000251 lb/day

Nonylphenols Octylphenol nonaethoxylate (OP9EO) 0.0000418 0.0000808 0.0000311 lb/day

Nonylphenols Octylphenol octaethoxylate (OP8EO) 0.0000257 0.000129 0.0000214 lb/day

Nonylphenols Octylphenol undecaethoxylate (OP11EO) 0.0000 445 0.000151 0. 0000503 lb/day

Nonylphenols Total Nonylphenol Polyethoxylates 0.0136 0.0232 0.0215 lb/day Nonylphenols Total Nonylphenols 0.000153 0.000122 0.0000763 lb/day

VOC (2-Methyl-1-Propenyl)-
Benzene 0.00298 0.00595 0.00714 lb/day
VOC (E)-1-Propenyl-Benzene 0.00000135 0.00000675 0.00000540 lb/day
VOC (E)-2-Butenal 0.00544 0.0109 0.0131 lb/day

VOC 1,2,3,4-Tetrahydro-1- Methylnaphthalene 0.00342 0.00684 0.00821 lb/day

VOC 1,2,3,4-Tetrahydro-2- Methylnaphthalene 0.00316 0.00632 0.00758 lb/day



## G-20Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 1 Total Loading Rate Fishing Harbor Vessel Vessel Scenario 2 Scenario 3

Total Loading Total Loading

Rate Large Units Rate Metropolitan Recreational Harbor Harbor

VOC 1,2,3,4-Tetrahydro-5- Methylnaphthalene 0.0277 0.0556 0.0664 lb/day

VOC 1,2,3,4-Tetrahydro-6- Ethylnaphthalene, 0.00298 0.00597 0.00716 lb/day

VOC 1,2,3,4-Tetrahydro-6- Methylnaphthalene 0.0253 0.0512 0.0603 lb/day

VOC 1,2,3,4-Tetrahydro-6- Methylnaphthalene (01) 0.00633 0.0127 0.0152 lb/day

VOC 1,2,3,4-Tetrahydro-6- Methylnaphthalene (02) 0.00530 0.0106 0.0127 lb/day

VOC 1,2,3,4- Tetrahydronaphthalene 0.0190 0.0382 0.0456 lb/day

VOC 1,2,3,4-TetramethylBenzene 0.000643 0.00429 0.00214 lb/day

VOC 1,2,3,5-TetramethylBenzene 0.000947 0.00631 0.00316 lb/day
VOC 1,2,3-Trimethylbenzene 0.00309 0.0206 0.0103 lb/day
VOC 1,2,4,5-Tetramethylbenzene 0.00144 0.00963 0.00481 lb/day
VOC 1,2,4-Trimethylbenzene 0.00616 0.0281 0.0176 lb/day
VOC 1,3,5-Trimethylbenzene 0.00166 0.00819 0.00474 lb/day
VOC 1,3-Methylnaphthalene 0.00391 0.00781 0.00938 lb/day
VOC 1,7-Methylnaphthalene 0.0177 0.0353 0.0424 lb/day

VOC 1-Ethyl-2,3-DimethylBenzene (01) 0.00272 0.00955 0.00735 lb/day

VOC 1-Ethyl-2,3-DimethylBenzene (02) 0.000393 0.00262 0.00131 lb/day

VOC 1-Ethyl-2,4-DimethylBenzene 0.00153 0.0102 0.00510 lb/day
VOC 1-Ethyl-2-Methyl-Benzene 0.00000417 0.0000208 0.0000167 lb/day
VOC 1-Ethyl-3-Methyl-Benzene 0.00327 0.00663 0.00790 lb/day
VOC 1-Ethyl-4-Methyl-Benzene 0.00644 0.0429 0.0215 lb/day

VOC 1-Methyl-2-(1-Methylethyl)-
Benzene 0.00 0.00 0.00 lb/day

VOC 1-Methyl-2-(1-Methylethyl)- Benzene (01) 0.00000337 0.0000169 0.0000135 lb/day

VOC 1-Methyl-2-(1-Methylethyl)- Benzene (02) 0.0000118 0.0000589 0.0000471 lb/day
VOC 1-Methyl-3-Propyl-Benzene 0.00126 0.00836 0.00419 lb/day

VOC 1-Methyl-4-(1- Methylidene)-Cyclohexane 0.00 0.00 0.00 lb/day
VOC 1-methyl-Indan 0.00792 0.0201 0.0199 lb/day
VOC 1-Propenyl-Benzene 0.00000155 0.00000774 0.00000619 lb/day
VOC 2- Heptanone 0.0000601 0.000400 0.000200 lb/day

VOC 2,3-Dihydro-1,2-Dimethyl1H-Indene 0.000323 0.00216 0.00108 lb/day



## G-21Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 1 Total Loading Rate Fishing Harbor Vessel Scenario 2 Total Loading

Rate Large Metropolitan Harbor Vessel Scenario 3 Total Loading Rate Recreational Harbor Units

VOC 2,3-Dihydro-1,6-Dimethyl1H-Indene 0.00356 0.0103 0.00906 lb/day

VOC 2,3-Dihydro-1- Methylindene 0.00518 0.0104 0.0124 lb/day

VOC 2,3-Dihydro-1-methylindene (01) 0.00290 0.00579 0.00695 lb/day

VOC 2,3-Dihydro-1-methylindene (02) 0.00614 0.0123 0.0147 lb/day

VOC 2,3-Dihydro-4,7-Dimethyl1H-Indene 0.0000409 0.000204 0.0000409 lb/day

VOC 2,3-Dihydro-4-Methyl-1HIndene 0.0546 0.119 0.133 lb/day

VOC 2,3-Dihydro-4-Methyl-1HIndene (01) 0.00000480 0.0000240 0.0000192 lb/day

VOC 2,3-Dihydro-4-Methyl-1HIndene (02) 0.00000810 0.0000405 0.0000324 lb/day

VOC 2,3-Dihydro-5,6-dimethyl1H-Indene 0.00281 0.00562 0.00674 lb/day

VOC 2,3-Dihydro-5-methyl-1HIndene 0.00159 0.0106 0.00530 lb/day
VOC 2,6-Dimethylnaphthalene 0.0384 0.0769 0.0923 lb/day
VOC 2-Butanone 0.0297 0.0613 0.0706 lb/day
VOC 2-Butenal 0.00340 0.00679 0.00815 lb/day

VOC 2-Ethyl-1,3,5-TrimethylBenzene 0.00409 0.00819 0.00982 lb/day

VOC 2-Ethyl-1,4-DimethylBenzene 0.0189 0.0378 0.0454 lb/day
VOC 2-Ethyl-1-Hexanol 0.00000111 0.00000741 0.00000370 lb/day
VOC 2-Ethyltoluene 0.00541 0.0209 0.0150 lb/day
VOC 2-Hexanone 0.00262 0.00562 0.00618 lb/day
VOC 2-Methyl-2-Propenal 0.00632 0.0130 0.0150 lb/day
VOC 2-Propenyl-Benzene 0.00471 0.0314 0.0157 lb/day
VOC 3-Buten-2-one 0.00578 0.0117 0.0138 lb/day

VOC 4-Ethyl-1,2-DimethylBenzene 0.00000429 0.0000214 0.0000171 lb/day
VOC 4-Heptanone 0.0000795 0.000530 0.000265 lb/day
VOC 4-Isopropyltoluene 0.000864 0.00187 0.00210 lb/day
VOC 4-Methyl-2-Pentanone 0.000900 0.00182 0.00215 lb/day
VOC Acetaldehyde 0.0183 0.0371 0.0436 lb/day
VOC Acetone 0.133 0.271 0.316 lb/day
VOC Acrolein 0.00764 0.0155 0.0183 lb/day
VOC Benzaldehyde 0.000237 0.000474 0.000569 lb/day
VOC Benzene 0.00719 0.0208 0.0182 lb/day
VOC Benzocycloheptatriene 0.0363 0.0726 0.0871 lb/day



## G-22Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 2 Total Loading

Rate Large Metropolitan Harbor Vessel Scenario 3 Total Loading Rate Recreational Harbor Units Vessel Scenario 1 Total Loading Rate Fishing Harbor

VOC Benzofuran 0.00368 0.00736 0.00883 lb/day
VOC Bromodichloromethane 0.00000416 0.0000277 0.0000139 lb/day
VOC Butane 0.000521 0.00347 0.00174 lb/day
VOC Butyraldehyde 0.00448 0.00917 0.0107 lb/day
VOC Carbon disulfide 0.00000279 0.00000559 0.00000671 lb/day
VOC Chloroform 0.00244 0.00488 0.00585 lb/day
VOC cis-1,2-Dichloroethene 0.00000430 0.00000860 0.0000103 lb/day
VOC Cyclohexane 0.0000660 0.000439 0.000221 lb/day
VOC Dibromochloromethane 0.00000408 0.0000272 0.0000136 lb/day
VOC Dimethocxymethane 0.0156 0.0130 0.0117 lb/day
VOC Ethanol 0.0000212 0.000142 0.0000708 lb/day
VOC Ethylbenzene 0.00230 0.0114 0.00667 lb/day
VOC Indene 0.0000735 0.000368 0.0000941 lb/day
VOC Isopropylbenzene 0.00132 0.00323 0.00327 lb/day
VOC Limonene 0.00 0.00 0.00 lb/day

VOC m,p-Xylene (Sum of Isomers) 0.00728 0.0414 0.0224 lb/day
VOC Methyl acetate 0.00190 0.00382 0.00457 lb/day

VOC Methyl tertiary butyl ether (MTBE) 0.00000865 0.0000564 0.0000293 lb/day
VOC Methylcyclohexane 0.0000599 0.000398 0.000200 lb/day
VOC Methylene chloride 0.000477 0.00104 0.00115 lb/day
VOC n-Butylbenzene 0.000819 0.00164 0.00197 lb/day
VOC nitro-Methane 0.00272 0.00544 0.00653 lb/day
VOC Nonanal 0.00000183 0.00000366 0.00000440 lb/day
VOC n-Propylbenzene 0.000644 0.00313 0.00191 lb/day
VOC n-Valeraldehyde 0.00397 0.00819 0.00943 lb/day
VOC O-Xylene 0.00481 0.0267 0.0145 lb/day
VOC sec-Butylbenzene 0.00186 0.00372 0.00446 lb/day
VOC Styrene 0.00138 0.00368 0.00340 lb/day
VOC Sulfur dioxide 0.00739 0.0385 0.00964 lb/day
VOC Tetrachloroethene 0.00000345 0.00000789 0.00000776 lb/day
VOC Toluene 0.00857 0.0417 0.0254 lb/day
VOC Trichloroethene 0.00000301 0.00000602 0.00000722 lb/day
VOC Trichlorofluoromethane 0.00158 0.00316 0.00379 lb/day
VOC Tridecane 0.00325 0.00649 0.00779 lb/day
VOC Unknown VOC 0.00379 0.00907 0.00939 lb/day
VOC Unknown VOC (01) 0.00288 0.00597 0.00681 lb/day
VOC Unknown VOC (02) 0.00382 0.00777 0.00910 lb/day
VOC Unknown VOC (03) 0.00347 0.00707 0.00826 lb/day
VOC Unknown VOC (04) 0.00228 0.00483 0.00535 lb/day
VOC Unknown VOC (05) 0.00208 0.00434 0.00490 lb/day



## G-23Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 2 Total Loading

Rate Large Metropolitan Harbor Vessel Scenario 3 Total Loading Rate Recreational Harbor Units Vessel Scenario 1 Total Loading Rate Fishing Harbor

VOC Vinyl acetate 0.00202 0.00407 0.00485 lb/day
SVOC (E)-2-Tetradecene 0.000237 0.00118 0.000237 lb/day

SVOC 1,2,3,4-Tetrahydro-2,7- Dimethylnaphthalene 0.000169 0.00112 0.000562 lb/day

SVOC 1,2,3-Trichloro-(Z)-1- Propene 0.0000494 0.000330 0.000165 lb/day
SVOC 1,2,3-Trimethylbenzene (1) 0.000719 0.00479 0.00240 lb/day
SVOC 1,2,3-Trimethylbenzene (2) 0.000917 0.00611 0.00306 lb/day

SVOC 1,2,4,5-Tetramethylbenzene (1) 0.000101 0.000671 0.000336 lb/day

SVOC 1,2,4,5-Tetramethylbenzene (2) 0.0000934 0.000623 0.000311 lb/day
SVOC 1,2-Diethyl-Cyclobutane 0.00930 0.0186 0.0223 lb/day
SVOC 1,3-Dimethylnaphthalene 0.0000821 0.000411 0.0000821 lb/day

SVOC 1,3-Dimethylnaphthalene (01) 0.00527 0.0105 0.0127 lb/day

SVOC 1,4-Dimethyl-1,2,3,4- tetrahydronaphthalene 0.00780 0.0156 0.0187 lb/day
SVOC 1,4-Dimethylnaphthalene 0.00840 0.0185 0.0204 lb/day

SVOC 1,4-Dimethylnaphthalene (01) 0.00559 0.0112 0.0134 lb/day
SVOC 1,5-Dimethylnaphthalene 0.000737 0.00461 0.00203 lb/day
SVOC 1,6-Dimethylnaphthalene 0.0395 0.0792 0.0948 lb/day

SVOC 1,7,7-tri-(methyl)- bicyclo[2.2.1]heptane 0.00 0.00 0.00 lb/day
SVOC 1-Dodecanol 0.0000265 0.000177 0.0000884 lb/day
SVOC 1-Hexadecene 0.00000246 0.0000164 0.00000819 lb/day

SVOC 1-Methyl-2-Propyl-Benzene (01) 0.000758 0.00506 0.00253 lb/day

SVOC 1-Methyl-2-Propyl-Benzene (02) 0.000219 0.00146 0.000730 lb/day
SVOC 1-Methylnaphthalene 0.0358 0.0737 0.0857 lb/day
SVOC 1-Phenyl-1-Butene 0.00000119 0.00000595 0.00000476 lb/day
SVOC 2-(dodecyloxy)-Ethanol 0.0000331 0.000221 0.000110 lb/day
SVOC 2-(hexadecyloxy)-Ethanol 0.00000851 0.0000567 0.0000284 lb/day
SVOC 2-(tetradecyloxy)-Ethanol 0.0000246 0.000164 0.0000819 lb/day
SVOC 2,3-Dimethylnaphthalene 0.00688 0.0138 0.0165 lb/day
SVOC 2,4,6-Trichlorophenol 0.0000142 0.0000284 0.0000340 lb/day
SVOC 2,4-Dimethyl-Benzaldehyde 0.00000221 0.0000111 0.00000886 lb/day
SVOC 2,4-Dimethylphenol 0.00198 0.00405 0.00470 lb/day

SVOC 2,6,10,14-Tetramethyl Pentadecane 0.0124 0.0252 0.0294 lb/day

SVOC 2,6,10,14- Tetramethylhexadecae 0.00826 0.0165 0.0198 lb/day



## G-24Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 2 Total Loading

Rate Large Metropolitan Harbor Vessel Scenario 3 Total Loading Rate Recreational Harbor Units Vessel Scenario 1 Total Loading Rate Fishing Harbor

SVOC 2,6,10,14- Tetramethylhexadecae (01) 0.0002 67 0.00178 0.0 00890 lb/day
SVOC 2,6-dimethyl-Heptadecane 0. 0135 0.0270 0. 0324 lb/day
SVOC 2,7-Dimethylnaphthalene 0.00967 0.0206 0.0229 lb/day
SVOC 2-Cyclopenten1-one 0.000929 0.00186 0.00223 lb/day
SVOC 2-Ethyl-Hexanoic acid 0.0947 0.631 0.316 lb/day
SVOC 2-Hydroxy-Benzaldehyde 0.0144 0.0292 0.0343 lb/day
SVOC 2-Mercaptobenzothiazole 0.00 0.00 0.00 lb/day
SVOC 2-Methyl Tridecane 0.000141 0.000942 0.000471 lb/day
SVOC 2-Methyl-Benzaldehyde 0.00607 0.0122 0.0146 lb/day
SVOC 2-Methyl-Dodecane 0.000117 0.000585 0.0 00117 lb/day
SVOC 2-Methylnaphthalene 0.0458 0.0957 0.110 lb/day

SVOC 2- Naphthalenecarboxaldehyde 0.00102 0.00203 0.00244 lb/day
SVOC 3,4-Dimethylphenol 0.00000104 0.00000520 0.00000416 lb/day
SVOC 3,5-Dimethyl-Benzaldehyde 0.00000135 0.00000673 0.00000538 lb/day
SVOC 3,6-Dimethylundecane 0.00000205 0.0000102 0.00000171 lb/day
SVOC 3-Methyl-Benzaldehyde 0.0129 0.0258 0.0310 lb/day

SVOC 3-Methyl-Benzaldehyde (01) 0.0145 0.0290 0.0347 lb/day
SVOC 3-Methyl-butanoic acid 0.000448 0.000299 0.000280 lb/day
SVOC 3-Methyl-Phenanthrene 0.00605 0.0121 0.0145 lb/day
SVOC 3-Methylphenol 0.000677 0.00135 0.00163 lb/day
SVOC 3-Phenyl-2-Propenal 0.000457 0.000914 0.00110 lb/day
SVOC 4,4-Dimethylbiphenyl 0.00629 0.0126 0.0151 lb/day
SVOC 4-Hydroxy-2-Butanone 0.00705 0.0141 0.0169 lb/day
SVOC 4-Methyl-1H-Benzotriazole 0.00000709 0.0000142 0.0000170 lb/day

SVOC 4-METHYL-PENTANOIC ACID 0.000299 0.000199 0.000187 lb/day
SVOC 5-Butyl-Hexadecane 0.000001 58 0.00000789 0.00000131 lb/day

SVOC 5-Methyl-2-(1-methyl)- Cyclohexanol 0.00000694 0.0000462 0.0000231 lb/day
SVOC 9-Methyl-9H-Fluorene 0.00648 0.0130 0.0155 lb/day
SVOC Acenaphthylene 0.00351 0.00707 0.00841 lb/day
SVOC Acetophenone 0.0000444 0.000222 0.0000444 lb/day
SVOC Benzeneacetic Acid 0.000228 0.000152 0.0 00142 lb/day
SVOC Benzenepropanoic Acid 0.000251 0.000168 0.000157 lb/day
SVOC Benzothiazole 0.0000293 0.0000712 0.0000728 lb/day
SVOC Benzyl alcohol 0.0000464 0.000232 0.0000464 lb/day
SVOC Biphenyl 0.00353 0.00767 0.00832 lb/day
SVOC Bis(2-ethylhexyl) phthalate 0.00148 0.00362 0.00347 lb/day
SVOC Caprolactam 0.0000250 0.000167 0.0000834 lb/day



## G-25Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 2 Total Loading

Rate Large Metropolitan Harbor Vessel Scenario 3 Total Loading Rate Recreational Harbor Units Vessel Scenario 1 Total Loading Rate Fishing Harbor

SVOC Cholesterol 0.000691 0.000461 0.000432 lb/day
SVOC Cyclic octaatomic sulfur 0.0223 0.122 0.0366 lb/day
SVOC Cyclodecane 0.000242 0.00121 0.000242 lb/day
SVOC Cyclododecane 0.0000275 0.000182 0.0000903 lb/day
SVOC Cyclotetradecane 0.0000145 0.0000967 0.0000484 lb/day

SVOC Diethene Glycol Monododecyl Ether 0.0000273 0.000182 0.0000911 lb/day
SVOC Dimethyl phthalate 0.0000827 0.000165 0.000199 lb/day
SVOC Di-n-butyl phthalate 0.00182 0.00409 0.00424 lb/day
SVOC Di-n-octyl phthalate 0.0000528 0.000344 0.000174 lb/day
SVOC Disopropylene glycol 0.00000806 0.0000538 0.0000269 lb/day
SVOC Dodecane 0.00000118 0.00000589 0.000000981 lb/day
SVOC Dodecanoic acid 0.0000198 0.000132 0.0000661 lb/day
SVOC Eicosane 0.0307 0.0638 0.0742 lb/day
SVOC Ethanol, 2,2-oxybis- 0.000892 0.00595 0.00297 lb/day
SVOC Ethanol, 2-Butoxy 0.00787 0.0157 0.0189 lb/day
SVOC Fluorene 0.00374 0.00755 0.00896 lb/day
SVOC Heneicosane 0.00918 0.0217 0.0227 lb/day
SVOC Heptadecane 0.0548 0.111 0.131 lb/day

SVOC Hexaethylene Glycol Monododecyl 0.0000166 0.000111 0.0000555 lb/day

SVOC Hexaethylene Glycol Monododecyl (01) 0.00000667 0.0000444 0.0000222 lb/day

SVOC Hexaethylene Glycol Monododecyl (02) 0.00000210 0.0000140 0.00000702 lb/day
SVOC Hexagol 0.00000960 0.0000640 0.0000320 lb/day
SVOC Indane 0.000785 0.00523 0.00262 lb/day
SVOC Indole 0.00126 0.000838 0.000786 lb/day

SVOC Isopropylbenzene-4,methyl1 0.00 0.00 0.00 lb/day
SVOC m-Cresol 0.0000717 0.000358 0.0000748 lb/day
SVOC Naphthalene 0.0167 0.0395 0.0405 lb/day

SVOC N-ButylBenzenesulfonamide 0.00000275 0.0000183 0.00000915 lb/day
SVOC n-Hexadecane 0.0521 0.105 0.125 lb/day
SVOC n-Hexadecanoic acid 0.0000140 0.0000935 0.0000468 lb/day
SVOC Nonadecane 0.0421 0.0849 0.101 lb/day
SVOC Nonadecane (01) 0.0130 0.0260 0.0312 lb/day
SVOC Nonanoic Acid 0.0102 0.0205 0.0246 lb/day
SVOC n-Pentadecane 0.0389 0.0952 0.0963 lb/day
SVOC n-Tetradecane 0.0490 0.109 0.119 lb/day
SVOC o-Cresol 0.00581 0.0116 0.0139 lb/day
SVOC Octadecane 0.0118 0.0237 0.0284 lb/day



## G-26Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## G-27 Appendix G.3: Vessel Scenario Tota l Analyte-Specific Loading Rates

Analyte

Class Analyte Vessel Scenario 1 Total Loading Rate Fishing Harbor Vessel Scenario 2 Total Loading

Rate Large Metropolitan Harbor Vessel Scenario 3 Total Loading Rate Recreational Harbor Units

SVOC p-Cresol 0.0175 0.0365 0.0416 lb/day
SVOC Pentacosane 0.000243 0.00162 0.000811 lb/day

SVOC Pentaethene Glycol Monododecyl Ether 0.00000225 0.0000150 0.00000750 lb/day

SVOC Pentaethene Glycol Monododecyl Ether (01) 0.0000164 0.000110 0.0000548 lb/day

SVOC Pentaethene Glycol Monododecyl Ether (02) 0.0000324 0.000216 0.000108 lb/day
SVOC Phenanthrene 0.00319 0.00790 0.00762 lb/day
SVOC Phenol 0.0365 0.0737 0.0853 lb/day

SVOC Phthalic acid, isobutyl octyl

ester 0.0000130 0.0000260 0.0000312 lb/day
SVOC Pyrene 0.000119 0.000783 0.000381 lb/day
SVOC Sulfur 0.0101 0.0510 0.0106 lb/day

SVOC Tetraethylene glycol monododecyl ether 0.0000168 0.000112 0.0000559 lb/day
SVOC Triethyl phosphate 0.000170 0.000130 0.000129 lb/day

SVOC Triethylene glycol monododecyl ether 0.0000249 0.000166 0.0000830 lb/day
SVOC Unknown SVOC 0.00970 0.0212 0.0226 lb/day
SVOC Unknown SVOC (01) 0.00893 0.0205 0.0208 lb/day
SVOC Unknown SVOC (02) 0.00957 0.0222 0.0220 lb/day
SVOC Unknown SVOC (03) 0.000681 0.00327 0.000879 lb/day
SVOC Unknown SVOC (04) 0.000637 0.00337 0.000902 lb/day
SVOC Unknown SVOC (05) 0.000188 0.00117 0.000508 lb/day
SVOC Unknown SVOC (06) 0.000124 0.000758 0.000315 lb/day

SVOC Unknown SVOC (07) 0.00141 0.00940 0.00470 lb/day (1) EPA suspects a limited number of the samples analyzed for selenium (even fewer for arsenic) for bilgewater, packing gland effluent, propulsion engine effluent, graywater and deck washdown water may be positively influenced (increased) by interference from high concentrations of major cations in the sample matrix. Although EPA suspects that the highest concentrations of dissolved arsenic (and to a lesser extent selenium) in fish hold effluent from a shrimping vessel could be slightly elevated due to cation interference; EPA believes the fish hold concentrations reasonably represent true effluent concentrations for the discharge (see Section 3.2.4.1). EPA considered these interferences when interpreting the potential for vessel discharges to pose a risk to human health, aquatic life, or the environment and determined that such cationic interference does not influence the major findings presented in the modeling analysis.Appendix G – Supporting Information for EPA’s Screening-Level Water Quality ModelAppendix G.4: Real World Water BodyCharacterization Data for Model Input Parameter DevelopmentHarborNameRiver NameCityNameHarborSalinity(PSU)aOceanSalinity(PSU)bHarborVolume (m3)cRiver Flow(m3/day)dfxFlushingTime(days)Scenario1DilutionScenario2DilutionScenario3DilutionAuke BayMendenhall RiverJuneau,AK26.1353,090,0002,900,0000.2540.2715,8004,1704,060BiscayneBayMiami RiverMiami,FL313538,500,000352,0000.11412.51,5701,1301,100CohassetHarborGulf RiverBoston,MA30.8351,170,00089,8000.1211.59377270264Craford BayEastern and SouthernBranch ElizabethRiverNorfolk,VA19.8351,660,000384,0000.4341.87451323315DorchesterBayNeponset RiverBoston,MA31.13543,300,000467,0000.11110.32,1401,5301,500EasternChannelIndian RiverSitka,AK30.8358,500,000210,0000.124.84893641625Mobile BayTensaw, Blakeley, andMobile RiverMobile,AL16.7351,970,000,000167,000,0000.5236.16163,000117,000114,000Yaquina BayYaquina RiverNewport,OR29.3356,880,0002,060,0000.1630.5446,4404,6304,510aSources: NOAA World Oceans Database (Auke Bay, Dorchester Bay, Eastern Channel, and Mobile Bay), USGS Changing Salinity Patterns in Biscayne Bay,Florida Study (Biscayne Bay), Massachusetts Department of Environmental Protection Total Maximum Daily Loads of Bacteria for Little Harbor (CohassetHarbor), EPA EMAP Salinity Data (Craford Bay), Oregon State Temperature and Salinity of the Yaquina Bay Estuary and the Potential Range of Carcinusmaenas Study (Yaquina Bay).bOcean salinity based on average ocean salinity of 35 PSU.cHarbor volume was estimated based on surface areas and harbordepths estimated from NOAA Booklet Charts (http://ocsdata.ncd.noaa.gov/BookletChart/)accessed 7/28/2009.dRiver flows were based on average annual flows estimated in the USGS NHD Plus GIS dataset. Alaska average annual rivers flowswere calculated based onbased USGS surface-water monthly statistics for site USGS 15052500 and USGS 15087700 available in the USGS National Water Information System.G-28Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.5: Fishing Harbor Vessel Scenar ios Instan taneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios

1 and 3 Model Scenarios 2 and 4 Model Scenarios 5 and 7 Model Scenarios 6 and 8 Units

Bacteria E. Coli by MF 0.64 0.0777 0.288 0.0349 CFU/100 ml

Bacteria E. Coli by MPN 0.258 0.0313 0.116 0.0141 MPN/100 ml

Bacteria Enterococci by MF 0.361 0.0438 0.162 0.0197 CFU/100 ml

Bacteria Enterococci by MPN 0.0733 0.0089 0.0329 0.004 MPN/100 ml

Bacteria Fecal Coliform by MF 1.96 0.238 0.883 0.107 CFU/100 ml

Bacteria Fecal Coliform by MPN 0.722 0.0877 0.325 0.0394 MPN/100 ml

Bacteria Total Coliforms by MPN 3.1 0.376 1.39 0.169 MPN/100 ml

Classicals Biochemical Oxygen Demand (BOD) 0.208 0.0252 0.0935 0.0113 mg/l

Classicals Chemical Oxygen Demand (COD) 0.604 0.0733 0.271 0.0329 mg/l

Classicals Dissolved Oxygen 0.00838 0.00102 0.00377 0.000457 mg/l

Classicals Hexane Extractable Material (HEM) 0.00373 0.000452 0.00167 0.000203 mg/l

Classicals Silica Gel Treated HEM (SGT -HEM) 0.00432 0.000525 0.00194 0.000236 mg/l

Classicals Sulfide 0.00000497 6.03E-07 0.00000223 2.71E-07 mg/l

Classicals Total Organic Carbon (TOC) 0.0783 0.0095 0.0352 0.00427 mg/l

Classicals Total Residual Chlorine 0.000132 0.000016 0.0000593 0.0000072 mg/l

Classicals Total Suspended Solids (TSS) 0.0758 0.0092 0.0341 0.00413 mg/l

Nutrients Ammonia As Nitrogen (NH3-N) 0.00279 0.000339 0.00125 0.000152 mg/l

Nutrients Nitrate/Nitrite (NO3/NO2-N) 0.0000415 0.00000504 0.0000187 0.00000226 mg/l

Nutrients Total Kjeldahl Nitrogen (TKN) 0.0321 0.00389 0.0144 0.00175 mg/l

Nutrients Total Phosphorus 0.00451 0.000547 0.00203 0.000246 mg/l

Metals Aluminum, Dissolved 0.658 0.0798 0.296 0.0359 μg/l

Metals Aluminum, Total 0.835 0.101 0.375 0.0455 μg/l

Metals Antimony, Dissolved 0.00000712 8.65E-07 0.0000032 3.89E-07 μg/l

Metals Antimony, Total 0.0000233 0.00000283 0.0000105 0.00000127 μg/l

Metals Arsenic, Dissolved 1 0.00624 0.000758 0.00281 0.00034 μg/l

Metals Arsenic, Total 1 0.00913 0.00111 0.0041 0.000498 μg/l

Metals Barium, Dissolved 0.0107 0.0013 0.0048 0.000582 μg/l

Metals Barium, Total 0.0121 0.00146 0.00542 0.000658 μg/l

Metals Cadmium, Dissolved 0.00000963 0.00000117 0.00000433 5.25E-07 μg/l

Metals Cadmium, Total 0.000246 0.0000298 0.00011 0.0000134 μg/l

Metals Calcium, Dissolved 214 26 96.2 11.7 μg/l

Metals Calcium, Total 212 25.7 95.3 11.6 μg/l

Metals Chromium, Dissolved 0.000639 0.0000775 0.000287 0.0000348 μg/l

Metals Chromium, Total 0.00168 0.000204 0.000757 0.0000919 μg/l

Metals Cobalt, Dissolved 0.0000244 0.00000296 0.000011 0.00000133 μg/l

Metals Cobalt, Total 0.0000484 0.00000588 0.0000218 0.00000264 μg/l

Metals Copper, Dissolved 0.942 0.114 0.423 0.0514 μg/l

Metals Copper, Total 0.0518 0.00629 0.0233 0.00283 μg/l

Metals Iron, Dissolved 0.00528 0.000641 0.00237 0.000288 μg/l

Metals Iron, Total 0.123 0.015 0.0554 0.00672 μg/l



## G-29Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.5: Fishing Harbor Vessel Scenar ios Instan taneous Concentration in the Hypothetical Harbor

Model Model Model Model Class Analyte Scenarios 1 and 3 Scenarios 2 and 4 Scenarios 5 and 7 Scenarios Units 6 and 8

Metals Lead, Dissolved 0.000578 0.0000701 0.00026 0.0000315 μg/l

Metals Lead, Total 0.00353 0.000429 0.00159 0.000193 μg/l

Metals Magnesium, Dissolved 649 78.8 292 35.4 μg/l

Metals Magnesium, Total 625 75.9 281 34.1 μg/l

Metals Manganese, Dissolved 0.0392 0.00476 0.0176 0.00214 μg/l

Metals Manganese, Total 0.0485 0.00588 0.0218 0.00264 μg/l

Metals Nickel, Dissolved 0.0028 0.00034 0.00126 0.000153 μg/l

Metals Nickel, Total 0.00323 0.000392 0.00145 0.000176 μg/l

Metals Potassium, Dissolved 18.3 2.23 8.24 1 μg/l

Metals Potassium, Total 18.4 2.23 8.26 1 μg/l

Metals Selenium, Dissolved 1 0.00704 0.000854 0.00316 0.000384 μg/l

Metals Selenium, Total 1 0.00801 0.000972 0.0036 0.000437 μg/l

Metals Silver, Dissolved 0.00000904 0.0000011 0.00000406 4.93E-07 μg/l

Metals Silver, Total 0.000017 0.00000206 0.00000764 9.27E-07 μg/l

Metals Sodium, Dissolved 405 49.1 182 22.1 μg/l

Metals Sodium,Total 473 57.4 213 25.8 μg/l

Metals Thallium, Dissolved 0.0000 0472 5.73E-07 0.0000 0212 2.58E-07 μg/l

Metals Thallium,Total 5.14E-08 6.24E-09 2.31E- 08 2.81E-09 μg/l

Metals Vanadium, Dissolved 0.000331 0.0000402 0.000149 0.0000181 μg/l

Metals Vanadium,Total 0.000425 0.0000516 0.000191 0.0000232 μg/l

Metals Zinc, Dissolved 0.101 0.0123 0.0456 0.00553 μg/l

Metals Zinc, Total 0.248 0.0301 0.112 0.0135 μg/l
Nonylphenols Bisphenol A 0.0000029 3.52E-07 0.00000131 1.58E-07 μg/l
Nonylphenols Nonylphenol decaethoxylate (NP 10EO) 0.000627 0.0000 761 0.000282 0.0000342 μg/l

Nonylphenols Nonylphenol dodecaethoxylate (NP12EO) 0.000499 0.0000605 0.000224 0.0000272 μg/l

Nonylphenols Nonylphenol heptadecaethoxylate (NP17EO) 0.0000313 0.0000038 0.0000141 0.00000171 μg/l
Nonylphenols Nonylphe nol heptaethoxylate (NP7EO) 0.000401 0.0000486 0.00018 0.0000218 μg/l

Nonylphenols Nonylphenol hexadecaethoxylate (NP16EO) 0.0000684 0.0000083 0.0000307 0.00000373 μg/l
Nonylphenols Nonylphe nol hexaethoxylate (NP6EO) 0.000284 0.0000344 0.000127 0.0000155 μg/l
Nonylphenols Nonylphenol nonaethoxylate (NP9EO) 0.000566 0.0000687 0.000254 0.0000309 μg/l
Nonylphenols Nonylphe nol octaethoxylate (NP8EO) 0.000521 0.0000632 0.000234 0.0000284 μg/l

Nonylphenols Nonylphenol octodecaethoxylate (NP18EO) 0.0000165 0.00000201 0.00000743 9.02E-07 μg/l

Nonylphenols Nonylphenol pendecaethoxylate (NP15EO) 0.00013 0.0000158 0.0000586 0.00000711 μg/l
Nonylphenols Nonylphenol pentaethoxylate (NP5EO) 0.000172 0.0000209 0.0000773 0.00000938 μg/l

Nonylphenols Nonylphenol tetradecaethoxylate (NP14EO) 0.000232 0.0000282 0.000104 0.0000127 μg/l
Nonylphenols Nonylphenol tetr aethoxylate (NP4EO) 0.0000763 0.00000926 0.0000343 0.00000416 μg/l

Nonylphenols Nonylphenol tridecaethoxylate (NP13EO) 0.000356 0.0000432 0.00016 0.0000194 μg/l
Nonylphenols Nonylphenol trie thoxylate (NP3EO) 0.000043 0.00000522 0.0000193 0.00000235 μg/l

Nonylphenols Nonylphenol undecaethoxylate (NP11EO) 0.000637 0.0000774 0.000286 0.0000348 μg/l
Nonylphenols Octylphenol decaethoxylate (OP 10EO) 0.0000226 0.000002 75 0.0000102 0.00000123 μg/l



## G-30Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.5: Fishing Harbor Vessel Scenar ios Instan taneous Concentration in the Hypothetical Harbor

Model Model Model Model Class Analyte Scenarios 1 and 3 Scenarios 2 and 4 Scenarios 5 and 7 Scenarios Units 6 and 8

Nonylphenols Octylphenol dodecaet hoxylate (OP12EO) 0.0000135 0.00000164 0. 00000608 7.38E-07 μg/l
Nonylphenols Octylphenol heptaet hoxylate (OP7EO) 0.000000989 0.00000012 4.44E-07 5.39E-08 μg/l
Nonylphenols Octylphenol nonaethoxylate (OP9 EO) 0.0000137 0.00000166 0.00000615 7.47E-07 μg/l
Nonylphenols Octylphenol oct aethoxylate (OP8EO) 0.00000843 0.00000102 0.00000379 0.00000046 μg/l
Nonylphenols Octylphenol undecaet hoxylate (OP11EO) 0.0000146 0.00000177 0. 00000655 7.95E-07 μg/l
Nonylphenols Total Nonylphenol Polyet hoxylates 0.00445 0.000541 0.002 0.000243 μg/l
Nonylphenols Total Nonylphenols 0. 00005 0.00000607 0.0000225 0.00000273 μg/l

VOC (2-Methyl-1-Propenyl)-Benzene 0.000975 0.000118 0.000438 0.0000532 μg/l

VOC (E)-1-Propenyl-Benzene 0.000000442 5.37E-08 1.99E-07 2.41E-08 μg/l

VOC (E)-2-Butenal 0.00178 0.000217 0.000802 0.0000973 μg/l

VOC 1,2,3,4-Tetrahydro-1-Methylnaphthalene 0.00112 0.000136 0.000504 0.0000612 μg/l

VOC 1,2,3,4-Tetrahydro-2-Methylnaphthalene 0.00103 0.000126 0.000465 0.0000565 μg/l

VOC 1,2,3,4-Tetrahydro-5-Methylnaphthalene 0.00908 0.0011 0.00408 0.000495 μg/l

VOC 1,2,3,4-Tetrahydro-6-Ethylnaphthalene, 0.000977 0.000119 0.000439 0.0000533 μg/l

VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene 0.00828 0.001 0.00372 0.000451 μg/l

VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene (01) 0.00208 0.000252 0.000933 0.000113 μg/l

VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene (02) 0.00174 0.000211 0.00078 0.0000947 μg/l

VOC 1,2,3,4-Tetrahydronaphthalene 0.00623 0.000756 0.0028 0.00034 μg/l

VOC 1,2,3,4-Tetramethyl-Benzene 0.000211 0.0000256 0.0000947 0.0000115 μg/l

VOC 1,2,3,5-Tetramethyl-Benzene 0.00031 0.0000376 0.000139 0.0000169 μg/l

VOC 1,2,3-Trimethylbenzene 0.00101 0.000123 0.000455 0.0000552 μg/l

VOC 1,2,4,5-Tetramethylbenzene 0.000473 0.0000574 0.000213 0.0000258 μg/l

VOC 1,2,4-Trimethylbenzene 0.00202 0.000245 0.000907 0.00011 μg/l

VOC 1,3,5-Trimethylbenzene 0.000545 0.0000662 0.000245 0.0000297 μg/l

VOC 1,3-Methylnaphthalene 0.00128 0.000155 0.000575 0.0000698 μg/l

VOC 1,7-Methylnaphthalene 0.00579 0.000703 0.0026 0.000316 μg/l

VOC 1-Ethyl-2,3-Dimethyl-Benzene (01) 0.000892 0.000108 0.000401 0.0000487 μg/l

VOC 1-Ethyl-2,3-Dimethyl-Benzene (02) 0.000129 0.0000156 0.0000579 0.00000703 μg/l

VOC 1-Ethyl-2,4-Dimethyl-Benzene 0.000501 0.0000608 0.000225 0.0000273 μg/l

VOC 1-Ethyl-2-Methyl-Benzene 0.00000137 1.66E-07 6.14E-07 7.45E-08 μg/l

VOC 1-Ethyl-3-Methyl-Benzene 0.00107 0.00013 0.000482 0.0000585 μg/l

VOC 1-Ethyl-4-Methyl-Benzene 0.00211 0.000256 0.000949 0.000115 μg/l

VOC 1-Methyl-2-(1-Methylethyl)-Benzene 0 0 0 0 μg/l

VOC 1-Methyl-2-(1-Methy lethyl)-Benzene (01) 0.00000111 1.34E-07 4.97E-07 6.03E-08 μg/l

VOC 1-Methyl-2-(1-Methy lethyl)-Benzene (02) 0.00000386 4.69E-07 0.00000174 2.11E-07 μg/l

VOC 1-Methyl-3-Propyl-Benzene 0.000411 0.0000499 0.000185 0.0000224 μg/l

VOC 1-Methyl-4-(1-Methylidene)- Cyclohexane 0 0 0 0 μg/l

VOC 1-methyl-Indan 0.0026 0.000315 0.00117 0.000142 μg/l

VOC 1-Propenyl-Benzene 0.000000507 6.16E-08 2.28E-07 2.77E-08 μg/l

VOC 2- Heptanone 0.0000197 0.00000239 0.00000885 0.00000107 μg/l

VOC 2,3-Dihydro-1,2-Dimethyl-1H-Indene 0.000106 0.0000129 0.0000476 0.00000578 μg/l



## G-31Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.5: Fishing Harbor Vessel Scenar ios Instan taneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios

1 and 3 Model Scenarios 5 and 7 Model Scenarios 6 and 8 Units Model Scenarios 2 and 4

VOC 2,3-Dihydro-1,6-Dimethyl-1H-Indene 0.00117 0.000141 0.000524 0.0000636 μg/l

VOC 2,3-Dihydro-1-Methylindene 0.0017 0.000206 0.000763 0.0000926 μg/l

VOC 2,3-Dihydro-1-methylindene (01) 0.000949 0.000115 0.000426 0.0000518 μg/l

VOC 2,3-Dihydro-1-methylindene (02) 0.00201 0.000244 0.000904 0.00011 μg/l

VOC 2,3-Dihydro-4,7-Dimethyl-1H-Indene 0.0000134 0.00000163 0.00000602 7.31E-07 μg/l

VOC 2,3-Dihydro-4-Methyl-1H-Indene 0.0179 0.00217 0.00804 0.000975 μg/l

VOC 2,3-Dihydro-4-Methyl-1H-Indene (01) 0.00000157 1.91E-07 7.07E-07 8.58E-08 μg/l

VOC 2,3-Dihydro-4-Methyl-1H-Indene (02) 0.00000265 3.22E-07 0.00000119 1.45E-07 μg/l

VOC 2,3-Dihydro-5,6-dimethyl-1H-Indene 0.00092 0.000112 0.000413 0.0000502 μg/l

VOC 2,3-Dihydro-5-methyl-1H-Indene 0.000521 0.0000632 0.000234 0.0000284 μg/l

VOC 2,6-Dimethylnaphthalene 0.0126 0.00153 0.00566 0.000687 μg/l

VOC 2-Butanone 0.00974 0.00118 0.00438 0.000531 μg/l

VOC 2-Butenal 0.00111 0.000135 0.0005 0.0000607 μg/l

VOC 2-Ethyl-1,3,5-Trimethyl-Benzene 0.00134 0.000163 0.000603 0.0000732 μg/l

VOC 2-Ethyl-1,4-Dimethyl-Benzene 0.0062 0.000753 0.00279 0.000338 μg/l

VOC 2-Ethyl-1-Hexanol 0.000000364 4.42E-08 1.64E-07 1.99E-08 μg/l

VOC 2-Ethyltoluene 0.00177 0.000215 0.000797 0.0000968 μg/l

VOC 2-Hexanone 0.000857 0.000104 0.000385 0.0000468 μg/l

VOC 2-Methyl-2-Propenal 0.00207 0.000251 0.000931 0.000113 μg/l

VOC 2-Propenyl-Benzene 0.00154 0.000187 0.000693 0.0000842 μg/l

VOC 3-Buten-2-one 0.00189 0.00023 0.000851 0.000103 μg/l

VOC 4-Ethyl-1,2-Dimethyl-Benzene 0.0000014 0.00000017 6.31E-07 7.66E-08 μg/l

VOC 4-Heptanone 0.000026 0.00000316 0.0000117 0.00000142 μg/l

VOC 4-Isopropyltoluene 0.000283 0.0000344 0.000127 0.0000155 μg/l

VOC 4-Methyl-2-Pentanone 0.000295 0.0000358 0.000132 0.0000161 μg/l

VOC Acetaldehyde 0.00599 0.000727 0.00269 0.000327 μg/l

VOC Acetone 0.0435 0.00528 0.0195 0.00237 μg/l

VOC Acrolein 0.0025 0.000304 0.00113 0.000137 μg/l

VOC Benzaldehyde 0.0000777 0.00000943 0.0000349 0.00000424 μg/l

VOC Benzene 0.00236 0.000286 0.00106 0.000129 μg/l

VOC Benzocycloheptatriene 0.0119 0.00144 0.00534 0.000648 μg/l

VOC Benzofuran 0.00121 0.000146 0.000542 0.0000658 μg/l

VOC Bromodichloromethane 0.00000136 1.65E-07 6.12E-07 7.43E-08 μg/l

VOC Butane 0.000171 0.0000207 0.0000768 0.00000932 μg/l

VOC Butyraldehyde 0.00147 0.000178 0.00066 0.0000801 μg/l

VOC Carbon disulfide 0.000000916 1.11E-07 4.12E-07 0.00000005 μg/l

VOC Chloroform 0.000799 0.000097 0.000359 0.0000436 μg/l

VOC cis-1,2-Dichloroethene 0.00000141 1.71E-07 6.33E-07 7.68E-08 μg/l

VOC Cyclohexane 0.0000216 0.00000263 0.00000973 0.00000118 μg/l

VOC Dibromochloromethane 0.00000134 1.62E-07 6.01E-07 7.29E-08 μg/l

VOC Dimethocxymethane 0.00512 0.000621 0.0023 0.000279 μg/l

VOC Ethanol 0.00000696 8.45E-07 0.00000313 0.00000038 μg/l

VOC Ethylbenzene 0.000754 0.0000916 0.000339 0.0000411 μg/l



## G-32Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.5: Fishing Harbor Vessel Scenar ios Instan taneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios

1 and 3 Model Scenarios 2 and 4 Model Scenarios 5 and 7 Model Scenarios 6 and 8 Units

VOC Indene 0.0000241 0.00000292 0.0000108 0.00000131 μg/l

VOC Isopropylbenzene 0.000431 0.0000523 0.000194 0.0000235 μg/l

VOC Limonene 0 0 0 0 μg/l

VOC m,p-Xylene (Sum of Isomers) 0.00239 0.00029 0.00107 0.00013 μg/l

VOC Methyl acetate 0.000624 0.0000757 0.00028 0.000034 μg/l

VOC Methyl tertiary butyl ether (MTBE) 0.00000283 3.44E-07 0.00000127 1.55E-07 μg/l

VOC Methylcyclohexane 0.0000196 0.00000238 0.00000883 0.00000107 μg/l

VOC Methylene chloride 0.000156 0.000019 0.0000703 0.00000853 μg/l

VOC n-Butylbenzene 0.000268 0.0000326 0.000121 0.0000146 μg/l

VOC nitro-Methane 0.000891 0.000108 0.000401 0.0000486 μg/l

VOC Nonanal 0.0000006 7.28E-08 0.00000027 3.27E-08 μg/l

VOC n-Propylbenzene 0.000211 0.0000256 0.0000949 0.0000115 μg/l

VOC n-Valeraldehyde 0.0013 0.000158 0.000585 0.000071 μg/l

VOC O-Xylene 0.00158 0.000191 0.000708 0.000086 μg/l

VOC sec-Butylbenzene 0.000609 0.0000739 0.000274 0.0000332 μg/l

VOC Styrene 0.000451 0.0000548 0.000203 0.0000246 μg/l

VOC Sulfur dioxide 0.00242 0.000294 0.00109 0.000132 μg/l

VOC Tetrachloroethene 0.00000113 1.37E-07 5.08E-07 6.17E-08 μg/l

VOC Toluene 0.00281 0.000341 0.00126 0.000153 μg/l

VOC Trichloroethene 0.000000986 0.00000012 4.43E-07 5.38E-08 μg/l

VOC Trichlorofluoromethane 0.000518 0.0000628 0.000233 0.0000282 μg/l

VOC Tridecane 0.00106 0. 000129 0.000478 0.000058 μg/l

VOC Unknown VOC 0.00124 0.000151 0.000558 0.0000677 μg/l

VOC Unknown VOC (01) 0.000943 0.000114 0.000424 0.0000515 μg/l

VOC Unknown VOC (02) 0.00125 0.000152 0.000562 0.0000682 μg/l

VOC Unknown VOC (03) 0.00114 0.000138 0.000511 0.000062 μg/l

VOC Unknown VOC (04) 0.000748 0.0000908 0.000336 0.0000408 μg/l

VOC Unknown VOC (05) 0.000681 0.0000827 0.000306 0.0000372 μg/l

VOC Vinyl acetate 0.000663 0.0000805 0.000298 0.0000362 μg/l

SVOC (E)-2-Tetradecene 0.0000776 0.00000942 0.0000349 0.00000423 μg/l

SVOC 1,2,3,4-Tetrahydro-2,7- Dimethylnaphthalene 0.0000553 0.00000671 0.0000248 0.00000302 μg/l

SVOC 1,2,3-Trichloro-(Z)-1-Propene 0.0000162 0.00000197 0.00000728 8.84E-07 μg/l

SVOC 1,2,3-Trimethylbenzene (1) 0.000236 0.0000286 0.000106 0.0000129 μg/l

SVOC 1,2,3-Trimethylbenzene (2) 0.0003 0.0000365 0.000135 0.0000164 μg/l

SVOC 1,2,4,5-Tetramethylbenzene (1) 0.000033 0.00000401 0.0000148 0.0000018 μg/l

SVOC 1,2,4,5-Tetramethylbenzene (2) 0.0000306 0.00000372 0.0000138 0.00000167 μg/l

SVOC 1,2-Diethyl-Cyclobutane 0.00305 0.00037 0.00137 0.000166 μg/l

SVOC 1,3-Dimethylnaphthalene 0.0000269 0.00000327 0.0000121 0.00000147 μg/l

SVOC 1,3-Dimethylnaphthalene (01) 0.00173 0.00021 0.000777 0.0000943 μg/l

SVOC 1,4-Dimethyl-1,2,3,4- tetrahydronaphthalene 0.00256 0.00031 0.00115 0.000139 μg/l

SVOC 1,4-Dimethylnaphthalene 0.00275 0.000334 0.00124 0.00015 μg/l

SVOC 1,4-Dimethylnaphthalene (01) 0.00183 0.000222 0.000823 0.0000999 μg/l



## G-33Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.5: Fishing Harbor Vessel Scenar ios Instan taneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios

1 and 3 Model Scenarios 2 and 4 Model Scenarios 5 and 7 Model Scenarios 6 and 8 Units

SVOC 1,5-Dimethylnaphthalene 0.000241 0.0000293 0.000109 0.0000132 μg/l

SVOC 1,6-Dimethylnaphthalene 0.013 0.00157 0.00582 0.000707 μg/l

SVOC 1,7,7-tri-(methyl)-bicyclo[2.2.1]heptane 0 0 0 0 μg/l

SVOC 1-Dodecanol 0.00000869 0.00000105 0.0000039 4.74E-07 μg/l

SVOC 1-Hexadecene 0.000000805 9.77E-08 3.62E- 07 4.39E-08 μg/l

SVOC 1-Methyl-2-Propyl-Benzene (01) 0.000249 0.0000302 0.000112 0.0000136 μg/l

SVOC 1-Methyl-2-Propyl-Benzene (02) 0.0000718 0.00000871 0.0000323 0.00000392 μg/l

SVOC 1-Methylnaphthalene 0.0117 0.00142 0.00527 0.00064 μg/l

SVOC 1-Phenyl-1-Butene 0.00000039 4.73E-08 1.75E-07 2.13E-08 μg/l

SVOC 2-(dodecyloxy)-Ethanol 0.0000109 0.00000132 0.00000488 5.92E-07 μg/l

SVOC 2-(hexadecyloxy)-Ethanol 0.00000279 3.38E-07 0.00000125 1.52E-07 μg/l

SVOC 2-(tetradecyloxy)-Ethanol 0.00000805 9.77E-07 0.00000362 4.39E-07 μg/l

SVOC 2,3-Dimethylnaphthalene 0.00225 0.000274 0.00101 0.000123 μg/l

SVOC 2,4,6-Trichlorophenol 0.00000465 5.64E-07 0.00000209 2.53E-07 μg/l

SVOC 2,4-Dimethyl-Benzaldehyde 0.000000726 8.81E-08 3.26E-07 3.96E-08 μg/l

SVOC 2,4-Dimethylphenol 0.000648 0.0000787 0.000291 0.0000354 μg/l

SVOC 2,6,10,14-Tetramethyl Pentad ecane 0.00405 0.000492 0.00182 0.000221 μg/l

SVOC 2,6,10,14-Tetramethylhexad ecae 0.00271 0.000329 0.00122 0.000148 μg/l

SVOC 2,6,10,14-Tetramethylhexadecae ( 01) 0.0000875 0.0000106 0.0000393 0.00000477 μg/l

SVOC 2,6-dimethyl-Heptadecane 0.00442 0.000536 0.00199 0.000241 μg/l

SVOC 2,7-Dimethylnaphthalene 0.00317 0.000385 0.00142 0.000173 μg/l

SVOC 2-Cyclopenten1-one 0.000304 0.0000369 0.000137 0.0000166 μg/l

SVOC 2-Ethyl-Hexanoic acid 0.031 0.00376 0.0139 0.00169 μg/l

SVOC 2-Hydroxy-Benzaldehyde 0.00471 0.000572 0.00212 0.000257 μg/l

SVOC 2-Mercaptobenzothiazole 0 0 0 0 μg/l

SVOC 2-Methyl Tridecane 0.0000463 0.00000562 0.0000208 0.00000253 μg/l

SVOC 2-Methyl-Benzaldehyde 0.00199 0.000241 0.000894 0.000109 μg/l

SVOC 2-Methyl-Dodecane 0.0000384 0.00000466 0.0000172 0.00000209 μg/l

SVOC 2-Methylnaphthalene 0.015 0.00182 0.00675 0.000819 μg/l

SVOC 2-Naphthalenecarboxaldehyde 0.000333 0.0000404 0.00015 0.0000182 μg/l

SVOC 3,4-Dimethylphenol 0.000000341 4.14E-08 1.53E-07 1.86E-08 μg/l

SVOC 3,5-Dimethyl-Benzaldehyde 0.000000441 5.35E-08 1.98E-07 2.4E-08 μg/l

SVOC 3,6-Dimethylundecane 0.000000671 8.15E-08 3.02E- 07 3.66E-08 μg/l

SVOC 3-Methyl-Benzaldehyde 0.00423 0.000513 0.0019 0.000231 μg/l

SVOC 3-Methyl-Benzaldehyde (01) 0.00474 0.000576 0.00213 0.000259 μg/l

SVOC 3-Methyl-butanoic acid 0.000147 0.0000178 0.000066 0.00000801 μg/l

SVOC 3-Methyl-Phenanthrene 0.00198 0.000241 0.000892 0.000108 μg/l

SVOC 3-Methylphenol 0.000222 0.0000269 0.0000997 0.0000121 μg/l

SVOC 3-Phenyl-2-Propenal 0.00015 0.0000182 0.0000673 0.00000817 μg/l

SVOC 4,4-Dimethylbiphenyl 0.00206 0.00025 0.000927 0.000113 μg/l

SVOC 4-Hydroxy-2-Butanone 0.00231 0.00028 0.00104 0.000126 μg/l

SVOC 4-Methyl-1H-Benzotriazole 0.00000232 2.82E-07 0.00000104 1.27E-07 μg/l

SVOC 4-METHYL-PENTANOIC ACID 0.0000978 0.0000119 0.000044 0.00000534 μg/l



## G-34Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.5: Fishing Harbor Vessel Scenar ios Instan taneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios

1 and 3 Model Scenarios 2 and 4 Model Scenarios 5 and 7 Model Scenarios 6 and 8 Units

SVOC 5-Butyl-Hexadecane 0.000000517 6.27E-08 2.32E-07 2.82E-08 μg/l

SVOC 5-Methyl-2-(1-methyl)-Cyclohexanol 0.00000227 2.76E-07 0.00000102 1.24E-07 μg/l

SVOC 9-Methyl-9H-Fluorene 0.00212 0.000258 0.000954 0.000116 μg/l

SVOC Acenaphthylene 0.00115 0.00014 0.000517 0.0000628 μg/l

SVOC Acetophenone 0.0000146 0.00000177 0.00000655 7.94E-07 μg/l

SVOC Benzeneacetic Acid 0.0000 747 0.00000906 0.0000336 0.00000407 μg/l

SVOC Benzenepropanoic Acid 0.0000824 0.00001 0.000037 0.00000449 μg/l

SVOC Benzothiazole 0.0000096 0.00000116 0.00000431 5.24E-07 μg/l

SVOC Benzyl alcohol 0.0000152 0.00000185 0.00000684 0.00000083 μg/l

SVOC Biphenyl 0.00116 0.00014 0.000519 0.000063 μg/l

SVOC Bis(2-ethylhexyl) phthalate 0.000485 0.0000588 0.000218 0.0000264 μg/l

SVOC Caprolactam 0.0000082 9.95E-07 0.00000368 4.47E-07 μg/l

SVOC Cholesterol 0.000227 0.0000275 0.000102 0.0000124 μg/l

SVOC Cyclic octaatomic sulfur 0.0073 0.000886 0.00328 0.000398 μg/l

SVOC Cyclodecane 0.0000795 0. 00000964 0.0000357 0.00000433 μg/l

SVOC Cyclododecane 0.00000901 0. 00000109 0.00000405 4.91E-07 μg/l

SVOC Cyclotetradecane 0.0000047 5 5.77E-07 0.00000214 2.59E-07 μg/l

SVOC Diethene Glycol Monododecyl Ether 0.00000896 0.00000109 0.00000403 4.89E-07 μg/l

SVOC Dimethyl phthalate 0.0000271 0.00000329 0.0000122 0.00000148 μg/l

SVOC Di-n-butyl phthalate 0.000596 0.0000723 0.000268 0.0000325 μg/l

SVOC Di-n-octyl phthalate 0.0000173 0.0000021 0.00000778 9.44E-07 μg/l

SVOC Disopropylene glycol 0.0000 0264 3.21E-07 0.00000119 1.44E-07 μg/l

SVOC Dodecane 0.000000386 4. 68E-08 1.73E-07 2.1E-08 μg/l

SVOC Dodecanoic acid 0.0000065 7.89E-07 0.00000292 3.55E-07 μg/l

SVOC Eicosane 0.0101 0.00122 0.00453 0.000549 μg/l

SVOC Ethanol, 2,2-oxybis- 0.000292 0.0000355 0.000131 0.0000159 μg/l

SVOC Ethanol, 2-Butoxy 0.00258 0.000313 0.00116 0.000141 μg/l

SVOC Fluorene 0.00123 0.000149 0.000552 0.0000669 μg/l

SVOC Heneicosane 0.00301 0.000365 0.00135 0.000164 μg/l

SVOC Heptadecane 0.0179 0. 00218 0.00806 0.000979 μg/l

SVOC Hexaethylene Glycol Monododecyl 0.00000545 6.62E-07 0.00000245 2.97E-07 μg/l

SVOC Hexaethylene Glycol Monododecyl (01) 0.00000218 2.65E-07 9.82E-07 1.19E-07 μg/l

SVOC Hexaethylene Glycol Monododecyl (02) 0.00000069 8.37E-08 0.00000031 3.76E-08 μg/l

SVOC Hexagol 0.00000315 3.82E-07 0.00000141 1.72E-07 μg/l

SVOC Indane 0.000257 0.0000312 0.000116 0.000014 μg/l

SVOC Indole 0.000412 0.00005 0.000185 0.0000225 μg/l

SVOC Isopropylbenzene-4,methyl-1 0 0 0 0 μg/l

SVOC m-Cresol 0.0000235 0.00000285 0.0000106 0.00000128 μg/l

SVOC Naphthalene 0.00547 0.000663 0.00246 0.000298 μg/l

SVOC N-Butyl-Benzenesulfonamide 0.0000009 1.09E-07 4.04E-07 4.91E-08 μg/l

SVOC n-Hexadecane 0.0171 0.00207 0.00768 0.000932 μg/l

SVOC n-Hexadecanoic acid 0.0000046 5.58E-07 0.00000207 2.51E-07 μg/l

SVOC Nonadecane 0.0138 0.00168 0.0062 0.000753 μg/l



## G-35Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## G-36 Appendix G.5: Fishing Harbor Vessel Scenar ios Instantaneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios

1 and 3 Model Scenarios 2 and 4 Model Scenarios 5 and 7 Model Scenarios 6 and 8 Units

SVOC Nonadecane (01) 0.0042 5 0.000516 0.00191 0.000232 μg/l

SVOC Nonanoic Acid 0.00335 0.000407 0.00151 0.000183 μg/l

SVOC n-Pentadecane 0.0127 0.00155 0.00573 0.000695 μg/l

SVOC n-Tetradecane 0.0161 0.00195 0.00722 0.000876 μg/l

SVOC o-Cresol 0.0019 0.000231 0.000856 0.000104 μg/l

SVOC Octadecane 0.00388 0.000471 0.00174 0.000211 μg/l

SVOC p-Cresol 0.00573 0.000696 0.00258 0.000313 μg/l

SVOC Pentacosane 0.0000797 0.00000968 0.0000358 0.00000435 μg/l

SVOC Pentaethene Glycol Monododecyl Ether 0.000000738 8.95E-08 3.31E-07 4.02E-08 μg/l

SVOC Pentaethene Glycol Monododecyl Ether (01) 0.00000539 6.54E-07 0.00000242 2.94E-07 μg/l

SVOC Pentaethene Glycol Monododecyl Ether (02) 0.0000106 0.00000129 0.00000477 5.79E-07 μg/l

SVOC Phenanthrene 0.00105 0.000127 0.00047 0.0000571 μg/l

SVOC Phenol 0.0119 0.00145 0.00537 0.000652 μg/l

SVOC Phthalic acid, isobutyl octyl este r 0.00000426 5.17E-07 0.00000192 2.32E-07 μg/l

SVOC Pyrene 0.0000391 0.00000474 0.0000176 0.00000213 μg/l

SVOC Sulfur 0.00332 0.000403 0.00149 0.000181 μg/l

SVOC Tetraethylene glycol monododecyl ether 0.00000549 6.67E-07 0.00000247 0.0000003 μg/l

SVOC Triethyl phosphate 0.0000557 0.00000676 0.000025 0.00000304 μg/l

SVOC Triethylene glycol monododecyl ether 0.00000816 0.00000099 0.00000367 4.45E-07 μg/l

SVOC Unknown SVOC 0.00318 0.000386 0.00143 0.000173 μg/l

SVOC Unknown SVOC (01) 0.00293 0.000355 0.00132 0.00016 μg/l

SVOC Unknown SVOC (02) 0.00313 0.00038 0.00141 0.000171 μg/l

SVOC Unknown SVOC (03) 0.000223 0.0000271 0.0001 0.0000122 μg/l

SVOC Unknown SVOC (04) 0.000209 0.0000253 0.0000938 0.0000114 μg/l

SVOC Unknown SVOC (05) 0.0000616 0.00000747 0.0000277 0.00000336 μg/l

SVOC Unknown SVOC (06) 0.0000407 0.00000494 0.0000183 0.00000222 μg/l

SVOC Unknown SVOC (07) 0.000462 0.0000561 0.000208 0.0000252 μg/l 

### (1) EPA suspects a limited number of the samples an alyzed for selenium (even fewer for arsenic) for bilgewater, packing gland effluent, propulsion engine effluent, graywater and deck washdown water may be positively influenced (increased) by interference from high concentrations of major cations in the sample matrix. Although EPA suspects that the highest concentrations of dissolved arsenic (and to a lesser extent selenium) in fish hold effluent from a shrimping vessel could be slightly elevated due to cation interference; EPA believes the fish hold concentrations reasonably represent true effluent concentrations for the discharge (see Section 3.2.4. 1). EPA considered these interferen ces when interpreting the potential for vessel discharges to pose a risk to human health, aquatic life, or the environment and determined that such cationic interference does not influence the ma jor findings presented in the modeling analysis.Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.6: Metropolitan Harbor Vesse l Scenarios Instantaneou s Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 9 and 11 Model Scenarios 10 an 12 Model Scenarios 13 and 15 Model Scenarios 14 and 16 Units

Bacteria E. Coli by MF 3.2 0.388 1.44 0.175 CFU/100 ml

Bacteria E. Coli by MPN 1.15 0.14 0.518 0.0629 MPN/100 ml

Bacteria Enterococci by MF 1.81 0.219 0.812 0.0985 CFU/100 ml

Bacteria Enterococci by MPN 0.0643 0.00781 0.0289 0.00351 MPN/100 ml

Bacteria Fecal Coliform by MF 5.89 0.715 2.65 0.321 CFU/100 ml

Bacteria Fecal Coliform by MPN 3.61 0.438 1.62 0.197 MPN/100 ml

Bacteria Total Coliforms by MPN 15.5 1.88 6.96 0.845 MPN/100 ml

Classicals Biochemical Oxygen Demand (BOD) 0.158 0.0191 0.0709 0.0086 mg/l

Classicals Chemical Oxygen Demand (COD) 0.43 0.0522 0.193 0.0235 mg/l

Classicals Dissolved Oxygen 0.0122 0.00149 0.0055 0.000668 mg/l

Classicals Hexane Extractable Material (HEM) 0.00626 0.00076 0.00281 0.000341 mg/l

Classicals Silica Gel Treated HEM (S GT-HEM) 0.0068 0.000825 0.00305 0.000371 mg/l

Classicals Sulfide 0.00000934 0.00000113 0.0000042 0.00000051 mg/l

Classicals Total Organic Carbon (TOC) 0.0606 0.00735 0.0272 0.0033 mg/l

Classicals Total Residual Chlorine 0.000239 0.000029 0.000108 0.0000131 mg/l

Classicals Total Suspended Solids (TSS) 0.0678 0.00823 0.0305 0.0037 mg/l

Nutrients Ammonia As Nitrogen (NH3-N) 0.00199 0.000241 0.000894 0.000109 mg/l

Nutrients Nitrate/Nitrite (NO3/NO2-N) 0.0000664 0.00000806 0.0000298 0.00000362 mg/l

Nutrients Total Kjeldahl Nitrogen (TKN) 0.0224 0.00272 0.0101 0.00122 mg/l

Nutrients Total Phosphorus 0.00292 0.000354 0.00131 0.000159 mg/l

Metals Aluminum, Dissolved 0.556 0.0675 0.25 0.0304 μg/l

Metals Aluminum, Total 0.885 0.107 0.398 0.0483 μg/l

Metals Antimony, Dissolved 0.0000364 0.00000442 0.0000163 0.00000198 μg/l

Metals Antimony, Total 0.000114 0.0000138 0.0000512 0.00000622 μg/l

Metals Arsenic, Dissolved 1 0.00933 0.00113 0.00419 0.000509 μg/l

Metals Arsenic, Total 1 0.0118 0.00143 0.00528 0.000641 μg/l

Metals Barium, Dissolved 0.0245 0.00297 0.011 0.00133 μg/l

Metals Barium, Total 0.0293 0.00356 0.0132 0.0016 μg/l

Metals Cadmium, Dissolved 0.0000142 0.00000172 0.00000637 7.74E-07 μg/l

Metals Cadmium, Total 0.000215 0.0000261 0.0000968 0.0000118 μg/l

Metals Calcium, Dissolved 184 22.3 82.7 10 μg/l

Metals Calcium, Total 185 22.5 83.3 10.1 μg/l

Metals Chromium, Dissolved 0.00147 0.000178 0.000659 0.00008 μg/l

Metals Chromium, Total 0.00292 0.000354 0.00131 0.000159 μg/l

Metals Cobalt, Dissolved 0.0000603 0.00000732 0.0000271 0.00000329 μg/l

Metals Cobalt, Total 0.0000859 0.0000104 0.0000386 0.00000468 μg/l

Metals Copper, Dissolved 1.63 0.198 0.733 0.0889 μg/l

Metals Copper, Total 0.0586 0.00712 0.0264 0.0032 μg/l

Metals Iron, Dissolved 0.0152 0.00185 0.00685 0.000831 μg/l

Metals Iron, Total 0.268 0.0326 0.121 0.0146 μg/l



## G-37Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.6: Metropolitan Harbor Vesse l Scenarios Instantaneou s Concentration in the Hypothetical Harbor

Model Model Model Model Class Analyte Scenarios 9 and 11 Scenarios 10 an 12 Scenarios 13 and 15 Scenarios Units 14 and 16

Metals Lead, Dissolved 0.00111 0.000134 0.000497 0.0000604 μg/l

Metals Lead, Total 0.00506 0.000614 0.00227 0.000276 μg/l

Metals Magnesium, Dissolved 493 59.8 221 26.9 μg/l

Metals Magnesium, Total 483 58.6 217 26.3 μg/l

Metals Manganese, Dissolved 0.0755 0.00916 0.0339 0.00412 μg/l

Metals Manganese, Total 0.097 0.0118 0.0436 0.00529 μg/l

Metals Nickel, Dissolved 0.00459 0.000557 0.00206 0.00025 μg/l

Metals Nickel, Total 0.00541 0.000657 0.00243 0.000295 μg/l

Metals Potassium, Dissolved 34.5 4.19 15.5 1.88 μg/l

Metals Potassium, Total 34.3 4.17 15.4 1.87 μg/l

Metals Selenium, Dissolved 1 0.0135 0.00164 0.00606 0.000736 μg/l

Metals Selenium, Total 1 0.0144 0.00175 0.00648 0.000787 μg/l

Metals Silver, Dissolved 0.00000723 8.78E-07 0.00000325 3.94E-07 μg/l

Metals Silver, Total 0.0000136 0.00000165 0.00000611 7.42E-07 μg/l

Metals Sodium, Dissolved 806 97.8 362 44 μg/l

Metals Sodium,Total 944 115 424 51.5 μg/l

Metals Thallium, Dissolved 0. 0000233 0.00000282 0.0000105 0.00000127 μg/l

Metals Thallium,Total 2.57E-07 3.12E-08 1.16E- 07 1.4E-08 μg/l

Metals Vanadium, Dissolved 0.000658 0.0000799 0.000296 0.0000359 μg/l

Metals Vanadium,Total 0.000882 0.000107 0.000397 0.0000481 μg/l

Metals Zinc, Dissolved 0.0968 0.0117 0.0435 0.00528 μg/l

Metals Zinc, Total 0.201 0.0244 0.0903 0.011 μg/l
Nonylphenols Bisphenol A 0.000005 81 7.05E-07 0.00000261 3.17E-07 μg/l
Nonylphenols Nonylphenol decaethoxylate (NP 10EO) 0.00111 0.0001 34 0.000497 0.0000604 μg/l
Nonylphenols Nonylphenol dode caethoxylate (NP12EO) 0.0008 85 0.000107 0.000398 0.0000483 μg/l

Nonylphenols Nonylphenol heptadecaethoxylate (NP17EO) 0.0000557 0.00000675 0.000025 0.00000304 μg/l
Nonylphenols Nonylphe nol heptaethoxylate (NP7EO) 0.000689 0.0000837 0.00031 0.0000376 μg/l

Nonylphenols Nonylphenol hexadecaethoxylate (NP16EO) 0.000119 0.0000144 0.0000534 0.00000648 μg/l
Nonylphenols Nonylphe nol hexaethoxylate (NP6EO) 0.00048 0.0000583 0.000216 0.0000262 μg/l
Nonylphenols Nonylphenol nonaethoxylate (NP9EO) 0.000983 0.000119 0.000442 0.0000536 μg/l
Nonylphenols Nonylphe nol octaethoxylate (NP8EO) 0.000882 0.000107 0.000397 0.0000481 μg/l

Nonylphenols Nonylphenol octodecaethoxylate (NP18EO) 0.0000268 0.00000325 0.000012 0.00000146 μg/l

Nonylphenols Nonylphenol pendecaethoxylate (NP15EO) 0.000224 0.0000272 0.000101 0.0000122 μg/l
Nonylphenols Nonylphe nol pentaethoxylate (NP5EO) 0.000282 0.0000342 0.000127 0.0000154 μg/l

Nonylphenols Nonylphenol tetradecaethoxylate (NP14EO) 0.000406 0.0000493 0.000182 0.0000221 μg/l
Nonylphenols Nonylphenol tetr aethoxylate (NP4EO) 0.000128 0.0000155 0.0000575 0.00000698 μg/l
Nonylphenols Nonylphenol tr idecaethoxylate (NP13EO) 0. 000627 0.0000762 0.000282 0.0000342 μg/l
Nonylphenols Nonylphenol trie thoxylate (NP3EO) 0.000074 0.00000898 0.0000332 0.00000403 μg/l
Nonylphenols Nonylphenol unde caethoxylate (NP11EO) 0.0011 2 0.000136 0.000505 0.0000613 μg/l
Nonylphenols Octylphenol decaethoxylate (OP 10EO) 0.0000832 0.0000 101 0.0000374 0.00000454 μg/l
Nonylphenols Octylphenol dodecaet hoxylate (OP12EO) 0.00004 0.00000485 0.000018 0.00000218 μg/l



## G-38Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.6: Metropolitan Harbor Vesse l Scenarios Instantaneou s Concentration in the Hypothetical Harbor

Model Model Model Model Class Analyte Scenarios 9 and 11 Scenarios 10 an 12 Scenarios 13 and 15 Scenarios Units 14 and 16

Nonylphenols Octylphenol hept aethoxylate (OP7EO) 0.00000494 0.0000006 0.00000222 0.00000027 μg/l
Nonylphenols Octylphenol non aethoxylate (OP9EO) 0.0000265 0.00000321 0.0000119 0.00000144 μg/l
Nonylphenols Octylphenol oc taethoxylate (OP8EO) 0.0000422 0.00000512 0.000019 0.0000023 μg/l
Nonylphenols Octylphenol undecaethoxylate (OP 11EO) 0.0000494 0.0000 06 0.0000222 0.0000027 μg/l
Nonylphenols Total Nonylphenol Polyet hoxylates 0.0076 0.000923 0.00342 0.000415 μg/l
Nonylphenols Total Nonylphenols 0. 00004 0.00000486 0.000018 0.00000218 μg/l

VOC (2-Methyl-1-Propenyl)-Benzene 0.00195 0.000237 0.000877 0.000106 μg/l

VOC (E)-1-Propenyl-Benzene 0.00000221 2.68E-07 9.94E-07 1.21E-07 μg/l

VOC (E)-2-Butenal 0.00357 0.000433 0.0016 0.000195 μg/l

VOC 1,2,3,4-Tetrahydro-1-Methylnaphthalene 0.00224 0.000272 0.00101 0.000122 μg/l

VOC 1,2,3,4-Tetrahydro-2-Methylnaphthalene 0.00207 0.000251 0.00093 0.000113 μg/l

VOC 1,2,3,4-Tetrahydro-5-Methylnaphthalene 0.0182 0.00221 0.00819 0.000994 μg/l

VOC 1,2,3,4-Tetrahydro-6-Ethylnaphthalene, 0.00195 0.000237 0.000879 0.000107 μg/l

VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene 0.0168 0.00204 0.00754 0.000915 μg/l

VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene (01) 0.00415 0.000504 0.00187 0.000226 μg/l

VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene (02) 0.00347 0.000422 0.00156 0.000189 μg/l

VOC 1,2,3,4-Tetrahydronaphthalene 0.0125 0.00152 0.00562 0.000682 μg/l

VOC 1,2,3,4-Tetramethyl-Benzene 0.0014 0.000171 0.000631 0.0000766 μg/l

VOC 1,2,3,5-Tetramethyl-Benzene 0.00207 0.000251 0.000929 0.000113 μg/l

VOC 1,2,3-Trimethylbenzene 0.00675 0.000819 0.00303 0.000368 μg/l

VOC 1,2,4,5-Tetramethylbenzene 0.00315 0.000383 0.00142 0.000172 μg/l

VOC 1,2,4-Trimethylbenzene 0.0092 0.00112 0.00413 0.000502 μg/l

VOC 1,3,5-Trimethylbenzene 0.00268 0.000326 0.00121 0.000146 μg/l

VOC 1,3-Methylnaphthalene 0.00256 0.000311 0.00115 0.00014 μg/l

VOC 1,7-Methylnaphthalene 0.0116 0.00141 0.00521 0.000632 μg/l

VOC 1-Ethyl-2,3-Dimethyl-Benzene (01) 0.00313 0.00038 0.00141 0.000171 μg/l

VOC 1-Ethyl-2,3-Dimethyl-Benzene (02) 0.000859 0.000104 0.000386 0.0000469 μg/l

VOC 1-Ethyl-2,4-Dimethyl-Benzene 0.00334 0.000405 0.0015 0.000182 μg/l

VOC 1-Ethyl-2-Methyl-Benzene 0.00000683 8.29E-07 0.00000307 3.72E-07 μg/l

VOC 1-Ethyl-3-Methyl-Benzene 0.00217 0.000264 0.000977 0.000119 μg/l

VOC 1-Ethyl-4-Methyl-Benzene 0.0141 0.00171 0.00632 0.000768 μg/l

VOC 1-Methyl-2-(1-Methylethyl)-Benzene 0 0 0 0 μg/l

VOC 1-Methyl-2-(1-Methylethyl)-Benzene (01) 0.00000553 6.71E-07 0.00000248 3.01E-07 μg/l

VOC 1-Methyl-2-(1-Methylethyl)-Benzene (02) 0.0000193 0.00000234 0.00000868 0.00000105 μg/l

VOC 1-Methyl-3-Propyl-Benzene 0.00274 0.000333 0.00123 0.000149 μg/l

VOC 1-Methyl-4-(1-Methylidene)-Cyclohexane 0 0 0 0 μg/l

VOC 1-methyl-Indan 0.00657 0.000798 0.00296 0.000359 μg/l

VOC 1-Propenyl-Benzene 0.00000254 3.08E-07 0.00000114 1.38E-07 μg/l

VOC 2- Heptanone 0.000131 0.0000159 0.000059 0.00000716 μg/l

VOC 2,3-Dihydro-1,2-Dimethyl-1H-Indene 0.000706 0.0000858 0.000318 0.0000385 μg/l

VOC 2,3-Dihydro-1,6-Dimethyl-1H-Indene 0.00338 0.00041 0.00152 0.000184 μg/l

VOC 2,3-Dihydro-1-Methylindene 0.0034 0.000413 0.00153 0.000186 μg/l



## G-39Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.6: Metropolitan Harbor Vesse l Scenarios Instantaneou s Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 9 and 11 Model Scenarios 13 and 15 Model Scenarios 14 and 16 Units Model Scenarios 10 an 12

VOC 2,3-Dihydro-1-methylindene (01) 0.0019 0.00023 0.000853 0.000104 μg/l

VOC 2,3-Dihydro-1-methylindene (02) 0.00402 0.000489 0.00181 0.00022 μg/l

VOC 2,3-Dihydro-4,7-Dimethyl-1H-Indene 0.000067 0.00000813 0.0000301 0.00000365 μg/l

VOC 2,3-Dihydro-4-Methyl-1H-Indene 0.0391 0.00475 0.0176 0.00213 μg/l

VOC 2,3-Dihydro-4-Methyl-1H-Indene (01) 0.00000787 9.55E-07 0.00000354 4.29E-07 μg/l

VOC 2,3-Dihydro-4-Methyl-1H-Indene (02) 0.0000133 0.00000161 0.00000596 7.24E-07 μg/l

VOC 2,3-Dihydro-5,6-dimethyl-1H-Indene 0.00184 0.000223 0.000827 0.0001 μg/l

VOC 2,3-Dihydro-5-methyl-1H-Indene 0.00347 0.000422 0.00156 0.000189 μg/l

VOC 2,6-Dimethylnaphthalene 0.0252 0.00306 0.0113 0.00137 μg/l

VOC 2-Butanone 0.0201 0.00244 0.00903 0.0011 μg/l

VOC 2-Butenal 0.00223 0.00027 0.001 0.000121 μg/l

VOC 2-Ethyl-1,3,5-Trimethyl-Benzene 0.00268 0.000326 0.00121 0.000146 μg/l

VOC 2-Ethyl-1,4-Dimethyl-Benzene 0.0124 0.00151 0.00557 0.000677 μg/l

VOC 2-Ethyl-1-Hexanol 0.00000243 2.95E-07 0.00000109 1.32E-07 μg/l

VOC 2-Ethyltoluene 0.00686 0.000832 0.00308 0.000374 μg/l

VOC 2-Hexanone 0.00184 0.000223 0.000827 0.0001 μg/l

VOC 2-Methyl-2-Propenal 0.00427 0.000519 0.00192 0.000233 μg/l

VOC 2-Propenyl-Benzene 0.0103 0.00125 0.00462 0.000561 μg/l

VOC 3-Buten-2-one 0.00384 0.000466 0.00173 0.00021 μg/l

VOC 4-Ethyl-1,2-Dimethyl-Benzene 0.00000702 8.52E-07 0.00000316 3.83E-07 μg/l

VOC 4-Heptanone 0.000174 0.0000211 0.000078 0.00000947 μg/l

VOC 4-Isopropyltoluene 0.000612 0.0000743 0.000275 0.0000334 μg/l

VOC 4-Methyl-2-Pentanone 0.000597 0.0000725 0.000268 0.0000326 μg/l

VOC Acetaldehyde 0.0122 0.00148 0.00546 0.000663 μg/l

VOC Acetone 0.0889 0.0108 0.04 0.00485 μg/l

VOC Acrolein 0.00508 0.000617 0.00228 0.000277 μg/l

VOC Benzaldehyde 0.000155 0.0000189 0.0000698 0.00000847 μg/l

VOC Benzene 0.00681 0.000826 0.00306 0.000371 μg/l

VOC Benzocycloheptatrien e 0.0238 0.00289 0.0107 0.0013 μg/l

VOC Benzofuran 0.00241 0.000293 0.00108 0.000132 μg/l

VOC Bromodichloromethane 0.00000908 0.0000011 0.00000408 4.96E-07 μg/l

VOC Butane 0.00114 0.000138 0.000512 0.0000621 μg/l

VOC Butyraldehyde 0.003 0.000365 0.00135 0.000164 μg/l

VOC Carbon disulfide 0.00000183 2.22E-07 8.23E-07 9.99E-08 μg/l

VOC Chloroform 0.0016 0.000194 0.000718 0.0000872 μg/l

VOC cis-1,2-Dichloroethene 0.00000282 3.42E-07 0.00000127 1.54E-07 μg/l

VOC Cyclohexane 0.000144 0.0000175 0.0000646 0.00000785 μg/l

VOC Dibromochloromethane 0.00000891 0.00000108 0.00000401 4.86E-07 μg/l

VOC Dimethocxymethane 0.00427 0.000518 0.00192 0.000233 μg/l

VOC Ethanol 0.0000464 0.00000563 0.0000209 0.00000253 μg/l

VOC Ethylbenzene 0.00375 0.000455 0.00168 0.000204 μg/l

VOC Indene 0.00012 0.0000146 0.0000541 0.00000657 μg/l

VOC Isopropylbenzene 0.00106 0.000129 0.000476 0.0000578 μg/l



## G-40Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.6: Metropolitan Harbor Vesse l Scenarios Instantaneou s Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 9 and 11 Model Scenarios 10 an 12 Model Scenarios 13 and 15 Model Scenarios 14 and 16 Units

VOC Limonene 0 0 0 0 μg/l

VOC m,p-Xylene (Sum of Isomers) 0.0136 0.00165 0.0061 0.00074 μg/l

VOC Methyl acetate 0.00125 0.000152 0.000562 0.0000682 μg/l

VOC Methyl tertiary butyl ether (MTBE) 0.0000185 0.00000224 0.00000831 0.00000101 μg/l

VOC Methylcyclohexane 0.000131 0.0000158 0.0000587 0.00000712 μg/l

VOC Methylene chloride 0.00034 0.0000413 0.000153 0.0000185 μg/l

VOC n-Butylbenzene 0.000537 0.0000651 0.000241 0.0000293 μg/l

VOC nitro-Methane 0.00178 0.000216 0.000801 0.0000972 μg/l

VOC Nonanal 0.0000012 1.46E-07 5.39E-07 6.55E-08 μg/l

VOC n-Propylbenzene 0.00103 0.000125 0.000461 0.000056 μg/l

VOC n-Valeraldehyde 0.00268 0.000326 0.00121 0.000146 μg/l

VOC O-Xylene 0.00876 0.00106 0.00394 0.000478 μg/l

VOC sec-Butylbenzene 0.00122 0.000148 0.000548 0.0000666 μg/l

VOC Styrene 0.00121 0.000146 0.000542 0.0000658 μg/l

VOC Sulfur dioxide 0.0126 0.00153 0.00568 0.000689 μg/l

VOC Tetrachloroethene 0.00000259 3.14E-07 0.00000116 1.41E-07 μg/l

VOC Toluene 0.0137 0.00166 0.00614 0.000746 μg/l

VOC Trichloroethene 0.00000197 2.39E-07 8.86E-07 1.08E-07 μg/l

VOC Trichlorofluoromethane 0.00104 0.000126 0.000465 0.0000565 μg/l

VOC Tridecane 0.00213 0. 000258 0.000956 0.000116 μg/l

VOC Unknown VOC 0.00297 0.000361 0.00134 0.000162 μg/l

VOC Unknown VOC (01) 0.00196 0.000237 0.000879 0.000107 μg/l

VOC Unknown VOC (02) 0.00255 0.000309 0.00114 0.000139 μg/l

VOC Unknown VOC (03) 0.00232 0.000281 0.00104 0.000126 μg/l

VOC Unknown VOC (04) 0.00158 0.000192 0.000711 0.0000863 μg/l

VOC Unknown VOC (05) 0.00142 0.000173 0.000639 0.0000775 μg/l

VOC Vinyl acetate 0.00133 0.000162 0.000599 0.0000727 μg/l

SVOC (E)-2-Tetradecene 0.0003 88 0.0000471 0.000174 0.0000212 μg/l

SVOC 1,2,3,4-Tetrahydro-2,7- Dimethylnaphthalene 0.000368 0.0000447 0.000166 0.0000201 μg/l

SVOC 1,2,3-Trichloro-(Z)-1-Propene 0.000108 0.0000131 0.0000485 0.00000589 μg/l

SVOC 1,2,3-Trimethylbenzene (1) 0.00157 0.00019 0.000705 0.0000856 μg/l

SVOC 1,2,3-Trimethylbenzene (2) 0.002 0.000243 0.0009 0.000109 μg/l

SVOC 1,2,4,5-Tetramethylbenzene (1) 0.00022 0.0000267 0.0000989 0.000012 μg/l

SVOC 1,2,4,5-Tetramethylbenzene (2) 0.000204 0.0000248 0.0000917 0.0000111 μg/l

SVOC 1,2-Diethyl-Cyclobutane 0.0061 0.00074 0.00274 0.000333 μg/l

SVOC 1,3-Dimethylnaphthalene 0.000135 0.0000163 0.0000605 0.00000734 μg/l

SVOC 1,3-Dimethylnaphthalene (01) 0.00346 0.000419 0.00155 0.000189 μg/l

SVOC 1,4-Dimethyl-1,2,3,4- tetrahydronaphthalene 0.00511 0.00062 0.0023 0.000279 μg/l

SVOC 1,4-Dimethylnaphthalene 0.00606 0.000735 0.00272 0.00033 μg/l

SVOC 1,4-Dimethylnaphthalene (01) 0.00366 0.000445 0.00165 0.0002 μg/l

SVOC 1,5-Dimethylnaphthalene 0.00151 0.000183 0.000678 0.0000823 μg/l

SVOC 1,6-Dimethylnaphthalene 0.026 0.00315 0.0117 0.00142 μg/l



## G-41Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.6: Metropolitan Harbor Vesse l Scenarios Instantaneou s Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 9 and 11 Model Scenarios 10 an 12 Model Scenarios 13 and 15 Model Scenarios 14 and 16 Units

SVOC 1,7,7-tri-(methyl)-bicyclo[2.2.1]heptane 0 0 0 0 μg/l

SVOC 1-Dodecanol 0.0000579 0.00000703 0.000026 0.00000316 μg/l

SVOC 1-Hexadecene 0.00000537 6. 52E-07 0.00000241 2.93E-07 μg/l

SVOC 1-Methyl-2-Propyl-Benzene (01) 0.00166 0.000201 0.000745 0.0000904 μg/l

SVOC 1-Methyl-2-Propyl-Benzene (02) 0.000478 0.0000581 0.000215 0.0000261 μg/l

SVOC 1-Methylnaphthalene 0.0242 0.00293 0.0109 0.00132 μg/l

SVOC 1-Phenyl-1-Butene 0.00000195 2.37E-07 8.77E-07 1.06E-07 μg/l

SVOC 2-(dodecyloxy)-Ethanol 0.0000724 0.00000879 0.0000325 0.00000395 μg/l

SVOC 2-(hexadecyloxy)-Ethanol 0.0000186 0.00000226 0.00000835 0.00000101 μg/l

SVOC 2-(tetradecyloxy)-Ethanol 0.0000536 0.00000651 0.0000241 0.00000293 μg/l

SVOC 2,3-Dimethylnaphthalene 0.00451 0.000547 0.00203 0.000246 μg/l

SVOC 2,4,6-Trichlorophenol 0.00000929 0.00000113 0.00000418 5.07E-07 μg/l

SVOC 2,4-Dimethyl-Benzaldehyde 0.00000363 0.00000044 0.00000163 1.98E-07 μg/l

SVOC 2,4-Dimethylphenol 0.00133 0.000161 0.000597 0.0000724 μg/l

SVOC 2,6,10,14-Tetramethyl Pentad ecane 0.00827 0.001 0.00372 0.000451 μg/l

SVOC 2,6,10,14-Tetramethylhexad ecae 0.00542 0.000657 0.00243 0.000295 μg/l

SVOC 2,6,10,14-Tetramethylhexadecae ( 01) 0.000583 0.0000708 0.000262 0.0000318 μg/l

SVOC 2,6-dimethyl-Heptadecane 0.00884 0.00107 0.00397 0.000482 μg/l

SVOC 2,7-Dimethylnaphthalene 0.00675 0.000819 0.00303 0.000368 μg/l

SVOC 2-Cyclopenten1-one 0.000609 0.0000739 0.000274 0.0000332 μg/l

SVOC 2-Ethyl-Hexanoic acid 0.207 0.0251 0.0929 0.0113 μg/l

SVOC 2-Hydroxy-Benzaldehyde 0.00957 0.00116 0.0043 0.000522 μg/l

SVOC 2-Mercaptobenzothiazole 0 0 0 0 μg/l

SVOC 2-Methyl Tridecane 0.000309 0.0000375 0.000139 0.0000168 μg/l

SVOC 2-Methyl-Benzaldehyde 0.00399 0.000484 0.00179 0.000218 μg/l

SVOC 2-Methyl-Dodecane 0.0001 92 0.0000233 0.0000862 0.0000105 μg/l

SVOC 2-Methylnaphthalene 0.0313 0.0038 0.0141 0.00171 μg/l

SVOC 2-Naphthalenecarboxaldehyde 0.000666 0.0000808 0.000299 0.0000363 μg/l

SVOC 3,4-Dimethylphenol 0.0000017 2.07E-07 7.66E-07 9.29E-08 μg/l

SVOC 3,5-Dimethyl-Benzaldehyde 0.0000022 2.68E-07 9.91E-07 0.00000012 μg/l

SVOC 3,6-Dimethylundecane 0.000003 36 4.07E-07 0.000001 51 1.83E-07 μg/l

SVOC 3-Methyl-Benzaldehyde 0.00846 0.00103 0.0038 0.000462 μg/l

SVOC 3-Methyl-Benzaldehyde (01) 0.00949 0.00115 0.00426 0.000518 μg/l

SVOC 3-Methyl-butanoic acid 0.0000978 0.0000119 0.000044 0.00000534 μg/l

SVOC 3-Methyl-Phenanthrene 0.00397 0.000482 0.00178 0.000216 μg/l

SVOC 3-Methylphenol 0.000444 0.0000539 0.000199 0.0000242 μg/l

SVOC 3-Phenyl-2-Propenal 0.0003 0.0000364 0.000135 0.0000163 μg/l

SVOC 4,4-Dimethylbiphenyl 0.00412 0.000501 0.00185 0.000225 μg/l

SVOC 4-Hydroxy-2-Butanone 0.00462 0.00056 0.00208 0.000252 μg/l

SVOC 4-Methyl-1H-Benzotriazole 0.00000465 5.64E-07 0.00000209 2.54E-07 μg/l

SVOC 4-METHYL-PENTANOIC ACID 0.0000652 0.00000792 0.0000293 0.00000356 μg/l

SVOC 5-Butyl-Hexadecane 0.00000258 3.14E-07 0.00000116 1.41E-07 μg/l

SVOC 5-Methyl-2-(1-methyl)-Cyclohexanol 0.0000152 0.00000184 0.00000681 8.27E-07 μg/l



## G-42Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.6: Metropolitan Harbor Vesse l Scenarios Instantaneou s Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 9 and 11 Model Scenarios 10 an 12 Model Scenarios 13 and 15 Model Scenarios 14 and 16 Units

SVOC 9-Methyl-9H-Fluorene 0.00424 0.000515 0.00191 0.000231 μg/l

SVOC Acenaphthylene 0.00232 0.000281 0.00104 0.000126 μg/l

SVOC Acetophenone 0.0000728 0.00000884 0.0000327 0.00000397 μg/l

SVOC Benzeneacetic Acid 0.0000 498 0.00000604 0.0000224 0.00000272 μg/l

SVOC Benzenepropanoic Acid 0.0000549 0.00000667 0.0000247 0.000003 μg/l

SVOC Benzothiazole 0.0000233 0.00000283 0.0000105 0.00000127 μg/l

SVOC Benzyl alcohol 0.0000761 0.00000923 0.0000342 0.00000415 μg/l

SVOC Biphenyl 0.00251 0.000305 0.00113 0.000137 μg/l

SVOC Bis(2-ethylhexyl) phthalate 0.00119 0.000144 0.000534 0.0000648 μg/l

SVOC Caprolactam 0.0000546 0.00000663 0.0000246 0.00000298 μg/l

SVOC Cholesterol 0.000151 0.0000183 0.0000679 0.00000824 μg/l

SVOC Cyclic octaatomic sulfur 0.0399 0.00484 0.0179 0.00217 μg/l

SVOC Cyclodecane 0.000397 0.0000482 0.000179 0.0000217 μg/l

SVOC Cyclododecane 0.0000598 0. 00000725 0.0000269 0.00000326 μg/l

SVOC Cyclotetradecane 0.0000 317 0.00000385 0.0000142 0.00000173 μg/l

SVOC Diethene Glycol Monododecyl Ether 0.0000597 0.00000725 0.0000268 0.00000326 μg/l

SVOC Dimethyl phthalate 0.0000542 0.00000658 0.0000244 0.00000296 μg/l

SVOC Di-n-butyl phthalate 0.00134 0.000163 0.000603 0.0000732 μg/l

SVOC Di-n-octyl phthalate 0.000113 0.0000137 0.0000506 0.00000614 μg/l

SVOC Disopropylene glycol 0.0000 176 0.00000214 0.00000792 9.61E-07 μg/l

SVOC Dodecane 0.00000193 2.34E -07 8.67E-07 1.05E-07 μg/l

SVOC Dodecanoic acid 0.0000433 0.00000526 0.0000195 0.00000236 μg/l

SVOC Eicosane 0.0209 0.00254 0.0094 0.00114 μg/l

SVOC Ethanol, 2,2-oxybis- 0.00195 0.000236 0.000876 0.000106 μg/l

SVOC Ethanol, 2-Butoxy 0.00516 0.000626 0.00232 0.000282 μg/l

SVOC Fluorene 0.00247 0.0003 0.00111 0.000135 μg/l

SVOC Heneicosane 0.00712 0.000864 0.0032 0.000388 μg/l

SVOC Heptadecane 0.0362 0.0044 0.0163 0.00198 μg/l

SVOC Hexaethylene Glycol Monododecy l 0.0000363 0.00000441 0.0000163 0.00000198 μg/l

SVOC Hexaethylene Glycol Monododecyl ( 01) 0.0000146 0.00000177 0.00000655 7.94E-07 μg/l

SVOC Hexaethylene Glycol Monododecyl ( 02) 0.0000046 5.58E-07 0.00000207 2.51E-07 μg/l

SVOC Hexagol 0.000021 0.00000255 0.00000943 0.00000114 μg/l

SVOC Indane 0.00171 0.000208 0.00077 0.0000935 μg/l

SVOC Indole 0.000275 0.0000333 0.000123 0.000015 μg/l

SVOC Isopropylbenzene-4,methyl-1 0 0 0 0 μg/l

SVOC m-Cresol 0.000117 0.0000143 0.0000528 0.00000641 μg/l

SVOC Naphthalene 0.0129 0.00157 0.00581 0.000706 μg/l

SVOC N-Butyl-Benzenesulfonamide 0.000006 7.28E-07 0.0000027 3.27E-07 μg/l

SVOC n-Hexadecane 0. 0346 0.0042 0.0155 0.00189 μg/l

SVOC n-Hexadecanoic acid 0.0000307 0.00000372 0.0000138 0.00000167 μg/l

SVOC Nonadecane 0.0278 0.00338 0.0125 0.00152 μg/l

SVOC Nonadecane (01) 0.0085 1 0.00103 0.00382 0.000464 μg/l

SVOC Nonanoic Acid 0.00671 0.000814 0.00301 0.000366 μg/l



## G-43Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## G-44 Appendix G.6: Metropolitan Harbor Vesse l Scenarios Instantaneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 9 and 11 Model Scenarios 10 an 12 Model Scenarios 13 and 15 Model Scenarios 14 and 16 Units

SVOC n-Pentadecane 0. 0312 0.00379 0.014 0.0017 μg/l

SVOC n-Tetradecane 0.0357 0.00433 0.016 0.00195 μg/l

SVOC o-Cresol 0.00381 0.000462 0.00171 0.000208 μg/l

SVOC Octadecane 0.00775 0.000941 0.00348 0.000423 μg/l

SVOC p-Cresol 0.012 0.00145 0.00537 0.000652 μg/l

SVOC Pentacosane 0.000532 0.0000645 0.000239 0.000029 μg/l

SVOC Pentaethene Glycol Monododecyl Ethe r 0.00000492 5.97E-07 0.00000221 2.68E-07 μg/l

SVOC Pentaethene Glycol Monododecyl Ether (01) 0.0000359 0.00000436 0.0000161 0.00000196 μg/l

SVOC Pentaethene Glycol Monododecyl Ether (02) 0.0000707 0.00000859 0.0000318 0.00000386 μg/l

SVOC Phenanthrene 0.00259 0.000314 0.00116 0.000141 μg/l

SVOC Phenol 0.0241 0.00293 0.0109 0.00132 μg/l

SVOC Phthalic acid, isobutyl octyl ester 0.00000852 0.00000103 0.00000383 4.65E-07 μg/l

SVOC Pyrene 0.000257 0.0000311 0.000115 0.000014 μg/l

SVOC Sulfur 0.0167 0.00203 0.00751 0.000911 μg/l

SVOC Tetraethylene glycol monododecyl ether 0.0000366 0.00000444 0.0000165 0.000002 μg/l

SVOC Triethyl phosphate 0.0000427 0.00000518 0.0000192 0.00000233 μg/l

SVOC Triethylene glycol monododecyl ether 0.0000544 0.0000066 0.0000244 0.00000297 μg/l

SVOC Unknown SVOC 0.00695 0.000844 0.00312 0.000379 μg/l

SVOC Unknown SVOC (01) 0.00672 0.000816 0.00302 0.000367 μg/l

SVOC Unknown SVOC (02) 0.00727 0.000883 0.00327 0.000397 μg/l

SVOC Unknown SVOC (03) 0.00107 0.00013 0.000481 0.0000584 μg/l

SVOC Unknown SVOC (04) 0.00111 0.000134 0.000497 0.0000603 μg/l

SVOC Unknown SVOC (05) 0.000383 0.0000465 0.000172 0.0000209 μg/l

SVOC Unknown SVOC (06) 0.000248 0.0000301 0.000112 0.0000135 μg/l

SVOC Unknown SVOC (07) 0.00308 0.000374 0.00138 0.000168 μg/l 

### (1) EPA suspects a limited number of the samples an alyzed for selenium (even fewer for arsenic) for bilgewater, packing gland effluent, propulsion engine effluent, graywater and deck washdown water may be positively influenced (increased) by interference from high concentrations of major cations in the sample matrix. Although EPA suspects that the highest concentrations of dissolved arsenic (and to a lesser extent selenium) in fish hold effluent from a shrimping vessel could be slightly elevated due to cation interference; EPA believes the fish hold concentrations reasonably represent true effluent concentrations for the discharge (see Section 3.2.4. 1). EPA considered these interferen ces when interpreting the potential for vessel discharges to pose a risk to human health, aquatic life, or the environment and determined that such cationic interference does not influence the ma jor findings presented in the modeling analysis.Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.7: Recreational Ha rbor Vessel Scen arios Instantaneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 17 and 19 Model Scenarios 18 and 20 Model Scenarios 21 and 23 Model Scenarios 22 and 24 Units

Bacteria E. Coli by MF 0.533 0.0647 0.24 0.0291 CFU/100 ml

Bacteria E. Coli by MPN 0.208 0.0252 0.0935 0.0113 MPN/100 ml

Bacteria Enterococci by MF 0.301 0.0365 0.135 0.0164 CFU/100 ml

Bacteria Enterococci by MPN 0.0395 0.0048 0.0178 0.00216 MPN/100 ml

Bacteria Fecal Coliform by MF 1.47 0.178 0.659 0.0799 CFU/100 ml

Bacteria Fecal Coliform by MPN 0.602 0.0731 0.271 0.0328 MPN/100 ml

Bacteria Total Coliforms by MPN 2.59 0.314 1.16 0.141 MPN/100 ml

Classicals Biochemical Oxygen Demand (BOD) 0.129 0.0156 0.0578 0.00701 mg/l

Classicals Chemical Oxygen Demand (COD) 0.361 0.0438 0.162 0.0197 mg/l

Classicals Dissolved Oxygen 0.0135 0.00164 0.00609 0.000739 mg/l

Classicals Hexane Extractable Material (HEM) 0.00573 0.000695 0.00257 0.000312 mg/l

Classicals Silica Gel Treated HEM (SGT -HEM) 0.00682 0.000828 0.00307 0.000372 mg/l

Classicals Sulfide 6.67E-06 8.09E-07 0.000003 3.64E-07 mg/l

Classicals Total Organic Carbon (TOC) 0.0483 0.00586 0.0217 0.00263 mg/l

Classicals Total Residual Chlorine 0.000185 0.0000225 0.0000832 0.0000101 mg/l

Classicals Total Suspended Solids (TSS) 0.061 0.00741 0.0274 0.00333 mg/l

Nutrients Ammonia As Nitrogen (NH3-N) 0.00166 0.000202 0.000747 0.0000907 mg/l

Nutrients Nitrate/Nitrite (NO3/NO2-N) 0.0000333 4.04E-06 0.000015 1.82E-06 mg/l

Nutrients Total Kjeldahl Nitrogen (TKN) 0.0193 0.00235 0.00868 0.00105 mg/l

Nutrients Total Phosphorus 0.00254 0.000308 0.00114 0.000138 mg/l

Metals Aluminum, Dissolved 0.539 0.0654 0.242 0.0294 μg/l

Metals Aluminum, Total 0.852 0.103 0.383 0.0465 μg/l

Metals Antimony, Dissolved 0.0000154 1.87E-06 6.92E-06 8.41E-07 μg/l

Metals Antimony, Total 0.0000448 5.44E-06 0.0000201 2.44E-06 μg/l

Metals Arsenic, Dissolved 1 0.0084 0.00102 0.00378 0.000458 μg/l

Metals Arsenic, Total 1 0.0103 0.00125 0.00465 0.000564 μg/l

Metals Barium, Dissolved 0.0218 0.00265 0.00981 0.00119 μg/l

Metals Barium, Total 0.0232 0.00282 0.0104 0.00127 μg/l

Metals Cadmium, Dissolved 0.00001 1.22E-06 4.51E-06 5.47E-07 μg/l

Metals Cadmium, Total 0.000181 0.0000219 0.0000812 9.85E-06 μg/l

Metals Calcium, Dissolved 173 21 77.7 9.43 μg/l

Metals Calcium, Total 175 21.3 78.7 9.55 μg/l

Metals Chromium, Dissolved 0.00139 0.000169 0.000625 0.0000758 μg/l

Metals Chromium, Total 0.00234 0.000284 0.00105 0.000128 μg/l

Metals Cobalt, Dissolved 0.0000254 3.09E-06 0.0000114 1.39E-06 μg/l

Metals Cobalt, Total 0.0000352 4.28E-06 0.0000158 1.92E-06 μg/l

Metals Copper, Dissolved 0.902 0.109 0.405 0.0492 μg/l

Metals Copper, Total 0.0542 0.00658 0.0244 0.00296 μg/l

Metals Iron, Dissolved 0.00474 0.000576 0.00213 0.000259 μg/l

Metals Iron, Total 0.197 0.0239 0.0884 0.0107 μg/l

Metals Lead, Dissolved 0.00112 0.000135 0.000501 0.0000608 μg/l

Metals Lead, Total 0.00465 0.000564 0.00209 0.000253 μg/l

Metals Magnesium, Dissolved 456 55.3 205 24.8 μg/l

Metals Magnesium, Total 447 54.3 201 24.4 μg/l

Metals Manganese, Dissolved 0.0835 0.0101 0.0375 0.00456 μg/l

Metals Manganese, Total 0.105 0.0128 0.0473 0.00574 μg/l

Metals Nickel, Dissolved 0.00437 0.000531 0.00197 0.000239 μg/l



## G-45Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.7: Recreational Ha rbor Vessel Scen arios Instantaneous Concentration in the Hypothetical Harbor

Model Model Model Model Class Analyte Scenarios 17 and 19 Scenarios 18 and 20 Scenarios 21 and 23 Scenarios Units 22 and 24

Metals Nickel, Total 0.00475 0.000577 0.00214 0.000259 μg/l

Metals Potassium, Dissolved 37 4.49 16.6 2.02 μg/l

Metals Potassium, Total 36.9 4.47 16.6 2.01 μg/l

Metals Selenium, Dissolved 1 0.0145 0.00176 0.00652 0.000792 μg/l

Metals Selenium, Total 1 0.0154 0.00187 0.00694 0.000842 μg/l

Metals Silver, Dissolved 4.52E-06 5.49E-07 2.03E-06 2.47E-07 μg/l

Metals Silver, Total 0.0000085 1.03E-06 3.82E-06 4.64E-07 μg/l

Metals Sodium, Dissolved 902 110 406 49.2 μg/l

Metals Sodium,Total 1070 130 480 58.3 μg/l

Metals Thallium, Dissolved 3.93E -06 4.78E-07 1.77E-06 2. 15E-07 μg/l

Metals Thallium,Total 4.29E-08 5.2E-09 1.93E- 08 2.34E-09 μg/l

Metals Vanadium, Dissolved 0.000742 0.0000901 0.000334 0.0000405 μg/l

Metals Vanadium,Total 0.000833 0.000101 0.000375 0.0000455 μg/l

Metals Zinc, Dissolved 0.085 0.0103 0.0382 0.00464 μg/l

Metals Zinc, Total 0.169 0.0205 0.0759 0.00922 μg/l Nonylphenols Bisphenol A 6.97E- 06 8.46E-07 3.13E-06 3.8E-07 μg/l Nonylphenols Nonylphenol decaethoxylate (NP 10EO) 0.00103 0.0001 25 0.000462 0.0000561 μg/l Nonylphenols Nonylphenol dode caethoxylate (NP12EO) 0. 000837 0.000102 0.000376 0.0000456 μg/l Nonylphenols Nonylphenol heptadecaethoxylate (NP17EO) 0.0000548 6.65E-06 0. 0000246 2.99E-06 μg/l Nonylphenols Nonylphe nol heptaethoxylate (NP7EO) 0.00058 0.0000704 0.000261 0.0000316 μg/l Nonylphenols Nonylphenol hexadecaethoxylate (NP16EO) 0.000117 0.0000142 0.0000 525 6.38E-06 μg/l Nonylphenols Nonylphenol he xaethoxylate (NP6EO) 0.000383 0.0000464 0.000172 0.0000209 μg/l Nonylphenols Nonylphenol nonaethoxylate (NP9EO) 0.000906 0.00011 0.000407 0.0000494 μg/l Nonylphenols Nonylphenol oc taethoxylate (NP8EO) 0.000784 0.0000951 0.000352 0.0000428 μg/l Nonylphenols Nonylphenol octo decaethoxylate (NP18EO) 0.0000273 3.31E-06 0.0000123 1.49E-06 μg/l Nonylphenols Nonylphe nol pendecaethoxylate (NP15EO) 0.000221 0.0000269 0.0000994 0.0000121 μg/l Nonylphenols Nonylphe nol pentaethoxylate (NP5EO) 0.000195 0.0000237 0.0000878 0.0000107 μg/l Nonylphenols Nonylphenol tetr adecaethoxylate (NP14EO) 0. 000398 0.0000482 0.000179 0.0000217 μg/l Nonylphenols Nonylphenol tetr aethoxylate (NP4EO) 0.0000567 6.88E-06 0.0000255 3.09E-06 μg/l Nonylphenols Nonylphenol trid ecaethoxylate (NP13EO) 0. 000604 0.0000733 0.000271 0.0000329 μg/l Nonylphenols Nonylphenol trie thoxylate (NP3EO) 0.0000309 3.75E-06 0.0000139 1.69E-06 μg/l Nonylphenols Nonylphenol unde caethoxylate (NP11EO) 0. 00105 0.000128 0.000473 0.0000574 μg/l Nonylphenols Octylphenol decaethoxylate (OP 10EO) 0.0000274 3.32E- 06 0.0000123 1.49E-06 μg/l Nonylphenols Octylphenol dodecaet hoxylate (OP12EO) 0.0000125 1.52E-06 5. 64E-06 6.84E-07 μg/l Nonylphenols Octylphenol hept aethoxylate (OP7EO) 8.24E-07 0.0000001 3.7E-07 4.49E-08 μg/l Nonylphenols Octylphenol nonaethoxylate (OP9 EO) 0.0000102 1.24E-06 4.58E-06 5.56E-07 μg/l Nonylphenols Octylphenol oct aethoxylate (OP8EO) 7.03E-06 8.53E-07 3.16E-06 3.83E-07 μg/l Nonylphenols Octylphenol undecaet hoxylate (OP11EO) 0.0000165 0.000002 7. 41E-06 8.99E-07 μg/l Nonylphenols Total Nonylphenol Polyet hoxylates 0.00705 0.000856 0.00317 0.000385 μg/l Nonylphenols Total Nonylphenols 0. 000025 3.03E-06 0.0000112 1.36E-06 μg/l

VOC (2-Methyl-1-Propenyl)-Benzene 0.00234 0.000284 0.00105 0.000128 μg/l

VOC (E)-1-Propenyl-Benzene 1.77E-06 2.15E-07 7.95E-07 9.65E-08 μg/l

VOC (E)-2-Butenal 0.00428 0.00052 0.00192 0.000234 μg/l

VOC 1,2,3,4-Tetrahydro-1-Methylnaphthalene 0.00269 0.000327 0.00121 0.000147 μg/l

VOC 1,2,3,4-Tetrahydro-2-Methylnaphthalene 0.00248 0.000302 0.00112 0.000136 μg/l

VOC 1,2,3,4-Tetrahydro-5-Methylnaphthalene 0.0218 0.00264 0.00978 0.00119 μg/l

VOC 1,2,3,4-Tetrahydro-6-Ethylnaphthalene, 0.00235 0.000285 0.00105 0.000128 μg/l

VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene 0.0198 0.0024 0.00888 0.00108 μg/l

VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene (01) 0.00498 0.000605 0.00224 0.000272 μg/l



## G-46Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.7: Recreational Ha rbor Vessel Scen arios Instantaneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 17 and 19 Model Scenarios 18 and 20 Model Scenarios 21 and 23 Model Scenarios 22 and 24 Units

VOC 1,2,3,4-Tetrahydro-6-Methylnaphthalene (02) 0.00417 0.000506 0.00187 0.000227 μg/l

VOC 1,2,3,4-Tetrahydronaphthalene 0.0149 0.00181 0.00671 0.000814 μg/l

VOC 1,2,3,4-Tetramethyl-Benzene 0.000702 0.0000853 0.000316 0.0000383 μg/l

VOC 1,2,3,5-Tetramethyl-Benzene 0.00103 0.000125 0.000465 0.0000564 μg/l

VOC 1,2,3-Trimethylbenzene 0.00338 0.00041 0.00152 0.000184 μg/l

VOC 1,2,4,5-Tetramethylbenzene 0.00158 0.000191 0.000709 0.000086 μg/l

VOC 1,2,4-Trimethylbenzene 0.00577 0.0007 0.00259 0.000315 μg/l

VOC 1,3,5-Trimethylbenzene 0.00155 0.000189 0.000698 0.0000848 μg/l

VOC 1,3-Methylnaphthalene 0.00307 0.000373 0.00138 0.000168 μg/l

VOC 1,7-Methylnaphthalene 0.0139 0.00169 0.00625 0.000758 μg/l

VOC 1-Ethyl-2,3-Dimethyl-Benzene (01) 0.00241 0.000293 0.00108 0.000131 μg/l

VOC 1-Ethyl-2,3-Dimethyl-Benzene (02) 0.000429 0.0000521 0.000193 0.0000234 μg/l

VOC 1-Ethyl-2,4-Dimethyl-Benzene 0.00167 0.000203 0.000751 0.0000912 μg/l

VOC 1-Ethyl-2-Methyl-Benzene 5.46E-06 6.63E-07 2.45E-06 2.98E-07 μg/l

VOC 1-Ethyl-3-Methyl-Benzene 0.00259 0.000314 0.00116 0.000141 μg/l

VOC 1-Ethyl-4-Methyl-Benzene 0.00704 0.000855 0.00317 0.000384 μg/l

VOC 1-Methyl-2-(1-Methylethyl)-Benzene 0 0 0 0 μg/l

VOC 1-Methyl-2-(1-Methylethyl)-Benzene (01) 4.42E-06 5.37E-07 1.99E-06 2.41E-07 μg/l

VOC 1-Methyl-2-(1-Methylethyl)-Benzene (02) 0.0000154 1.88E-06 6.94E-06 8.43E-07 μg/l

VOC 1-Methyl-3-Propyl-Benzene 0.00137 0.000167 0.000617 0.0000749 μg/l

VOC 1-Methyl-4-(1-Methylidene)-Cyclohexane 0 0 0 0 μg/l

VOC 1-methyl-Indan 0.00651 0.00079 0.00292 0.000355 μg/l

VOC 1-Propenyl-Benzene 2.03E-06 2.46E-07 9.12E-07 1.11E-07 μg/l

VOC 2- Heptanone 0.0000656 7.96E-06 0.0000295 3.58E-06 μg/l

VOC 2,3-Dihydro-1,2-Dimethyl-1H-Indene 0.000353 0.0000429 0.000159 0.0000193 μg/l

VOC 2,3-Dihydro-1,6-Dimethyl-1H-Indene 0.00297 0.00036 0.00133 0.000162 μg/l

VOC 2,3-Dihydro-1-Methylindene 0.00408 0.000495 0.00183 0.000223 μg/l

VOC 2,3-Dihydro-1-methylindene (01) 0.00228 0.000276 0.00102 0.000124 μg/l

VOC 2,3-Dihydro-1-methylindene (02) 0.00483 0.000586 0.00217 0.000263 μg/l

VOC 2,3-Dihydro-4,7-Dimethyl-1H-Indene 0.0000134 1.63E-06 6.02E-06 7.31E-07 μg/l

VOC 2,3-Dihydro-4-Methyl-1H-Indene 0.0436 0.00529 0.0196 0.00238 μg/l

VOC 2,3-Dihydro-4-Methyl-1H-Indene (01) 6.29E-06 7.64E-07 2.83E-06 3.43E-07 μg/l

VOC 2,3-Dihydro-4-Methyl-1H-Indene (02) 0.0000106 1.29E-06 4.77E-06 5.79E-07 μg/l

VOC 2,3-Dihydro-5,6-dimethyl-1H-Indene 0.00221 0.000268 0.000992 0.00012 μg/l

VOC 2,3-Dihydro-5-methyl-1H-Indene 0.00174 0.000211 0.00078 0.0000947 μg/l

VOC 2,6-Dimethylnaphthalene 0.0302 0.00367 0.0136 0.00165 μg/l

VOC 2-Butanone 0.0231 0.00281 0.0104 0.00126 μg/l

VOC 2-Butenal 0.00267 0.000324 0.0012 0.000146 μg/l

VOC 2-Ethyl-1,3,5-Trimethyl-Benzene 0.00322 0.000391 0.00145 0.000176 μg/l

VOC 2-Ethyl-1,4-Dimethyl-Benzene 0.0149 0.00181 0.00669 0.000812 μg/l

VOC 2-Ethyl-1-Hexanol 1.21E-06 1.47E-07 5.45E-07 6.62E-08 μg/l

VOC 2-Ethyltoluene 0.00492 0.000597 0.00221 0.000268 μg/l

VOC 2-Hexanone 0.00202 0.000246 0.00091 0.00011 μg/l

VOC 2-Methyl-2-Propenal 0.00492 0.000597 0.00221 0.000268 μg/l

VOC 2-Propenyl-Benzene 0.00514 0.000624 0.00231 0.000281 μg/l

VOC 3-Buten-2-one 0.00452 0.000548 0.00203 0.000246 μg/l

VOC 4-Ethyl-1,2-Dimethyl-Benzene 5.62E-06 6.82E-07 2.52E-06 3.06E-07 μg/l

VOC 4-Heptanone 0.0000868 0.0000105 0.000039 4.74E-06 μg/l

VOC 4-Isopropyltoluene 0.000689 0.0000836 0.000309 0.0000376 μg/l



## G-47Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.7: Recreational Ha rbor Vessel Scen arios Instantaneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 17 and 19 Model Scenarios 18 and 20 Model Scenarios 21 and 23 Model Scenarios 22 and 24 Units

VOC 4-Methyl-2-Pentanone 0.000705 0.0000855 0.000317 0.0000384 μg/l

VOC Acetaldehyde 0.0143 0.00173 0.00642 0.00078 μg/l

VOC Acetone 0.103 0.0126 0.0465 0.00564 μg/l

VOC Acrolein 0.00598 0.000726 0.00269 0.000326 μg/l

VOC Benzaldehyde 0.000186 0.0000226 0.0000838 0.0000102 μg/l

VOC Benzene 0.00596 0.000723 0.00268 0.000325 μg/l

VOC Benzocycloheptatriene 0.0285 0.00346 0.0128 0.00156 μg/l

VOC Benzofuran 0.00289 0.000351 0.0013 0.000158 μg/l

VOC Bromodichloromethane 4.54E-06 5.51E-07 2.04E-06 2.48E-07 μg/l

VOC Butane 0.000569 0.0000691 0.000256 0.0000311 μg/l

VOC Butyraldehyde 0.00349 0.000424 0.00157 0.00019 μg/l

VOC Carbon disulfide 0.0000022 2.67E-07 9.88E-07 1.2E-07 μg/l

VOC Chloroform 0.00192 0.000233 0.000862 0.000105 μg/l

VOC cis-1,2-Dichloroethene 3.38E-06 4.1E-07 1.52E-06 1.84E-07 μg/l

VOC Cyclohexane 0.0000723 8.78E-06 0.0000325 3.95E-06 μg/l

VOC Dibromochloromethane 4.46E-06 5.41E-07 0.000002 2.43E-07 μg/l

VOC Dimethocxymethane 0.00384 0.000466 0.00173 0.000209 μg/l

VOC Ethanol 0.0000232 2.82E-06 0.0000104 1.27E-06 μg/l

VOC Ethylbenzene 0.00219 0.000265 0.000982 0.000119 μg/l

VOC Indene 0.0000308 3.74E-06 0.0000139 1.68E-06 μg/l

VOC Isopropylbenzene 0.00107 0.00013 0.000482 0.0000585 μg/l

VOC Limonene 0 0 0 0 μg/l

VOC m,p-Xylene (Sum of Isomers) 0.00733 0.00089 0.0033 0.0004 μg/l

VOC Methyl acetate 0.0015 0.000182 0.000672 0.0000816 μg/l

VOC Methyl tertiary butyl ether (MTBE) 9.62E-06 1.17E-06 4.32E-06 5.25E-07 μg/l

VOC Methylcyclohexane 0.0000656 7.97E-06 0.0000295 3.58E-06 μg/l

VOC Methylene chloride 0.000376 0.0000456 0.000169 0.0000205 μg/l

VOC n-Butylbenzene 0.000644 0.0000782 0.000289 0.0000351 μg/l

VOC nitro-Methane 0.00214 0.00026 0.000961 0.000117 μg/l

VOC Nonanal 1.44E-06 1.75E-07 6.47E-07 7.86E-08 μg/l

VOC n-Propylbenzene 0.000626 0.000076 0.000281 0.0000341 μg/l

VOC n-Valeraldehyde 0.00309 0.000375 0.00139 0.000169 μg/l

VOC O-Xylene 0.00476 0.000578 0.00214 0.00026 μg/l

VOC sec-Butylbenzene 0.00146 0.000177 0.000657 0.0000797 μg/l

VOC Styrene 0.00112 0.000135 0.000501 0.0000608 μg/l

VOC Sulfur dioxide 0.00316 0.000383 0.00142 0.000172 μg/l

VOC Tetrachloroethene 2.54E-06 3.09E-07 1.14E-06 1.39E-07 μg/l

VOC Toluene 0.00832 0.00101 0.00374 0.000454 μg/l

VOC Trichloroethene 2.37E-06 2.87E-07 1.06E-06 1.29E-07 μg/l

VOC Trichlorofluoromethane 0.00124 0.000151 0.000558 0.0000678 μg/l

VOC Tridecane 0.00255 0. 00031 0.00115 0.000139 μg/l

VOC Unknown VOC 0.00308 0.000373 0.00138 0.000168 μg/l

VOC Unknown VOC (01) 0.00223 0.000271 0.001 0.000122 μg/l

VOC Unknown VOC (02) 0.00298 0.000362 0.00134 0.000163 μg/l

VOC Unknown VOC (03) 0.00271 0.000328 0.00122 0.000148 μg/l

VOC Unknown VOC (04) 0.00175 0.000213 0.000788 0.0000957 μg/l

VOC Unknown VOC (05) 0.00161 0.000195 0.000722 0.0000877 μg/l

VOC Vinyl acetate 0.00159 0.000193 0.000714 0.0000867 μg/l

SVOC (E)-2-Tetradecene 0.0000776 9.42E-06 0.0000349 4.23E-06 μg/l



## G-48Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.7: Recreational Ha rbor Vessel Scen arios Instantaneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 17 and 19 Model Scenarios 18 and 20 Model Scenarios 21 and 23 Model Scenarios 22 and 24 Units

SVOC 1,2,3,4-Tetrahydro-2,7-Dimethylna phthalene 0.000184 0.0000224 0.0000828 0.0000101 μg/l

SVOC 1,2,3-Trichloro-(Z)-1-Propene 0.000054 6.55E-06 0.0000243 2.95E-06 μg/l

SVOC 1,2,3-Trimethylbenzene (1) 0.000786 0.0000954 0.000353 0.0000429 μg/l

SVOC 1,2,3-Trimethylbenzene (2) 0.001 0.000122 0.00045 0.0000546 μg/l

SVOC 1,2,4,5-Tetramethylbenzene (1) 0.00011 0.0000134 0.0000494 0.000006 μg/l

SVOC 1,2,4,5-Tetramethylbenzene (2) 0.000102 0.0000124 0.0000459 5.57E-06 μg/l

SVOC 1,2-Diethyl-Cyclobutane 0.00731 0.000888 0.00329 0.000399 μg/l

SVOC 1,3-Dimethylnaphthalene 0.0000269 3.27E-06 0.0000121 1.47E-06 μg/l

SVOC 1,3-Dimethylnaphthalene (01) 0.00415 0.000503 0.00186 0.000226 μg/l

SVOC 1,4-Dimethyl-1,2,3,4-tetrahydrona phthalene 0.00613 0.000745 0.00276 0.000335 μg/l

SVOC 1,4-Dimethylnaphthalene 0.00668 0.000811 0.003 0.000364 μg/l

SVOC 1,4-Dimethylnaphthalene (01) 0.0044 0.000533 0.00198 0.00024 μg/l

SVOC 1,5-Dimethylnaphthalene 0.000664 0.0000806 0.000298 0.0000362 μg/l

SVOC 1,6-Dimethylnaphthalene 0.0311 0.00377 0.014 0.00169 μg/l

SVOC 1,7,7-tri-(methyl)-bicyclo[2.2.1]heptane 0 0 0 0 μg/l

SVOC 1-Dodecanol 0.000029 3.51E-06 0.000013 1.58E-06 μg/l

SVOC 1-Hexadecene 2.68E-06 3. 26E-07 1.21E-06 1.46E-07 μg/l

SVOC 1-Methyl-2-Propyl-Benzene (01) 0.000828 0.000101 0.000372 0.0000452 μg/l

SVOC 1-Methyl-2-Propyl-Benzene (02) 0.000239 0.000029 0.000108 0.0000131 μg/l

SVOC 1-Methylnaphthalene 0.0281 0.00341 0.0126 0.00153 μg/l

SVOC 1-Phenyl-1-Butene 1.56E-06 1.89E-07 7.01E-07 8.51E-08 μg/l

SVOC 2-(dodecyloxy)-Ethanol 0.0000362 4.39E-06 0.0000163 1.97E-06 μg/l

SVOC 2-(hexadecyloxy)-Ethanol 9.29E-06 1.13E-06 4.18E-06 5.07E-07 μg/l

SVOC 2-(tetradecyloxy)-Ethanol 0.0000268 3.26E-06 0.0000121 1.46E-06 μg/l

SVOC 2,3-Dimethylnaphthalene 0.00541 0.000657 0.00243 0.000295 μg/l

SVOC 2,4,6-Trichlorophenol 0.0000112 1.35E-06 5.01E-06 6.08E-07 μg/l

SVOC 2,4-Dimethyl-Benzaldehyde 0.0000029 3.52E-07 0.0000013 1.58E-07 μg/l

SVOC 2,4-Dimethylphenol 0.00154 0.000187 0.000693 0.0000841 μg/l

SVOC 2,6,10,14-Tetramethyl Pentad ecane 0.00965 0.00117 0.00434 0.000526 μg/l

SVOC 2,6,10,14-Tetramethylhexad ecae 0.0065 0.000789 0.00292 0.000355 μg/l

SVOC 2,6,10,14-Tetramethylhexadecae ( 01) 0.000292 0.0000354 0.000131 0.0000159 μg/l

SVOC 2,6-dimethyl-Heptadecan e 0.0106 0.00129 0.00477 0.000578 μg/l

SVOC 2,7-Dimethylnaphthalene 0.0075 0.000911 0.00337 0.000409 μg/l

SVOC 2-Cyclopenten1-one 0.00073 0.0000886 0.000328 0.0000398 μg/l

SVOC 2-Ethyl-Hexanoic acid 0.103 0.0125 0.0465 0.00564 μg/l

SVOC 2-Hydroxy-Benzaldehyde 0.0112 0.00136 0.00505 0.000613 μg/l

SVOC 2-Mercaptobenzothiazole 0 0 0 0 μg/l

SVOC 2-Methyl Tridecane 0.000154 0.0000187 0.0000694 8.42E-06 μg/l

SVOC 2-Methyl-Benzaldehyde 0.00478 0.00058 0.00215 0.000261 μg/l

SVOC 2-Methyl-Dodecane 0.0000384 4.66E-06 0.0000172 2.09E-06 μg/l

SVOC 2-Methylnaphthalene 0.036 0.00437 0.0162 0.00196 μg/l

SVOC 2-Naphthalenecarboxaldehyde 0.000799 0.0000969 0.000359 0.0000436 μg/l

SVOC 3,4-Dimethylphenol 1.36E-06 1.65E-07 6.12E-07 7.43E-08 μg/l

SVOC 3,5-Dimethyl-Benzaldehyde 1.76E-06 2.14E-07 7.92E-07 9.62E-08 μg/l

SVOC 3,6-Dimethylundecane 5.59E- 07 6.79E-08 2.51E- 07 3.05E-08 μg/l

SVOC 3-Methyl-Benzaldehyde 0.0102 0.00123 0.00456 0.000554 μg/l

SVOC 3-Methyl-Benzaldehyde (01) 0.0114 0.00138 0.00512 0.000621 μg/l

SVOC 3-Methyl-butanoic acid 0.0000917 0.0000111 0.0000412 0.000005 μg/l

SVOC 3-Methyl-Phenanthrene 0.00476 0.000578 0.00214 0.00026 μg/l



## G-49Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## Appendix G.7: Recreational Ha rbor Vessel Scen arios Instantaneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 17 and 19 Model Scenarios 18 and 20 Model Scenarios 21 and 23 Model Scenarios 22 and 24 Units

SVOC 3-Methylphenol 0.000532 0.0000646 0.000239 0.000029 μg/l

SVOC 3-Phenyl-2-Propenal 0.000359 0.0000436 0.000162 0.0000196 μg/l

SVOC 4,4-Dimethylbiphenyl 0.00495 0.000601 0.00222 0.00027 μg/l

SVOC 4-Hydroxy-2-Butanone 0.00554 0.000673 0.00249 0.000302 μg/l

SVOC 4-Methyl-1H-Benzotriazole 5.58E-06 6.77E-07 2.51E-06 3.04E-07 μg/l

SVOC 4-METHYL-PENTANOIC ACID 0.0000611 7.42E-06 0.0000275 3.34E-06 μg/l

SVOC 5-Butyl-Hexadecane 4.31E-07 5.23E-08 1.94E-07 2.35E-08 μg/l

SVOC 5-Methyl-2-(1-methyl)-Cyclohexanol 7.58E-06 9.2E-07 3.41E-06 4.13E-07 μg/l

SVOC 9-Methyl-9H-Fluorene 0.00509 0.000618 0.00229 0.000278 μg/l

SVOC Acenaphthylene 0.00275 0.000334 0.00124 0.00015 μg/l

SVOC Acetophenone 0.0000146 1.77E-06 6.55E-06 7.94E-07 μg/l

SVOC Benzeneacetic Acid 0.0000 467 5.66E-06 0.0000 21 2.55E-06 μg/l

SVOC Benzenepropanoic Acid 0.0000515 6.25E-06 0.0000231 2.81E-06 μg/l

SVOC Benzothiazole 0.0000239 0.0000029 0.0000107 0.0000013 μg/l

SVOC Benzyl alcohol 0.0000152 1.85E-06 6.84E-06 8.3E-07 μg/l

SVOC Biphenyl 0.00273 0.000331 0.00122 0.000149 μg/l

SVOC Bis(2-ethylhexyl) phthalate 0.00114 0.000138 0.000511 0.000062 μg/l

SVOC Caprolactam 0.0000273 3.32E-06 0.0000123 1.49E-06 μg/l

SVOC Cholesterol 0.000142 0.0000172 0.0000636 7.72E-06 μg/l

SVOC Cyclic octaatomic sulfur 0.012 0.00146 0.00539 0.000654 μg/l

SVOC Cyclodecane 0.0000795 9. 64E-06 0.0000357 4.33E-06 μg/l

SVOC Cyclododecane 0.0000296 3. 59E-06 0.0000133 1.61E-06 μg/l

SVOC Cyclotetradecane 0.0000158 1.92E-06 7.12E-06 8.64E-07 μg/l

SVOC Diethene Glycol Monododecyl Ether 0.0000299 3.62E-06 0.0000134 1.63E-06 μg/l

SVOC Dimethyl phthalate 0.0000651 0.0000079 0.0000292 3.55E-06 μg/l

SVOC Di-n-butyl phthalate 0.00139 0.000168 0.000624 0.0000757 μg/l

SVOC Di-n-octyl phthalate 0.0000571 6.94E-06 0.0000257 3.12E-06 μg/l

SVOC Disopropylene glycol 8.81E -06 1.07E-06 3.96E-06 4.8E-07 μg/l

SVOC Dodecane 3.21E-07 3.9E -08 1.44E-07 1.75E-08 μg/l

SVOC Dodecanoic acid 0.0000217 2.63E-06 9.74E-06 1.18E-06 μg/l

SVOC Eicosane 0.0243 0.00295 0.0109 0.00133 μg/l

SVOC Ethanol, 2,2-oxybis- 0.000974 0.000118 0.000438 0.0000531 μg/l

SVOC Ethanol, 2-Butoxy 0.00619 0.000752 0.00278 0.000338 μg/l

SVOC Fluorene 0.00294 0.000356 0.00132 0.00016 μg/l

SVOC Heneicosane 0.00744 0.000903 0.00334 0.000406 μg/l

SVOC Heptadecane 0.0429 0.00521 0.0193 0.00234 μg/l

SVOC Hexaethylene Glycol Monododecyl 0.0000182 2.21E-06 8.17E-06 9.91E-07 μg/l

SVOC Hexaethylene Glycol Monododecyl (01) 7.28E-06 8.84E-07 3.27E-06 3.97E-07 μg/l

SVOC Hexaethylene Glycol Monododecyl ( 02) 0.0000023 2.79E-07 1.03E-06 1.25E-07 μg/l

SVOC Hexagol 0.0000105 1.27E-06 4.71E-06 5.72E-07 μg/l

SVOC Indane 0.000858 0.000104 0.000386 0.0000468 μg/l

SVOC Indole 0.000257 0.0000313 0.000116 0.000014 μg/l

SVOC Isopropylbenzene-4,methyl-1 0 0 0 0 μg/l

SVOC m-Cresol 0.0000245 2.98E-06 0.000011 1.34E-06 μg/l

SVOC Naphthalene 0.0133 0.00161 0.00596 0.000723 μg/l

SVOC N-Butyl-Benzenesulfonamide 0.000003 3.64E-07 1.35E-06 1.64E-07 μg/l

SVOC n-Hexadecane 0.0408 0.00495 0.0183 0.00223 μg/l

SVOC n-Hexadecanoic acid 0.0000153 1.86E-06 6.89E-06 8.36E-07 μg/l

SVOC Nonadecane 0.033 0.00401 0.0148 0.0018 μg/l



## G-50Appendix G – Supporting Information for EPA’ s Screening-Level Water Quality Model



## G-51 Appendix G.7: Recreational Harbor Vessel Scen arios Instantaneous Concentration in the Hypothetical Harbor

Class Analyte Model Scenarios 17 and 19 Model Scenarios 18 and 20 Model Scenarios 21 and 23 Model Scenarios 22 and 24 Units

SVOC Nonadecane (01) 0. 0102 0.00124 0.00459 0.000557 μg/l

SVOC Nonanoic Acid 0.00805 0.000977 0.00362 0.000439 μg/l

SVOC n-Pentadecane 0.0316 0.00383 0.0142 0.00172 μg/l

SVOC n-Tetradecane 0.039 0.00474 0.0175 0.00213 μg/l

SVOC o-Cresol 0.00457 0.000555 0.00205 0.000249 μg/l

SVOC Octadecane 0.0093 0. 00113 0.00418 0.000508 μg/l

SVOC p-Cresol 0.0136 0.00165 0.00612 0.000743 μg/l

SVOC Pentacosane 0.000266 0.0000323 0.000119 0.0000145 μg/l

SVOC Pentaethene Glycol Monododecyl Ethe r 2.46E-06 2.98E-07 0.0000011 1.34E-07 μg/l

SVOC Pentaethene Glycol Monododecyl Ether (01) 0.000018 2.18E-06 8.07E-06 9.8E-07 μg/l

SVOC Pentaethene Glycol Monododecyl Ether (02) 0.0000354 4.29E-06 0.0000159 1.93E-06 μg/l

SVOC Phenanthrene 0.0025 0.000303 0.00112 0.000136 μg/l

SVOC Phenol 0.0279 0.00339 0.0126 0.00152 μg/l

SVOC Phthalic acid, isobutyl octyl es ter 0.0000102 1.24E-06 0.0000046 5.58E-07 μg/l

SVOC Pyrene 0.000125 0.0000151 0.0000561 6.81E-06 μg/l

SVOC Sulfur 0.00346 0.00042 0.00156 0.000189 μg/l

SVOC Tetraethylene glycol monododecyl ether 0.0000183 2.22E-06 8.23E-06 9.99E-07 μg/l

SVOC Triethyl phosphate 0.0000422 5.13E-06 0.000019 0.0000023 μg/l

SVOC Triethylene glycol monododecyl ether 0.0000272 0.0000033 0.0000122 1.48E-06 μg/l

SVOC Unknown SVOC 0.00742 0.0009 0.00333 0.000405 μg/l

SVOC Unknown SVOC (01) 0.00681 0.000826 0.00306 0.000371 μg/l

SVOC Unknown SVOC (02) 0.0072 0.000874 0.00324 0.000393 μg/l

SVOC Unknown SVOC (03) 0.000288 0.0000349 0.000129 0.0000157 μg/l

SVOC Unknown SVOC (04) 0.000295 0.0000359 0.000133 0.0000161 μg/l

SVOC Unknown SVOC (05) 0.000166 0.0000202 0.0000748 9.08E-06 μg/l

SVOC Unknown SVOC (06) 0.000103 0.0000125 0.0000464 5.63E-06 μg/l

SVOC Unknown SVOC (07) 0.00154 0.000187 0.000692 0.000084 μg/l 

### (1) EPA suspects a limited number of the samples analyzed for selenium (even fewer for arsenic) for bilgewater, packing gland effluent, propulsion engine effluent, graywater and deck washdown water may be positively influenced (increased) by interference from high concentrations of major cations in the sample matrix. Although EPA suspects that the highest concentrations of dissolved arsenic (and to a lesser extent selenium) in fish hold effluent from a shrimping vessel could be slightly elevated due to cation interference; EPA believes the fish hold concentrations reasonably represent true effluent concentrations for the discharge (see Section 3.2.4.1). EPA considered these interferences when interpreting the potential for vessel discharges to pose a risk to human health, aquatic life, or the environment and determined that such cationic interference does not influence the major findings presented in the modeling analysis.

## Appendix H – Responsiveness Summary



# Appendix H
R esponsiveness Summary

EPA received 24 separate comment letters from 23 different commenters. These included 19 trade associations (Alaska L ongline Fishermen’s Association, Alaska Trollers Association, American Coatings A ssociation, American Waterways Operators, Boat U.S., California Wetfish Producers Asso ciation, two comments fr om Conference of Professional Operators for Response To wing (C-PORT), Garden State Seafood Association, National Associ ation of Charterboats, Nati onal Marine Manufacturers Association, Offshore Marine Service Association, Passenger Vessel Association, Recreational Fishing Alliance – South Carolina Chapter, Sefood Producers Coop, Southeast Alaska Fishermen’s Alliance, Un ited Cook Inlet Drift Association (UCIDA), the United Fishermen of Alaska, and West Coast Seafood Processors Association), 4 vessel operators or businesses (3 in Alaska or the Pacific Northwest, 1 in New Jersey) and 1 state agency (Alaska Department of Environmental Conservation). EPA considered the comments received in finalizing the Report and thanks these commenters for providing us with their feedback on the report. We have su mmarized significant or reoccurring comments below.

COMMENT: Some commenters noted that EPA did not sample a sufficient number of vessels.

RESPONSE: EPA believes that the dataset used to ch aracterize discharges from nonrecreational vessels less than 79 feet in length and all comm ercial fishing vessels regardless of length is from a representative cross-section of ve ssels and is adequate to evaluate the vessel population. In conducting this study, EPA work ed with 14 trade associations and 27 individual companies to obt ain information regarding the shipboard processes, equipment, materials, and operations that co ntribute to the discharges, as well as the discharge rates, duration, frequency, and location.

EPA collected samples of nine vessel discharg es from a total of 61 vessels (one to four discharges sampled per vessel) in nine vesse l classes to characterize discharge pollutant concentrations and flow. These vessels were located in 15 different towns/cities in nine separate states, representing several of the major regions of the United States.

In preparing the Report to Congress, EPA used all of the technical ly appropriate data provided by industry and colle cted from EPA’s vessel sampling program. EPA released the pre publication version of the draft report to congress to the public on March 2, 2010 (announced in the March 8th Federal Regi ster Notice (75 FR 10477)) and solicited comment on all aspects of the report as we ll as specific comment on the existence of additional data or data sources. As previously discussed, EPA received 24 separate comment letters from 23 diffe rent commenters, including 19 tr ade associations, 4 vessel operators or businesses, and 1 state agency. EPA evaluated the comments and

H-1

## Appendix H – Responsiveness Summary

information received and revised the draft re port to incorporate additional technically appropriate information. EPA be lieves that the final reportis based on adequate EPAgathered and industry-supplied data, whic h includes primary sampling data and an extensive review of existing peer-reviewe d literature and other government reports.

COMMENT: Several commenters questioned the repr esentativeness of the sampled vessels, particularly for commer cial fishing vessels.

RESPONSE: EPA believes that the dataset used to ch aracterize discharges from nonrecreational vessels less than 79 feet in length and all comm ercial fishing vessels regardless of length, including sampling data from 61 vessels, is from a representative cros s-section of vessels and is adequate for the purposes of this national, screening-level evaluation. EPA sampled vessels from each of the nine most common vessel classes and sampled more commercial fishing vessels (33 vessels) than any other vess el class due to the large number of fishing vessels in the P.L. 110-299 study universe. EPA notes that additional sampling to characterize the less common vesse l classes/types and di scharges would not influence the major findings of this study as the total discharge volume from these vessels are an insignificant po rtion of discharges from the to tal industry population. Given that EPA has limited data with which to base this study, EPA’s approach is reasonable.

In response to comments, EPA further evalua ted the representativeness of the sampled commercial fishing vessels by comparing their size, class, and geogr aphic distribution to those of the overall industry population.

Size. The following table compares the size dist ribution of the sampled vessels to the total industry population.

Percentage of Vessels

Vessel Length Sampled Commercial Fishing Vessel Population Overall Commercial Fishing Vessel Population *



## Less than 26 feet 0% 10% 26 to 50 feet 52% 70% 50 to 79 feet 39% 16% 79 feet or more 9% 4% * – Size distribution of those ve ssels that reported vessel length in the U.S. Coast Guard MISLE Database, 2009.

Commenters noted, and EPA concurs, that the sampled commercial fishing vessel population does not represent discharges from vessels less than 26 feet in length. EPA observed that these small vessels typically store their catch in coolers (which do not have a discharge) rather than in refrigerated seaw ater or ice holding tanks, as allowed by their relatively short fishing voyages. EPA attempted to interview small commercial fishing vessel captains to obtain information on fish ing operations and disc harges; however, none of the contacted vessel captains volunteered their vessels to rema in at the pier long

H-2

## Appendix H – Responsiveness Summary

enough for EPA to collect information or to sam p le their holding tanks (if any), but rather offloaded their catch within a few minutes (e .g., physically transferred bushels of crabs or lobsters from the cooler to the dock) and immediately returned to the fishing grounds.

For the remaining categories of vessel le ngth, the sampled vessel population reasonably agrees with the overall vessel population, albeit somewhat more heavily weighted toward the largest of commercial fishing vessels (i.e ., 50 feet or more) as compared to the overall vessel population. Again, due to the time requi red to collect the necessary data, captains of larger vessels were more willing to partic ipate in the study because they had more time shoreside during large offloads than the captains of smaller vessels.

In summary, with the exception of the smallest commercial fishing ve ssels, EPA believes that the sampled vessel population is a repres entative cross-section of vessels and is adequate to evaluate the vessel population fo r the purpose of this study. With respect to small vessels, as a conservative estimate, EPA assumed vessel discharge characteristics for small vessels similar to those of larger vessels.

Class . The following table compares the dist ribution by vessel class for the sampled fishing vessel types to th e total industry population.

Percentage of Vessels

Vessel Class Sampled Commercial Fishing Vessel Population Overall Commercial Fishing Vessel Population *



## Gillnetter 15% 9% Pot/Trap 3% 1 

## 27% Longliner 9% 6% Seiner 15% 2% Shrimper/Scalloper/Dredge 18% 23%
Tender 9% <1% Trawler 12% 12% Troller/Hook and Line 18% 19%
* – Vessel class distribution of those vessels that reported vessel subtype in the U.S. Coast Guard MISLE Database, 2009.

EPA’s sampled commercial fishing vessel populati on includes vessels in all of the fishing vessel classes. Furthermore, the percentage of sampled vessels by class is similar to or greater than the percentage of the overall vessel population by class for all vessel classes except for Pot/Trap vessels. Pot/Trap vessels include many of the smallest commercial vessels that are not represen ted by EPA’s sampled vessel population as discussed above, and in general have flow-through seawater holdi ng tanks used to keep crabs and lobsters alive until reaching th e seafood processing facility. As such, discharges from seafood holding tanks on Pot/Trap vessels are generally seawater. EPA also notes that it sampled a much larger percentage of seiners than the overall vessel populat ion (15% of vessels sampled versus only 2% of the overall vess el population). EPA sampled all vessels

1 

### EPA did sample a lobster hold tank on a 63-foot trawler.



## H-3

## Appendix H – Responsiveness Summary

(where the permission of the captains was gr anted ) that arrived at the docks at the seafood processors while the EPA sampling crew was at the docks. Sampling in Sitka, AK occurred at the start of the salmon fish ing season, resulting in a preponderance of Seiners at the docks of seafood processers.

In summary, with the possible exception of Pot/Trap vessels, EPA believes that the sampled vessel population is a representative cro ss-section of vessels and is adequate to evaluate the vessel population fo r the purpose of this study. With respect to Seiners, fish hold effluent analyte concentrations from th ese vessels were neither the lowest nor the highest among the fish hold effluent discharged by the sampled vessel population. Therefore, EPA believes that a ny overrepresentation of Seiner fish hold effluent in EPA’s analyses of vessel discharges would provi de neither a high nor low bias to EPA’s findings or conclusions.

Geographic Distribution . EPA sampled commercial fish ing vessels in the following regions: Alaska (21 vessels); Gulf Coast (6 vessels); and New England (6 vessels). According to the National Marine Fisheries Service 2 

## , in 2008 Alaska had nearly 55% of U.S. domestic commercial landings; the Gu lf Coast had approximately 15% of U.S. domestic commercial landings; and New Engla nd had just over 7% of U.S. domestic commercial landings. Combined, these three ar eas represent approximately 77% of U.S. domestic commercial landings in 2008. Among the remaining geographic regions that EPA was unable to sample, the Pacific Coas t (excluding Alaska) ha s the greatest landings in 2008 at 13%; commercials fishing vessels in this region are expected to be similar to those in Alaska. Finally, many of other remaining geographic re gions that EPA was unable to sample, such as Chesapeake, Middl e Atlantic, Great Lakes, and Hawaii, are likely dominated by small fishing vessels that may not have fish hold effluent discharges. Therefore, EPA believes that the geographic distribution of the sa mpled vessel population is a representative cross-s ection of vessels and is ade quate to evaluate the vessel population for the purpose of this study.

COMMENT: Some commenters noted that th e assumptions used for estimating discharge volumes for the screening-level water quality model (Chapt er 4 of the Report to Congress) resulted in higher estimates of volumes discharged. Fo r example, commenters noted that some commercial fishing vessels do not clean thei r hulls daily or empty their holds daily.

RESPONSE: Based on review and analysis of the comments, EPA ran a supplemental model run with the adjusted model assumptions presented in the table below and recalculated the associated discharge flows and loads. EPA performed this supplemental model run using the revised values to assess the impact s on the model results. EPA observed no significant change in model results based on th e revised values. EPA revised Chapter 4 to describe this supplemental model run and to present the findings.

2 

### National Marine Fisheries Service (NMFS). 2009. Fisheries of the United States 2008. NMFS Fisheries Statistics Division. Silver Spring, MD.



## H-4

## Appendix H – Responsiveness Summary

Revised Model Assumptions

Vessel Class Vessel Subclass Discharge Old Assumption New Assumption

Fishing Gillnetter Fish Hold Offloads daily Offloads once per five days Fishing Longliner Fish Hold Offloads once per two days Offloads once per five days

Fishing Toller Fish Hold Clean Offloads daily Offloads once per seven days Fishing Toller Fish Hold Offloads daily Offloads once per seven days Fishing Toller Fish Hold 840 ft 3 

### fish hold 595 ft 3 

### fish hold Fishing Toller Fish Hold 5.5 tons of ice per offload 2 tons of ice per offload Fishing Toller Deck Wash 125 gallons per deck wash 50 gallons per deck wash

Fishing Shrimping Bilge Water 150 gallons per minute bilge pump rate 20 gallons per minute bilge pump rate Tour Boat NA Bilge Water 14.3 gallons per day 5 gallons per day



## COMMENT: Many commenters noted that some vessels do no t have discharge type s discussed in the report, for example, towing vessels do not have fish hold waste.

RESPONSE: EPA agrees with this statement and believes th at this point is clear in the report when describing discharge types. Furthermore, in its model, EPA estimates certain discharge types to occur from only some vessels.

COMMENT: Some commenters noted th at too few vessels, or too few ve ssels of a certain vessel type were sampled. For example, one commenter stated that EPA should have sampled charter fishing vessels. Others stated that EPA should have sample d different types of vessels than those selected.

RESPONSE: See above response to comment regarding th e sufficiency of the number of vessels sampled. Charter fishing vessels are often manufactured or used primarily for pleasure, or leased, rented or chartered to a person fo r the pleasure of that person. Many are not inspected by the US Coast Guard. Charter fishing vessels which are not inspected are exempted form NPDES permitting requireme nts by the Clean Boating Act (P.L. 110- 288). Other charter fishing vessels are inspected by the US Coast Guard. These inspected, non-recreational ve ssels are not exempted from NPDES by the Clean Boating Act and are study vessels. Charter fishing vessels were not one of the most common vessels seen by EPA in its sampling program and the opportunity to sample charter fishing vessels did not present itself during the course of EPA’s sampling.

COMMENT: Some commenters noted that th e MISLE database is not a completely accurate database for estimating vessel numbers or vessel location.

H-5

## Appendix H – Responsiveness Summary

RESPONSE: EPA agrees that use of the database may result in shortcomings. For example, the database under- or overcounts certain categories of vessels due to gaps in documentation or reporting requirements, differences in how the categories are defined, or missing information. Additionally, while a vessel may lis t New Orleans as its hailing port, it may rarely, if ever, operate in waters in an d around New Orleans. However, based on its research, EPA concluded that the MISLE databa se was the best source of information for estimating the numbers and locations of study vessels. Several commenters pointed EPA to other databases. EPA revi ewed these sources of informa tion, and qualified the data in Chapter 1 of the report where appropriate.

Specifically, commenters raised concerns regarding estimates provided for two particular categories of vessels – passenger vessels and tank and freight barges – for which they believed MISLE misrepresents the number of active vessels less than 79 feet in length. EPA reviewed the MISLE database records a nd used additional information to further qualify the estimates presented in the report. For example, EPA revi sed the report to (1) detail the various types of vessels included in each category where the category definition differed from the types of vessels menti oned by commenters; (2) emphasize and further clarify limitations and potential shortcomings of the analyses; a nd (3) where possible, present ranges rather than unique estimates for the number of in-scope vessels.

In general, while EPA agrees that info rmation provided by the MISLE database is uncertain, subject to potential er rors and omissions, or potentially outdated, the Agency believes that this source still provides the most complete data available on vessel characteristics, particularly for smaller undocumented vessels which are of key concern in this study. EPA consulted with U.S. Coas t Guard personnel on the estimates presented in the report and compared numbers obtained from MISLE with those presented in other sources, when such sources are available. No other public database provides the same breadth of information, however, from which to develop estimates of the number or characteristics of study vessels.

COMMENT: Several commenters recommended that EPA anal yze data on a regional basis, particularly for discharges from commercial fishing vessels.

RESPONSE: Based on public comments received on EPA’ s Draft version of this report, EPA conducted a regional analysis of vessel fish hold discharges. While the preliminary analysis does suggest potential regional differences, issues with small sample size and an unbalanced distribution of vesse ls across regions suggest th at additional sampling would be required to make a definitive determina tion. This regional analysis, which also includes additional analyses to determine the degree to which regional differences were an artifact of differences in vessel type (f ishing method), or discha rge type (refrigerated water vs. ice vs. ice slurry) are now include d as a new subsection within the fish hold discharge section in Ch apter 3 of the report.

H-6

## Appendix H – Responsiveness Summary

COMMENT: Some commenters noted that EP A should distinguish between different types of fish hold effluent in the analytical results. For ex ample, one commenter stated that the Agency needed to more clearly distinguish between th e discharge of refrigerated seawater and sea ice or sea ice slurry. Other commenters noted that EPA needed to more clearly distinguish between fish hold discharge and fish hol d cleaning discharge.

RESPONSE: In response to the first comment (distingui shing results between types of discharge (refrigerated vs. sea ice or sea ice slurry), EPA conducted additional screening analyses. EPA conducted an analysis comparing poten tial differences between refrigerated seawater, sea ice, or sea ice slurry. Differen ces in the type of fish hold discharge were separately investigated both for all 26 vesse ls included in this study and for the 20 vessels from Alaska. In both instances, there were no statistically significant differences between fish hold discharges between vessels as a function of whether the discharge was refrigerated seawater, ice, or ice slurry. Th ese analyses are discussed within the regional analysis section within the fish hold disc harge section in Chap ter 3 of the Report.

EPA disagrees with the second comment because the data presented in the report clearly indicate few, if any, distingui shable differences between resu lts obtained for fish hold and fish hold cleaning discharge, and where those differences occur, EPA discusses them in

text.

COMMENT: One commenter noted that the report is not conducted on recr eational vessels and that the report needs to be clearer to this effect. Other commenters noted that the potential cumulative environmental impacts from all study vessels should be compared to the potential cumulative environmental im pacts from all recreational vessels.

RESPONSE: EPA believes the report is clear that the vast majority of samples are from vessels which were not in recreational service. Howeve r, two vessels sample d were recreational vessels, while discharges from several others were fundamentally similar to those which may originate from recreational vessels (e .g., engine effluent from certain towing vessels).

For purposes of this study, EPA does not beli eve that the cumulative impact of study vessels should be compared to those of recrea tional vessels, as an anal ysis of this kind is beyond the original congressional charge and beyond the original scope of the study design.

COMMENT: Some commenters noted that EP A should examine the impacts of invasive species from recreational vessels, or what w ould happen if EPA were to prohibit practices designed to reduce the transport of invasive species (e .g., anti-foulant hull coatings). A commenter

H-7

## Appendix H – Responsiveness Summary

noted that EP A should add additional references to the impact of i nvasive species caused by boating, specifically in the absence of cuprous oxide anti-foulant hull coatings.

RESPONSE: EPA and EPA scientists, among others have conducted numerous studies on the impacts of invasive species. EPA further discusses the impacts of invasive sp ecies in regulatory documents such as the fact sheet and other supporting documents for its recently issued Vessel General Permit. EPA agrees with the commenter that the risks of increasing the likelihood of invasive species being transported needs to be weighed against any regulatory limits placed on discharges. However, this report does not make recommendations regarding regulatory lim its or best management practices.

COMMENT: Two commenters noted that EPA needed to fu rther research and cl arify its statements regarding anti-f oulant paints.

RESPONSE: One commenter noted that the issue of invasive species wa s inadequately discussed in relationship to the regulation of anti-foulant coatings (AFC s). As discussed in the previous response, the focus of the study was not on invasive species. Additionally, based on comments regarding AFCs, EPA remo ved one sentence: “On the other hand, improvements to water quality, including impr ovements associated with AFC restrictions and BMPs may allow native ecosystems to r ecover from acute and chronic impacts and become more resistant to invasions of non- native species” attri buted to Johnson and Gonzalez (2006), which appear ed to be speculative.

Additional test data for copper AFC leach ing rates were provided to EPA by the Antifouling Coatings Work Group (AFWG) of the American Coatings Association (ACA) during the public comment period. EPA added a footnote in Section 3.2.8 acknowledging receipt of additi onal test data for copper AF C leaching rates, and noted that this data substa ntially agrees with EPA's "best es timate" of copper AFC leaching rate used for water quality modeling.

One commenter noted that statements regardi ng the regulation of AFCs in other countries were misleading and/or incorrect. Upon revi ew, EPA found that the regulation of AFCs in Europe and other countries are dynamic and evolving. Therefore, EPA elected to remove the text in question, which appeared to be outdated.

COMMENT: One commenter noted that EPA needs to cl arify in the executive summary that the National Recommended Water Quality Crit eria (NRWQC) benchmarks used are conservative in nature.

RESPONSE: EPA disagrees and feels the informati on provided in Chapter 3 on the NRWQC benchmarks is clear. This level of detail is not appropriate for discussion in a short executive summary.

H-8

## Appendix H – Responsiveness Summary

COMMENT: Some commenters stated that they believed the release or leaching of metals or other biocides from hull coatings did not constitute a discharge.

RESPONSE: EPA disagrees, and would consider these rel eases as discharges from the vessel. EPA has consistently determined that the release of metals or leaching of metals or other biocides constitutes the addition of pollutants from a point source to waters of the United States, i.e., a discharge. (See EPA’s 2008 Vessel General Permit or Uniform National Discharge Standards (UNDS) Phase I rule and CWA section 502). The CWA definition of “point source” includes “ve ssel or other floating craft.”

COMMENT: One commenter noted that EPA should clearl y distinguish between commercial fishing vessels and charter fishing vesse ls. The commenter also noted that charter fishing vessels are more similar to recreational vessels than many of their commercial fishing counterparts.

RESPONSE: The charter fishing vessels discussed by th ese commenters may fall under the definition of recreational vessel as defi ned in the Clean Boating Ac t of 2008. Charter fishing vessels are often manufactured or used primarily for pleasure, or leased, rented, or chartered to a person for the pleasure of th at person. Many are not inspected by the US Coast Guard. Charter fishing vessels which are not inspected are exempted form NPDES permitting requirements by the Clean Boating Act (P.L. 110-288). Other charter fishing vessels are inspected by the US Coast Guar d. These inspected, non-recreational vessels are not exempted from NPDES by the Clean Boating Act, and are study vessels,. EPA did not sample any charter fishing vesse ls as part of the sampling program.

In addition to sampling two recreational vesse ls, EPA studied several recreational vessels used for non-recreational purposes as part of the study (some tow/salvage boats and research vessels). Vessel di scharges such as engine effl uent are likely fundamentally similar to the engine effluent between the two vessel classes, provided they are similar engine types and maintained in a similar manner.

COMMENT: Several commenters noted that they recomm ended Congress continue to extend the P.L. 110-299 moratorium or that Congress devise an alternate regula tory program. For example, several commenters noted that co mmercial fishing vesse ls less than 79 feet should be regulated similarly to those under the Clean Boating Act of 2008 (P.L. 110- 288). Other commenters requested exempti ons from NPDES permitting or any permit EPA may promulgate under the NPDES pe rmitting program for smaller commercial fishing vessels.

H-9

## Appendix H – Responsiveness Summary

H-10 RESPONSE: On July 30, 2010, President Obama signed Senate Bill S. 3372 to extend an existing moratorium from July 31, 2010 to December 18, 2013. This moratorium exempts all incidental discharges exce pt ballast water from comme rcial fishing vessels and nonrecreational vessels less than 79 feet fr om having to obtain an NPDES permit.

EPA notes that this is not the proper fo rum for requesting that the Agency grant exemptions to certain classes of vessels fr om the NPDES program. Please see discussion in the 2008 VGP Fact Sheet for additional information about why EPA now regulates certain vessel discharges and for additional information on Congressional legislation that did grant permanent exemptions to certain types of vessels.

COMMENT: One commenter requested an extension of tim e to review the report and provide further

comments.

RESPONSE: Due to the short time granted to EPA to conduct the study, EPA believes it would be inappropriate to grant any exte nsions to review the report as the Agency wants the final report to be available for congr essional decision makers and others as soon as possible.Appendix I – List of Preparers and Contributors



# Appendix I
L ist of Preparers and Contributors

Ryan Albert, Office of Water, EPA Robin Danesi, Office of Water, EPA Erin Saylor, Office of Water, EPA Sean Ramach, EPA Region 5 Marcus Zobrist, Office of Water, EPA Jill Bloom, Office of Prevention, Pesticides, and Toxic Substances Brian Rappoli, Office of Water, EPA Renee Searafoss , EPA Region 3 Tyler Linton, Great Lakes Environmental Center Doug Endicott , Great Lakes Environmental Center Keith Taulbee, Great Lakes Environmental Center Michelle Moore, Great Lakes Environmental Center Debra Falatko, Eastern Research Group Mark Briggs , Eastern Research Group Kathleen Wu, Eastern Research Group Kristi Bibb, Eastern Research Group Isabelle Morin, Abt Associates Lauren Tikusis, Abt Associates



# Laboratory Support and Analyses:

John Bourbon, EPA Region 2 John Lee, EPA Region 2 Maria Javier, EPA Region 2 William Rickert, EPA Region 2 Renee Lettieri, EPA Region 2 Jamie Hale, EPA Region 2 Deborah Kay, EPA Region 2 Cindy Caporale, EPA Region 3 Sue Warner , EPA Region 3 Dave Russell , EPA Region 3 Robin Costas , EPA Region 3 Joe Dorsey , EPA Region 3 John Curry, EPA Region 3 Ron Altman , EPA Region 3 Norman Fritsche , EPA Region 3 Kevin Poff , EPA Region 3 Kevin Martin , EPA Region 3 Larry Zintec, EPA Region 5

I-1