This document contains the Draft EPA Report “Underwater Ship 

Husbandry Environmental Effects Analysis Report” published in 

August 2003. The reference number is: EPA-842-D-06-012

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Environmental Effects Analysis Report 

Underwater Ship Husbandry 

August 2003 
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ENVIRONMENTAL EFFECTS ANALYSIS REPORT 

UNDERWATER SHIP HUSBANDRY 

Prepared by: 

Naval Sea Systems Command 

U.S. Department of the Navy 

Office of Water 

U.S. Environmental Protection Agency 
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TABLE OF CONTENTS 

1.0 INTRODUCTION ............................................................................................................... 1

2.0 SUMMARY OF EEA METHODOLOGY ........................................................................ 2

3.0 SUMMARY OF EEA RESULTS ....................................................................................... 3

3.1 BASELINE DISCHARGE (CURRENT PRACTICE)............................................................ 4

3.1.1 Discharge Characterization Data ................................................................................... 4

3.1.2 Discharge Comparison to Criteria ................................................................................. 4

3.1.3 Discharge Toxicity (Hazard Index) ............................................................................... 5

3.1.4 Nonindigenous Species Release .................................................................................... 6

3.1.5 Bioaccumulative Contaminants of Concern .................................................................. 7

3.1.6 Constituent Mass Loading and Toxic Pound Equivalents ............................................. 7

3.1.7 Other Potential Environmental Impacts......................................................................... 8

3.1.8 Summary of Environmental Effects............................................................................... 9

3.2 UNDERWATER SHIP HUSBANDRY MANAGEMENT PLAN (USHMP) MPCD ............ 10

3.2.1 Discharge Comparison to Criteria ............................................................................... 12

3.2.2 Discharge Toxicity (Hazard Index) ............................................................................. 13

3.2.3 Nonindigenous Species Release .................................................................................. 13

3.2.4 Bioaccumulative Contaminants of Concern ................................................................ 15

3.2.5 Constituent Mass Loading and Toxic Pound Equivalents ........................................... 15

3.2.6 Other Potential Environmental Impacts....................................................................... 16

3.2.7 Summary of Environmental Effects............................................................................. 16

4.0 UNCERTAINTY ANALYSIS .......................................................................................... 17

4.1 EXCEEDED WATER QUALITY CRITERIA ................................................................... 17

4.2 DISCHARGE HAZARD INDEX ...................................................................................... 17

4.3 NONINDIGENOUS SPECIES RELEASE.......................................................................... 18

4.4 BIOACCUMULATIVE CONTAMINANTS OF CONCERN ................................................. 18

4.5 CONSTITUENT MASS LOADING AND TOXIC POUND EQUIVALENTS ......................... 18

4.6 OTHER POTENTIAL ENVIRONMENTAL IMPACTS ...................................................... 18

4.7 CONCLUSION .............................................................................................................. 19

5.0 REFERENCES .................................................................................................................. 20

APPENDIX A NARRATIVE WATER QUALITY CRITERIA ANALYSIS FOR 

UWSH UNDERWATER SHIP CLEANING DISCHARGE......................................... 23
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LIST OF TABLES 

Table 3-1. Constituents of Concern Identified in the Baseline Discharge from Underwater Ship 

Cleanings with Comparisons to Numeric WQC ....................................................................... 5

Table 3-2. Narrative WQC Categories Exceeded by the Baseline Discharge from

Underwater Ship Cleanings.......................................................................................................5

Table 3-3. UWSH Constituent Concentrations (above background) at EOMZ........................................... 6

Table 3-4. Constituents of Concern Ranked by EOP and EOMZ HQ in the Baseline Discharge

from Underwater Ship Cleanings .............................................................................................. 6

Table 3-5. Bioaccumulative Contaminants of Concern Identified in the Baseline Discharge from

Underwater Ship Cleanings.......................................................................................................7

Table 3-6. Mass Loading and TPEs for the Constituents of Concern Identified in the Baseline 

Discharge from Underwater Ship Cleanings ............................................................................. 8

Table 3-7. Constituents of Concern Summary of Environmental Effects for Underwater 

Ship Cleanings........................................................................................................................... 9

Table 3-8. Summary of Projected Environmental Impacts ........................................................................ 11
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LIST OF ACRONYMS 

BCC Bioaccumulative Contaminant of Concern 

BOD Biological Oxygen Demand 

ChAR Characterization Analysis Report 

CMC Criterion Maximum Concentration 

COC Constituent of Concern 

DAT Discharge Assessment Team 

EEA Environmental Effects Analysis 

EEAR Environmental Effects Analysis Report 

EOMZ Edge of Mixing Zone (35 m from EOP) 

EOP End of Pipe (assumed to be adjacent to the hull at 3 m) 

EPA Environmental Protection Agency 

FR Fouling Rating 

HI Hazard Index (sum of constituent HQs) 

HQ Hazard Quotient 

MPCD Marine Pollution Control Device 

NIS Nonindigenous Species 

NSTM Naval Ships’ Technical Manual 

SCAMP Submersible Cleaning and Maintenance Platform 

TDD Technical Development Document (UNDS Phase I) 

TPE Toxic Pound Equivalent 

TSS Total Suspended Solids 

UNDS Uniform National Discharge Standards 

USCG United States Coast Guard 

USHMP Underwater Ship Husbandry Management Plan 

UWSH Underwater Ship Husbandry 

VOC Volatile Organic Compound 

WQS Federal Water Quality Standards or State Water Quality Criteria 
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1.0 INTRODUCTION 

The Armed Forces perform hull cleaning operations to remove fouling organisms (i.e., 

biofouling) that have adhered to the underwater surfaces of a vessel. A vessel produces the 

underwater ship husbandry (UWSH) discharge when, during the performance of inspection, 

maintenance, cleaning, and repairing of hulls, materials are discharged into the environment (40 

CFR 1700.4). The primary source of constituents for the UWSH discharge is hull cleaning 

operations. 

The Uniform National Discharge Standards (UNDS) Phase I Technical Development Document 

(TDD) identified eight activities that may contribute to the UWSH discharge (EPA and DoD, 

1999). The Phase I TDD concluded that hull cleaning operations have the potential to cause an 

adverse environmental effect. The remaining seven activities identified in the Phase I TDD 

Nature of Discharge (NOD) report (i.e., fiberglass repair, welding, sonar dome repair, paint 

operations, non-destructive testing/inspection, masker belt repair, and SEAWOLF Propulsor 

layup) were re-evaluated in UNDS Phase II (McCue, 2002a; McCue, 2002b) and were again 

determined to be discharged infrequently and result in small discharge amounts of a nature that 

results in a low potential for environmental effect (Navy and EPA, 2003a). Based on that 

determination, this environmental effects analysis (EEA) addresses only underwater hull 

cleaning operations for the UWSH discharge. 

The Navy usually conducts full hull cleanings when a fouling rating of FR-40 or greater is 

observed over 20 percent of the hull. This generally would occur once hard fouling is observed 

on the hull (i.e., second stage of fouling). Interim cleanings are conducted between full 

cleanings when performance limitations are evidenced (e.g. speed degradation; fuel efficiency 

decrease). Additional information on hull cleanings and fouling ratings can be found in the 

Characterization Analysis Report (ChAR): UWSH (Navy and EPA, 2003b). 

While there are several types of antifouling coatings on the market, two types of coatings are 

approved for use on the hulls of Armed Forces vessels: (1) copper-containing antifouling 

coatings and (2) “foul-release” (non-biocide) coatings. The majority of Armed Forces vessel 

hulls are coated with copper-containing antifouling coatings. The number of vessels with foulrelease coating systems is approximately 13% of the fleet or 383 vessels. This number is small 

when compared to the 2,614 Armed Forces vessels with copper-containing coatings. The vessels 

with foul-release or advanced coating account for approximately 0.4% of the entire surface area 

of the Armed Forces vessels (Shimko, 2003a). The use of foul-release or other advanced 

coatings has not been demonstrated to control fouling effectively for most vessels and, as a 

result, is limited to Armed Forces vessels with (1) aluminum hulls, (2) drydock cycles less than 

five years, or (3) vessels that have specialized acoustic performance requirements. This 

Environmental Effects Analysis Report (EEAR) only evaluates the UWSH discharge associated 

with copper-containing antifouling coatings. The UWSH Discharge Assessment Team (DAT) 

determined that environmental impacts from foul-release coatings were of sufficiently low 

toxicity that they did not need to be evaluated (Navy and EPA, 2003c). Additional information 

on the types of coatings, their application, and leachate rates on Armed Forces vessels are found 

in the ChAR: UWSH, the EEAR: Hull Coating Leachate, and the ChAR: Hull Coating Leachate 

(Navy and EPA, 2003b; Navy and EPA, 2003d; Navy and EPA, 2003e). 
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The Phase I NOD report in the TDD identified only copper and zinc as constituents of concern 

for copper antifouling coating systems (EPA and DoD, 1999). In addition, data from previous 

Navy environmental reports, including Environmental Effects from In-Water Hull Cleaning of 

Ablative Copper Antifouling Coatings (Navy, 1994) and Characterization of Effluent from Navy 

Advanced Underwater Hull Cleaning Vehicle Operations Conducted on USS Saipon (LHA-2) 

(Navy, 2001), were used to characterize the UWSH discharge generated during hull cleaning 

operations. These reports provide sampling data collected during typical Navy underwater hull 

cleaning operations occurring pierside. Samples were taken from discharge plumes generated by 

a multi-brush cleaning device [i.e., submersible cleaning and maintenance platform (SCAMP)] 

and hand-held cleaning devices operated by divers. Data from the samples include chemical 

constituent concentrations; field measurements of pH, biological oxygen demand (BOD), and 

total suspended solids (TSS). Samples were taken before, during, and after hull cleaning 

operations. Discharge characterization was also supplemented by process knowledge provided 

by Navy equipment experts. Details on the characterization of this discharge are contained in the 

Underwater Ship Husbandry ChAR (Navy and EPA, 2003b). 

The USHMP provides for comprehensive control of materials discharged during UWSH 

cleaning operations. The USHMP would function to control underwater ship cleaning 

discharges by a variety of means including standardization of cleaning criteria (i.e., thresholds at 

which underwater cleaning is required), appropriate types of cleaning (i.e., only cleaning the 

areas that have reached a minimum level of fouling), and the selection of appropriate cleaning 

equipment (i.e., selecting the proper piece of equipment based on the level and intensity of 

fouling). The USHMP would consolidate all of these practices into a single plan. 

2.0 SUMMARY OF EEA METHODOLOGY

 The UWSH EEA only addresses vessels that produce the discharge, which are referred to as 

“vessels cleaned while afloat”. A representative vessel class was not selected because the 

variables associated with cleaning and the major constituents released are independent of vessel 

class. Refer to the Vessel Grouping and Representative Vessels for Underwater Ship Husbandry 

(Navy and EPA, 2003f) for additional information. Vessel grouping methodology is discussed 

further in the Development of Vessel Groups and Selection of Representative Vessels for 

Feasibility and Environmental Effects Analyses guidance document (Navy and EPA, 2000). 

For the purpose of this EEA, the baseline discharge (current practice) for the hull cleaning 

discharge is considered the same as the USHMP MPCD option. The results presented in this 

report are based on the quantitative and qualitative characterization of the baseline discharge 

(current practice) described in the ChAR: UWSH (Navy and EPA, 2003b). Section 3.2 of this 

report includes a sensitivity analysis to assess the environmental impact of changing baseline 

practices from current equipment, methodology, and management practices. 

Because the UWSH discharge is not released from a pipe, end-of-pipe (EOP) concentration is 

not directly applicable. However, to facilitate analysis, the DAT defined a surrogate resultant 

concentration as the increase in receiving water concentration adjacent to the hull over 

background (ambient) that result from the hull cleaning operations. This increase in 
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concentration over background levels was used for comparison to numeric water quality criteria. 

The Navy hull cleaning studies provided a range of receiving water data at different depths and 

distances from ship hulls undergoing hull cleaning operations. For comparison to numeric and 

narrative water quality criteria, samples reported in the Phase I NOD of the TDD during hull 

cleaning operations were used as EOP. 

The only sample analysis data reported was for dissolved copper (Navy, 1994). Studies have 

demonstrated that only dissolved copper is biologically available (Zirino and Seligman, 2002). 

The Navy report (1994) considered only dissolved copper because the report focused on the 

biological availability of the copper and total copper samples were not taken. The report notes 

that although an area may have a higher total copper value, the amount of toxic copper present 

may be low because most copper is strongly bound in a complex organic matrix, present as an 

insoluble oxide, or sorbed to particulates. In addition, no other chemical constituents were 

evaluated. To determine the concentrations of zinc (zinc was not an analyte in hull cleaning 

studies), the dissolved copper data from Navy (1994) was used as a basis to develop surrogate 

data to characterize the UWSH. The copper to zinc ratio (2.5:1) was used to estimate the 

changes in zinc concentrations due to cleaning. The average copper to zinc ratio used in this 

evaluation is the same as that reported in the Phase I TDD for bulk coatings (EPA and DoD, 

1994). Although this ratio can vary by paint formulation, it provides the best available approach 

for estimating dissolved zinc from dissolved copper concentrations. Use of this ratio implies that 

zinc is found in receiving waters surrounding vessels being cleaned in approximately the same 

ratio as zinc is found in antifouling paints prior to application (EPA and DoD, 1994). 

Because of limited field data, alternative EOMZ concentrations were estimated by three 

methods. The resulting data are discussed in Section 3.1.3. The first method used field data 

from Navy (1994) studies that reported receiving water concentrations of dissolved copper 

between 20 and 50 m from hull cleaning activities. The second method used mass loading data 

(from the Phase I NOD) and assumed uniform mixing in a pool of water extending 35 m away 

from an aircraft carrier (e.g., CVN 68). The third method used per square meter copper loss 

reported in the Phase I NOD and the CH3D model to simulate constituent dilution from cleaning 

of an aircraft carrier’s hull surface area (SPAWAR, 2003). 

Section 3.1.6 presents the mass loading calculations. Annual mass loadings of copper and zinc 

were determined for all vessels that are cleaned during a typical year. Copper mass loadings 

were assumed to be identical among all clean wetted surface areas of vessel hulls. Calculated 

data are presented in the ChAR: UWSH (Navy and EPA, 2003b). 

Methods for the evaluation of UWSH discharge of nonindigenous species (NIS) release, 

bioaccumulative contaminants of concern (BCC), and other potential environment impacts are 

identical to those presented in the Environmental Effects Analysis Guidance Manual (EPA and 

Navy, 2000). 

3.0 SUMMARY OF EEA RESULTS 

This section summarizes the results of the eight technical analyses conducted for the baseline 

discharge (with current practices employed). The USHMP discharge is the same as the baseline 
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discharge. Section 3.1 describes the baseline EEA. Section 3.2 describes the USHMP sensitivity 

analysis on the environmental benefits of the current process. 

3.1 BASELINE DISCHARGE (CURRENT PRACTICE) 

The baseline discharge is defined as the release of constituents to the receiving water that occurs 

during the cleaning of hulls coated with antifouling hull coating systems (i.e., copper-containing 

antifouling coating systems), when the cleaning is conducted according to NSTM Chapter 081. 

These guidelines require that hull cleaning is performed under similar fouling conditions 

(normally defined as a fouling rating (FR) of 40). Foul condition is determined by visual 

inspection of the hull surface using divers or remote operating vehicles. Photographs of levels of 

fouling conditions are provided in NSTM Chapter 081 and in the ChAR: UWSH (Navy, 2002a; 

Navy and EPA, 2003b). The discharge generally occurs pierside and is generated by various 

types of cleaning equipment (e.g., multi-brush and single brush units, hydroblasters, and 

scrapers) operated by a diver. A detailed description of the baseline discharge is provided in the 

ChAR: UWSH (Navy and EPA, 2003b). 

3.1.1 Discharge Characterization Data 

Baseline discharge characterization data for vessels undergoing underwater hull cleanings were 

assembled from samples collected during hull cleaning operations of several Navy vessels and 

supplemented by process knowledge from Navy equipment experts. The data analysis for this 

discharge identified two constituents of concern (COCs) in the baseline discharge – copper and 

zinc: 

• Research studies of UWSH hull cleanings (Navy, 1994) demonstrated exceedances of 

Federal and State numeric water quality criteria (WQC) for copper. 

• Studies have identified copper and zinc – both of which are identified as BCCs. 

• Copper has a hazard quotient (HQ) > 1 near the hull. 

In accordance with the EEA guidance manual (Navy and EPA, 2000b), COCs are defined as: 

• Constituents that exceed one or more numeric or narrative WQC, 

• Constituents identified as BCCs, or 

• Constituents with HQ > 1.0 near the hull. 

The ChAR: UWSH contains more information of the discharge characterization data (Navy and 

EPA, 2003b). 

3.1.2 Discharge Comparison to Criteria 

Sampling data and Navy process knowledge (Navy, 1994; Navy, 2001) was used to compare the 

UWSH discharge to Federal and State WQC. Vessels that produce UWSH discharge operate in 

saltwater and freshwater. However, hull cleanings have typically been performed at saltwater 
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ports. In the comparison of the baseline discharge constituent data to numeric saltwater WQC, 

the dissolved copper values (1.1E+02 μg/L) exceeded 14 of 14 numeric WQC (Table 3-1). The 

EOP concentration of dissolved zinc did not exceed any numeric WQC (Table 3-1). 

Table 3-1. Constituents of Concern Identified in the Baseline Discharge from Underwater Ship 

Cleanings with Comparisons to Numeric WQC 

Constituents 

Estimated 

Concentration at 

EOP (μg/L) 

Criteria 

Exceeded 

Strictest 

Criterion 

(μg/L) 

State(s) with 

Strictest Criterion 

Copper, dissolved 1.1E+02 14 of 14 2.4E+00 CT, GA, MS 

Zinc, dissolved 4.3E+01 0 of 14 9.0E+01 Federal 

The baseline discharge also has the potential to exceed five narrative WQC categories (Table 

3-2). Appendix A provides the complete narrative WQC analysis including narrative endpoint 

descriptions and a summary table of narrative determinations. 

Table 3-2. Narrative WQC Categories Exceeded by the Baseline Discharge from 

Underwater Ship Cleanings 

Narrative Constituent Result 

Color Fail 

Floating Materials Fail 

Settleable Materials Fail 

Total Suspended Solids Fail [2.7E+01 μg/L] 

Turbidity Fail 

3.1.3 Discharge Toxicity (Hazard Index) 

Data from samples collected during and after several Navy hull cleaning operations were used to 

predict increases of dissolved copper in the receiving water relative to distance from the hull 

(Navy, 1984).1 A dissolved copper value (adjacent to hulls) was estimated at 1.1E+02 μg/L 

(above background concentration). A detailed description is provided in the ChAR: UWSH 

(Navy and EPA, 2003b). 

Because the dissolved copper concentration following a hull cleaning is difficult to predict, three 

separate estimates of dissolved copper concentrations at 35 m were made. A mass dilution 

calculation produced an increase in dissolved copper concentration of 3.5E+01 μg/L (above 

background at EOMZ). Samples taken between 20-50 m during a hull cleaning showed an 

increase in dissolved copper concentration of 4.7E+00 μg/L (above background at EOMZ) 

(Navy, 1994). Modeling of the discharge (Navy, 2003) showed an approximate dilution factor of 

3.16 at EOMZ, equating to 3.4E+01 μg/L (above background) of dissolved copper. Dissolved 

zinc values were extrapolated from the dissolved copper values, as previously described in 

Section 2.0. The EOMZ methods and the extrapolations used for the zinc values are described in 

1

 Total copper concentrations were not sampled. 
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Section 2.0. Table 3-3 illustrates the results of the UWSH constituent concentrations (above 

background) at EOMZ. 

Table 3-3. UWSH Constituent Concentrations (above background) at EOMZ 

Determination Method 

Estimated Cleaning Effluent Concentration at EOMZ 

(above background) 

Copper, dissolved (μg/L) Zinc, dissolved (μg/L) 

Mass Dilution Calculation 3.5E+01 1.1E+01 

Field Data (Navy, 1994) 4.7E+00 1.9E+00 

Model (dilution factor ~3.16) 3.4E+01 1.4E+01 

HI values were calculated using the estimated copper and zinc concentrations from the three 

EOMZ methods. The mass dilution method produces an HI > 1 (7.5E+00). The field data 

method results in an HI = 1 (1.0E+00). The model method results in an HI > 1 (7.2E+00). Table 

3-4 summarizes the results of the HQ and HI calculations for the baseline discharge constituents 

from the three EOMZ methods. 

For more information on the use of the HI calculations in the UNDS program, see Method for 

Assessing the Toxicity of Multiple Contaminants in Discharges from Vessels of the Armed Forces 

Uniform National Discharge Standards (UNDS) Phase II (Navy and EPA, 2001a). 

Table 3-4. Constituents of Concern Ranked by EOP and EOMZ HQ in the Baseline Discharge 

from Underwater Ship Cleanings 

Constituent HQ* at EOP 

HQ* at EOMZ 

(Mass Dilution) 

HQ* at EOMZ 

(Field Data) 

HQ* at EOMZ 

(Model) 

Copper, dissolved 2.2E+01 7.3E+00 9.8E-01 7.3E+00 

Zinc, dissolved 4.8E-01 1.6E-01 2.1E-02 1.6E-01 

Total 2.3E+01 7.5E+00 HI > 1.0 1.0E+00 HI = 1.0 7.2E+00 HI > 1.0 

* Calculated HQs for concentrations above background conditions 

An HI of 1.0 is the level considered to be protective of aquatic life from acute toxic effects of the 

discharge (Brent, 2001). This level is based on the EPA water quality criteria for aquatic life 

(i.e., Criterion Maximum Concentration [CMC]). The CMC is intended to protect most species 

most of the time (EPA, 1991). This level of protection is set near the concentration resulting in 

no observable effect on the most sensitive aquatic species, which EPA has determined will 

adequately protect aquatic communities. At HI values less than or equal to 1.0, the potential for 

acute toxic effects to aquatic species is considered to be at an acceptable level. 

3.1.4 Nonindigenous Species Release 

Hull cleaning operations are designed to remove organisms that colonize on the hull surface in 

spite of the biocidal properties of the antifouling paint. Consequently, cleaning operations have 

the potential to cause the release of nonindigenous species. Regular (i.e., FR-40) cleaning 

activities may decrease the potential by limiting the amount and types of organism communities 

that colonize on the hull. As described in the NSTM Chapter 081, cleaning at appropriate 
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intervals decreases significant accumulation of organisms and improves the effectiveness of the 

antifouling coating system. Cleaning hulls at greater than FR-40 may increase the potential to 

release nonindigenous species because fouling communities at these levels are more developed 

and may contain mature organisms that can likely colonize new environments. 

The physico-chemical and biological conditions of the receiving waters, the lifecycle of the 

fouling organism, and the competition of resident plant and animal species also affects the 

potential – positively and negatively – for nonindigenous species released by hull cleaning 

operations to successfully colonize receiving waters. Presently, hull cleaning operations do not 

consider any of these factors, and there are insufficient data to correlate nonindigenous species 

release and colonization to hull cleaning operations. Hull cleanings at different fouling ratings 

have not been correlated with different types of nonindigenous species release and/or the 

successful colonization of species. Not all introduced species to an aquatic environment 

successfully colonize. The ChAR: UWSH contains information on the organisms that may be 

found on the hull and subsequently released during a hull cleaning operation (Navy and EPA, 

2003b). 

3.1.5 Bioaccumulative Contaminants of Concern 

The UNDS program divides BCCs into two types: those designated for elimination by various 

international, Federal, and State programs and those designated for reduction by U.S. permit and 

clean-up programs. Copper and zinc, which are present in the discharge, are designated as 

reduction BCCs. Table 3-5 lists the constituents identified as BCCs. 

Table 3-5. Bioaccumulative Contaminants of Concern Identified in the Baseline Discharge from 

Underwater Ship Cleanings 

Elimination BCCs Reduction BCCs 

None Copper 

Zinc 

3.1.6 Constituent Mass Loading and Toxic Pound Equivalents 

The mass loadings of copper and zinc and calculated toxic pound equivalents (TPEs) were 

determined from UNDS Phase I data. Refer to the ChAR: UWSH for additional information on 

mass loading calculations (Navy and EPA, 2003b). Table 3-6 presents the mass loading and 

TPE values for dissolved copper and zinc. 
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Table 3-6. Mass Loading and TPEs for the Constituents of Concern Identified in the Baseline 

Discharge from Underwater Ship Cleanings 

Discharge Constituent 

Mass 

Loading 

(lb/yr) 

Toxic 

Weighting 

Factor (TWF) 

Toxic Pound 

Equivalents 

(TPEs) 

Copper, dissolved 7.5E+02 1.8E+00 3.7E+02 

Zinc, dissolved 3.0E+02 7.0E-02 1.3E+01 

COC TPE Total 3.8E+02 

Total Discharge TPE 3.8E+02 

The primary contributor to the total discharge TPE is copper (with a TPE value of approximately 

3.7E+-2, which is 97% of the total TPE). The other COC, zinc, has a TPE value of 1.3E+-2, 

which is 3% of the total TPE. 

3.1.7 Other Potential Environmental Impacts 

Additional potential environmental impacts resulting from hull cleaning operations include 

impacts to air and sediments. Regular cleanings optimize the period that a hull coating system is 

functional, and thereby minimizes the need for repainting. Limiting the need for repainting, 

whether small in-water recoating operations or drydocking for hull recoating reduces volatile 

organic compounds (VOCs) released during painting operations. Painting copper-containing 

coatings is estimated to emit approximately 4.3E+00 pounds of VOCs per 100 ft2 cleaned during 

the repainting process (Shimko, 2003b). 

The discharge from cleaning operations has the potential to release suspended solids and 

particulates, such as small particles from the hull coating and organic matter from the fouling 

organisms. The particles may settle to the sediment close to where the hull cleaning operations 

are performed. 

From observations of the plume emanating from the SCAMP during a hull cleaning, the 

calcareous particles often settle to the sediment close to where the hull cleaning operations are 

performed, while the finer particles remain suspended for a longer period of time. From the 

observation of a one-liter sample bottle collected during a hull cleaning operation, the calcareous 

particles settle in a matter of seconds; fine paint particles (less than ~100 μm) slowly settle to the 

bottom within 24 hours, while grass and other plant material float on the surface or remain 

suspended (Klinkhammer, 2003). The introduction of metals from the particulate matter may 

negatively impact benthic communities. 

Paint particles discharged into the environment have the potential to contribute copper to both 

sediment and water, in dissolved and particulate form. The release rate of dissolved copper from 

paint particles, as they settle to the bottom, depends primarily on the age and condition of the 

paint, size of the paint particles released from the hull, temperature, and amount of potential 

complexing compounds in the waterbody. The quantity of dissolved copper released from paint 

particles, as they settle to the bottom, depends primarily on the release rate and the rate of 

settling of the particles. The particles from a recently applied coating would have a greater 

potential to increase concentration than an older paint. Similarly the size of the particle would 
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also increase the concentration as the surface area of these fine particles increase. Complexation 

capacity of the waterbody would influence the concentrations of dissolved copper that has been 

released from the paint particles. 

However, the dissolved fraction of copper is likely to be small relative to the amount of copper 

deposited in particulate form to the sediment. After deposition to sediments, the paint particles 

will continue to leach copper over a long period of time. Some of the dissolved copper leached 

into interstitial waters from the settled particulate eventually binds to dissolved and particulate 

(organic and inorganic) materials in the sediment. The increase of copper in these fractions has a 

low potential to produce toxic conditions in the sediments (Shaner, 2003). Although organic 

matter deposited to sediments has the potential to adversely affect sediment biota under heavy 

loading and certain hydrologic conditions, such effects were not found in a previous study in San 

Diego Bay by Navy (1994). Appendix A provides the endpoints for narrative criteria WQC. 

3.1.8 Summary of Environmental Effects 

The analysis of the baseline discharge identified two COCs, copper and zinc. Table 3-7 details 

the concentrations of the COCs, their corresponding acute WQC, HQs at EOMZ, BCC 

identification, mass loading, and TPE values. 

Table 3-7. Constituents of Concern Summary of Environmental Effects for Underwater 

Ship Cleanings 

Constituent 

of Concern 

Concentration 

at EOP (μg/L) 

Corresponding 

Acute WQC 

HQs at EOMZ 

(model) 

Reduction 

BCC 

Mass Loading 

(lb/yr) 

TPE 

Values 

Copper, 

dissolved 1.1E+02 2.4E+00 (CT, GA, MS) 7.3E+00 3 7.5E+02 3.7E+02 

Zinc, 

dissolved 4.3E+01 9.0E+01 (Federal) 1.6E-01 3 3.0E+02 1.3E+01 

In summary, the baseline discharge: 

• Exceeds 14 numeric saltwater WQC for dissolved copper; no exceedances for dissolved 

zinc. 

• Exceeds five narrative WQC categories (see Appendix A). 

• Has EOMZ HI values ranging from 1.0 or greater. 

• Has the potential to both introduce and control nonindigenous species. 

• Contains two reduction BCCs (copper and zinc). 

• Has a total discharge TPE of 3.8E+02, with the COCs comprising approximately 100% 

of the total TPE. 
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3.2 UNDERWATER SHIP HUSBANDRY MANAGEMENT PLAN (USHMP) MPCD 

The USHMP will function to consolidate the current practices into a single document, thus the 

baseline discharge is the same as the MPCD discharge (i.e., USHMP). This section evaluates 

changes in the EEA results with deviations in (1) criteria for cleaning, (2) type of cleaning, and 

(3) equipment selection. Quantitative data are not available; therefore, process knowledge was 

used to evaluate comparisons of each deviation from current practices. 

Specific deviations to the current practices are listed below: 

• Criteria for cleaning: 

− Clean more frequently 

− Clean less frequently. 

• Type of cleaning (partial or interim versus full cleaning): 

− More full cleanings (less partial or interim cleanings) 

− Less full cleanings (more partial or interim cleanings). 

− No cleanings. 

• Equipment selection: 

− More aggressive 

− Less aggressive. 

The environmental benefits or consequences of each deviation from current practices are 

summarized in Table 3-8. Only one practice was considered at a time. The interrelations of 

changing multiple combined practices were not considered. 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 

Table 3-8. Summary of Projected Environmental Impacts 

Practice Operation 

WQC Exceedances Toxicity (HI) at 

EOMZ 

NIS 

Introduction BCC Mass Loading

Numeric Narrative 

Current Practice (Cleaning at established fouling threshold) 

Copper, 

dissolved 

(14 of 14) 

Color, TSS, 

turbidity, floating 

material, settleable 

material 

Range from HI = 1 

to 7.5 

Potential to 

release 

Copper, 

Zinc 

Cu = 7.5E+

Zn = 3.0E+0

Total TPE 3.8E

Criteria For 

Cleaning 

Clean at Lower Threshold (Clean more frequently) 

Copper, 

dissolved 

(14 of 14) 

Decreased 

likelihood to 

exceed 

Increased relative 

to current practice 

Impact 

Unknown 

Copper, 

Zinc 

Increased m

loadings and 

Clean at Higher Threshold (Clean less frequently) 

Copper, 

dissolved 

(14 of 14) 

Increased 

likelihood to 

exceed 

Increased relative 

to current practice 

Increased 

potential 

Copper, 

Zinc 

Increased m

loadings and 

Current Practice (full, partial or interim cleaning; as appropriate) 

Copper, 

dissolved 

(14 of 14) 

Color, TSS, 

turbidity, floating 

material, settleable 

material 

Range from 

HI = 1 to 7.5 

Potential to 

release 

Copper, 

Zinc 

Cu = 7.5E+

Zn = 3.0E+0

Total TPE 3.8E

Type of 

Cleaning 

More Full Cleanings (fewer partial or interim cleanings) 

Copper, 

dissolved 

(14 of 14) 

Same or increased 

likelihood to 

exceed 

Increased relative 

to current practice 

Decreased 

potential 

Copper, 

Zinc 

Increased m

loadings and 

Fewer Full Cleanings (more partial or interim cleanings) 

Copper, 

dissolved 

(14 of 14) 

Same likelihood to 

exceed 

Decreased 

relative to current 

practice 

Potential to 

release 

Copper, 

Zinc 

Decreased m

loading and T

No Cleanings None None None Increased potential None None Current Practice (Selecting the proper equipment) 

Copper, 

dissolved 

(14 of 14) 

Color, TSS, 

turbidity, floating 

material, settleable 

material 

Range from 

HI = 1 to 7.5 

Potential to 

release 

Copper, 

Zinc 

Cu = 7.5E+

Zn = 3.0E+0

Total TPE 3.8E

Equipment 

Selection More Aggressive 

Copper, 

dissolved 

(14 of 14) 

Increased 

likelihood to 

exceed 

Increased HI 

values 

Increased 

potential 

Copper, 

Zinc 

Increased m

loadings and 

Less Aggressive 

Decreased 

exceedances 

of copper 

Decreased 

likelihood to 

exceed 

Decreased HI 

values 

Increased 

potential 

Copper, 

Zinc 

Decreased m

loadings and 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

3.2.1 Discharge Comparison to Criteria 

In the comparison of constituent data to numeric WQC, deviations resulting from cleaning more 

or less frequently may increase or decrease numeric or narrative WQC exceedances. Copper 

releases are expected to continue to exceed the same 14 numeric WQC by approximately the 

same magnitude regardless of deviations. For zinc, releases are still not expected to exceed any 

numeric WQC. 

Criteria for Cleaning 

More frequent hull cleanings would likely result in similar concentrations of paint constituents 

and thus would not affect the likelihood of causing an exceedance of copper criteria. It is 

expected that the concentration of biofouling organisms, TSS, and color would decrease as a 

result of more frequent cleanings because the hull would have less accumulation of biofouling 

when the cleaning occurred. Therefore, increased cleaning frequencies would be expected to 

result in a lower likelihood of causing narrative criteria exceedances for color and total 

suspended solids. Conversely, less frequent hull cleanings would be expected to increase the 

likelihood of causing an exceedance in narrative criteria due to the removal of the accumulated 

biofouling on the hull. 

Type of Cleaning 

The decision about the type of cleaning to conduct (partial, interim or full) depends on the degree 

of biofouling identified, along with other factors such as ship size, mission, and schedule. 

Performing a full cleaning rather than a partial or interim cleaning would not be expected to 

affect the concentration of paint constituents discharged into the water column. The 

concentrations discharged would be expected to be similar to the baseline concentrations, albeit 

discharged over a longer period of time (greater area of hull cleaned) the likelihood of greater 

exceedances of numeric WQC would not change. The likelihood that a full cleaning event 

would result in an exceedance of one of more narrative WQC would remain the same as the 

baseline. If a hull cleaning was not performed, the discharge would not be released and 

exceedances to numeric or narrative WQC would not result. 

Equipment Selection 

Using inappropriate equipment to clean a hull may result in poor cleaning performance. Using a 

more aggressive brush or inappropriate equipment for the level of biofouling can damage the hull 

coating by increasing the amount of hull coating material and paint particulates discharged into 

the environment. Whereas, the use of a less aggressive brush or inappropriate equipment may 

not remove all of the materials present on the hull. The likelihood of exceeding additional 

numeric WQC for hull cleanings conducted with inappropriate equipment is not expected. In 

addition, similar exceedances of one of more narrative WQC, such as color and TSS, may result 

when cleaning with inappropriate equipment (e.g., a more aggressive brush). Using a less 

aggressive brush would likely decrease the amount of biofouling and constituents discharged into 

the water column. However, the likelihood of exceeding numeric WQC would not be affected 

and the likelihood of exceeding one of more narrative WQC would decrease. 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

3.2.2 Discharge Toxicity (Hazard Index) 

Because the baseline discharge is the same as the MPCD discharge, actual HI calculations for the 

USHMP MPCD option will be the same as the baseline discharge (current practice). The mixing 

of the discharge with the background receiving water is driven primarily by the flow of water 

from the hull cleaning system, tidal flow of the surrounding waters, and wind-induced currents. 

Criteria for Cleaning 

The mixing factors listed above are not affected by the frequency of cleaning. Discharge 

concentrations of copper and zinc are not expected to change due to an increase or decrease in 

cleaning frequency, the HI is expected to be in the same range at the EOMZ (ranging from HI = 

1 to 7.5) regardless of the cleaning frequency. 

Type of Cleaning 

The type of cleaning (e.g., full, partial, or interim) does not affect the mixing of the discharge. 

Therefore, changes from current practices are not expected to change the EOMZ concentrations 

of copper or zinc. It is expected that the HI at EOMZ will be the same (ranging from HI = 1 to 

7.5) regardless of the type of cleaning. If no hull cleanings were performed, no release of a 

discharge would occur and the toxicity would be zero. 

Equipment Selection 

The type of brush (more aggressive versus less aggressive) or equipment selected for cleaning 

does not affect the mixing of the discharge in the receiving water. It is expected that the EOMZ 

HI would be the same (ranging from HI = 1 to 7.5) regardless of the equipment selected. Use of 

more aggressive equipment may increase the quantity of biofouling and constituents released and 

may increase HI values. Hull cleanings performed using a diver operated hand-held device 

would not result in the same degree of initial water flow as seen from a typical multi-brush unit 

(e.g., the SCAMP utilizes an impeller to position on the hull and to flush the debris away from 

the brushes at approximately 1.3E+04 gpm); however, the use of less aggressive equipment may 

result in a decreased HI value due to the surrounding waters tidal flows and wind-induced 

currents. 

3.2.3 Nonindigenous Species Release 

Cleaning operations have the potential to cause the release of nonindigenous species; however 

the potential is expected to be the same for the USHMP as the characteristics of the baseline 

discharge (current practices). Regular hull cleanings may decrease the transmission of 

nonindigenous species. A fouled hull is more likely to provide habitat (and transport) for new 

organisms than a clean hull. A hull that is cleaned before deployment and operated continuously 

(as vessels on deployment are) provides a hull surface that is more resistant to attachment by 

organisms and is less likely to return to U.S. waters fouled with unwanted species from other 

ports. 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

Criteria for Cleaning 

Hull cleaning operations are designed to remove organisms that colonize on the hull surface in 

spite of the biocidal properties of copper-containing antifouling paint. Nonindigenous species 

can be introduced from hulls that have not been cleaned adequately or frequently enough, and 

consequently have well-developed biofouling communities adhering to the hull. The potential to 

release nonindigenous species is expected to be small when hull cleanings are conducted at 

sufficiently frequent intervals. It is uncertain whether more frequent hull cleanings would pose 

an increased or decreased risk of NIS introduction. Cleanings performed less frequently would 

allow a greater degree of species colonization to occur on the hull. It is anticipated that increased 

growth and colonization on the hull would increase the potential for nonindigenous release. 

Type of Cleaning 

Nonindigenous species can be introduced from hulls that have not been cleaned adequately or 

frequently enough, and consequently have well-developed biofouling communities adhering to 

the hull. A reduction in the potential to release nonindigenous species is expected when proper 

hull cleanings are conducted. The type of cleaning conducted (partial, interim or full) is 

dependent upon the degree of biofouling identified, along with other factors such as ship size, 

mission, and schedule. Performing a full cleaning would result in a cleaning of the entire hull, 

increasing the effectiveness of the hull coating, thereby reducing the growth of organisms on the 

hull and reducing the potential for nonindigenous species release. Conducting a full cleaning 

when a partial or interim cleaning is more appropriate would increase the amount of unfouled 

hull area cleaned, but should not affect the potential to introduce nonindigenous species. If hull 

cleanings are not conducted, no discharge would result and NIS would not be released by the 

cleaning process. However, a fouled hull is more likely to carry nonindigenous species from 

port to port, and is more likely to provide a receptive environment for new attachment of 

additional species. 

Equipment Selection 

A reduced potential to release NIS is expected when hull cleanings are conducted using the 

proper equipment. Inappropriate equipment selection may increase the amount of paint particles 

and TSS released into the marine environment and damage the hull coating. Inadequately 

cleaned hulls can result in well-developed biofouling communities adhering to the hull, 

increasing the potential to introduce nonindigenous species. An aggressive cleaning device may 

remove biofouling adhered to the hull. The majority of tubeworms, barnacles, and grasses found 

on the hull surface are destroyed in the hull cleaning process. In contrast, less aggressive device 

applied to hard biofouling will not completely remove the growth on the hull. Organisms may 

remain on the hull, increasing the potential for nonindigenous species release, as the organisms 

would not be removed sufficiently from the hull and may continue to develop and/or reproduce 

on the hull. 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

3.2.4 Bioaccumulative Contaminants of Concern 

Because copper and zinc are the only two BCCs identified in this discharge, these constituents 

are expected to remain in the discharge regardless of the changes to cleaning criteria, cleaning 

type, or equipment selected. 

3.2.5 Constituent Mass Loading and Toxic Pound Equivalents 

Deviations from the current practice may result in an increase or decrease to mass loadings and 

TPE values. 

Criteria for Cleaning 

While hull cleaning creates an initial release of copper and zinc, the mass loadings from the 

discharge may change if cleanings are performed at significantly greater or lesser foul ratings. A 

hull that is not regularly cleaned near to FR-40 is susceptible to coating degradation and may 

require more frequent hull coating applications. The vessel would spend more time with a new 

hull coating and its correspondingly higher leach rate. 

The Navy Marine Environmental Support Office (MESO) conducted tests in San Diego Bay of 

hulls painted with ablative coatings to generate release rates for copper (Navy, 2002b). Static 

testing was conducted using stationary steel panels, while rotating steel drums were used for 

dynamic testing. The ChAR: Hull Coating Leachate describes the estimated release rates using 

the information from the MESO report and MSDS paint lists (Navy and EPA, 2003e). The 

copper leachate rate from the hull coating system decreases significantly over time. More 

frequent hull cleanings may increase the amount of biofouling and constituents released into the 

marine environment over time, which potentially could increase the mass loading of copper. 

Less frequent hull cleanings may create an increase in mass loadings of copper, as greater 

amounts of growth on the hull and coating system materials would be removed. In addition, less 

frequent cleanings will increase the likelihood of coating system failures requiring removal and 

reapplication of the coating system resulting in a higher release rate. 

Type of Cleaning 

The type of cleaning conducted (partial, interim or full) is dependent upon the degree of 

biofouling identified, along with other factors such as ship size, mission, and schedule. Cleaning 

the hull unnecessarily by performing a full cleaning in situations where a partial or interim 

cleaning is sufficient would increase the amount of biofouling and constituents released into the 

marine environment, and thus increasing TPE and mass loadings in receiving waters. If 

cleanings were not conducted, no discharge would be released. 

Equipment Selection 

Inappropriate equipment selection may affect the amount of discharge constituents released into 

the marine environment. Inappropriate hull cleanings can increase the amount of coating 

discharged into the environment if a more aggressive device is applied to a fouled hull; thereby 

increasing the biofouling and constituents released into the marine environment, and thus 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

increasing TPE and mass loadings in receiving waters. Using a less aggressive device may not 

completely clean the fouled area, thereby decreasing the amount of biofouling and constituents 

released and reducing TPE and mass loading. 

3.2.6 Other Potential Environmental Impacts 

Deferring hull cleaning operations will allow an increase in biofouling. Biofouling increases 

vessel drag, thereby decreasing vessel speed and increasing fuel consumption. Increased fuel 

consumption may cause air quality impacts from the resulting increased engine emissions. 

Unnecessary or inappropriate cleanings may also create an increase in biofouling and 

constituents released and may cause damage to the hull coating system and shorten the coating 

life, thus requiring more frequent drydocking and hull coating applications. An increase in the 

frequency of coating applications may cause air quality impacts as well as increased discharges 

associated with the drydocking process. Hull coating reapplications would require more frequent 

use of paint equipment (adding to fuel consumption and exhaust emissions) and may release 

additional VOCs into the air. In addition, more frequent hull coating applications would increase 

the amounts of copper leaching after each reapplication. Refer to the EEAR: Hull Coating 

Leachate for additional information about impacts resulting from the application of new 

antifouling paint (Navy and EPA, 2003d). 

The total suspended solids released by the discharge, such as paint particulates and biofouling 

habitats (i.e., barnacle, tube worm and oyster shells), settle in the sediment close to where the 

hull cleaning operations are conducted. Unnecessary hull cleanings or inappropriate equipment 

selection may increase the amount of paint constituents released to the sediment. Cleaning less 

frequently is expected to increase the likelihood of experiencing significant biofouling, which in 

turn, may also increase the load of sediment to the local environment. In addition, the suspended 

paint particles discharged into the environment have the potential to leach copper into the water 

column due to the increased surface area of the particles discharged. Results of limited studies 

conducted on the time dependency of dissolved copper concentrations in samples of effluent 

collected during hull cleaning operations suggest that a potential may exist for increased 

dissolved copper concentrations within 20 minutes of the cleaning process (Hertel et al., 2001). 

The contribution of this effect on dissolved copper concentration in the water column proximate 

to the ship is unknown; however, the toxicity associated with any increase may be reduced or 

mitigated by natural complexation (Zirino and Seligman, 2002). 

3.2.7 Summary of Environmental Effects 

In summary, deviations from the current practice (or USHMP) are: 

• Not expected to result in any additional numeric WQC exceedances for dissolved copper 

(14 of 14) or zinc (no exceedances) if cleanings were conducted more or less frequently 

or if full cleanings were conducted. (Note: Discharge is likely to exceed additional 

numeric WQC for dissolved copper and zinc if equipment selected is more aggressive.) 

• More likely to result in additional narrative WQC exceedances (five) if hulls are cleaned 

less frequently or with inappropriate equipment. 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

• Likely to increase HI values if inappropriate equipment is selected. 

• More likely to introduce NIS if hulls are cleaned less frequently, hulls are not cleaned, or 

with inappropriate equipment selection. 

• It is uncertain if cleaning more frequently poses an increased or decreased risk of NIS 

introduction. 

• Will not affect the number or type of BCCs (copper and zinc). 

• Likely to increase mass loadings of copper and zinc if hulls are cleaned more frequently, 

if full cleanings are conducted, or with inappropriate equipment selection. 

4.0 UNCERTAINTY ANALYSIS 

As discussed in the ChAR: UWSH, there is wide variability in the composition of the ship 

husbandry discharge (Navy and EPA, 2003b). This variability is due to many factors, including 

degree and variety of hull biofouling, variation in cleaning types, age of the vessel and coating 

system, and variations in equipment/operator reliability. Due to these many factors, sampling 

obtained from earlier Navy research studies were used as a “snapshot” of the discharge 

composition, which was then used to complement available process knowledge. 

4.1 EXCEEDED WATER QUALITY CRITERIA 

Copper concentration data was obtained from Navy research studies. These studies include 

results from San Diego Bay waters sampled before, during, and after underwater hull cleaning 

operations. The measurement of dissolved copper at any one point is transitory, as the water 

mass moves with the tide and wind-induced currents and particulate concentrations will vary 

significantly with time and over short distances. Furthermore, copper is found in receiving 

waters as a “background” contaminant. Sampling values taken prior to hull cleaning operations 

illustrate that the San Diego Bay waters exceeded numeric WQC (specifically for copper) before 

the hull cleaning operation was performed (Navy, 1994; Navy, 2002b). 

4.2 DISCHARGE HAZARD INDEX 

The HI approach used in this environmental effects analysis estimates the aggregate toxicity of a 

baseline discharge. The uncertainty of HI values is primarily based on (1) the uncertainty in 

sample data both from receiving water studies and hull coating loss rate analyses and (2) the 

methodology for determining EOMZ concentrations. The variability associated with the sample 

data is due largely to the variability of local conditions, including hull size and configuration, age 

of paint, tidal conditions, temperature, etc. The uncertainty associated with the mass dilution 

method can be characterized as an overly simplified approach – “real world” mixing is not 

performed in a uniform fashion and all constituents are not discharged instantaneously. The 

uncertainty associated with the discharge model can be attributed to the fact that the model is a 

virtual harbor and does not portray an actual harbor. In addition, the model verification for the 

leachate analysis is limited. For more information on the HI method, refer to Method for 

Assessing the Toxicity of Multiple Contaminants in Discharges from Vessels of the Armed Forces 

Uniform National Discharge Standards (Navy and EPA, 2001b). 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

4.3 NONINDIGENOUS SPECIES RELEASE 

The potential to introduce NIS is expected to be minimized when hull cleanings are conducted at 

proper times. Cleaning a hull prior to a long deployment should provide a surface that is more 

resistant to attachment by organisms, making the hull less likely to carry unwanted organisms, 

especially larger species and mature organisms that are more likely to reproduce than younger 

organisms. The uncertainty associated with the release of NIS is attributed to the variability in 

the colonization and organization of marine organisms on the hull surface. A few factors 

contributing to the variety of marine growth include the vessel location (waterbody), depth of 

hull, and effect of hull coating biocidal properties. In addition, the variability of the receiving 

waters (i.e., water temperatures, season, tidal flow) can affect the potential for invasion by a 

nonindigenous species. 

4.4 BIOACCUMULATIVE CONTAMINANTS OF CONCERN 

Two reduction BCCs, copper and zinc, were identified for the discharge. There is little 

uncertainty related with the identification of the BCCs reported as the these are the only BCCs 

present in the MSDS paint lists for the hull coatings applied to Armed Forces vessels. The only 

uncertainty with this approach is the dependence on the MSDS paint list information, which is 

not comprehensive. 

4.5 CONSTITUENT MASS LOADING AND TOXIC POUND EQUIVALENTS 

As described in the EEA guidance manual, mass loading and TPEs of the baseline discharge 

were calculated for each discharge constituent (Navy and EPA, 2000b). Both the mass loading 

and TPE calculations are functions of the constituent concentrations and annual discharge 

volumes. The uncertainty associated with the constituent concentration values is due to the 

naturally occurring variability in the ship husbandry discharge composition. For more 

information about the uncertainty associated with the discharge, refer to the ChAR: UWSH, 

which provides details on the assumptions made to determine the generation rates (Navy and 

EPA, 2003b). 

4.6 OTHER POTENTIAL ENVIRONMENTAL IMPACTS 

As mentioned previously, the characterization and frequency of the ship husbandry discharge is 

widely variable (Navy and EPA, 2003b). This variability is due to many factors, including 

degree and variety of hull biofouling, variation in cleaning types, age of the vessel and coating 

system, and variations in equipment/operator reliability. The uncertainty associated with benthic 

impacts includes the dynamics of the receiving water and sediments (deposition, redistribution, 

and export rates and patterns), the physico-chemical conditions of both water and sediments 

(parameters such as particle size distributions, pH and redox states, dissolved and particulate 

organic matter), operational details related to the cleaning activities, and the contributions from 

other UNDS and non-UNDS sources. Copper released from the UWSH discharge may settle to 

the bottom as sediment; however, it is unclear what the impacts of sediment containing copper 

may pose. The uncertainty associated with air impacts may include the operational aspects of 

repainting (e.g., occurrence in non-attainment areas), controls for VOC emissions, and weather 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

conditions (Shaner, 2003). All of these factors contribute to other potential environmental 

effects and the uncertainty of these effects. 

4.7 CONCLUSION 

Variations from the management plan may increase the potential to exceed WQC (narrative and 

numeric) and may show an increase in toxicity, mass loadings, and the potential to introduce 

nonindigenous species. Conducting underwater ship cleaning in accordance with the practices in 

the management plan (USHMP) minimizes impacts to receiving waters while balancing the 

necessity and feasibility of cleaning hulls of Armed Forces vessels. Performing hull cleanings at 

the prescribed intervals, based on environmental considerations and feasible and practical 

solutions, such as biofouling rating guidelines, cleaning types, appropriate equipment, and 

trained divers is the best practice to mitigate the discharge. 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

5.0 REFERENCES 

40 CFR 1700.4. 1999. Uniform National Discharge Standards for Vessels of the Armed Forces. 

Phase I Final Rule. 10 May 1999. 

Brent, R. 2001. Whole Effluent Toxicity Test Analysis for the Uniform National Discharge 

Standards Program. DynCorp Information & Enterprise Technology, Inc. Alexandria, 

VA. 19 February 2001. 

EPA. 1991. Technical Supporting Document for Water Quality-based Toxics Control. U.S. 

Environmental Protection Agency, Office of Water, Washington, DC. EPA/505/2-90-

001. March 1991. 

EPA and DoD. 1999. Phase I Uniform National Discharge Standards for Vessels of the Armed 

Forces: Technical Development Document. U.S. Environmental Protection Agency, 

Office of Water, Washington DC. EPA 821-R-99-001. 

Hertel, W., M. Klinkhammer, and E. Haslbeck. 2001. Characterization of Effluent From Navy 

Advanced Underwater Hull Cleaning Vehicle Operations Conducted on USS SAIPAN 

(LHA 2). Naval Surface Warfare Center, Carderock Division, Code 632 (Pollution 

Prevention & Material Safety Branch), Bethesda, MD. NSWCCD-63-TR-2001/57. June 

2001. 

Klinkhammer, M. 2003. Email to Mr. Gordon Smith, Naval Sea Systems, Washington, D.C., 

from Mr. Michael Klinkhammer, Naval Surface Warfare Center, Carderock Division, 

Code 632 (Pollution Prevention & Material Safety Branch), Bethesda, MD. Re: Settling 

rate narrative. 8 May 2003. 

McCue, T. 2002a. The Frequency of Ship Husbandry Non-Cleaning Activities. Naval Sea 

Systems Command, Code 00C, Washington, DC. December 2002. 

McCue, T. 2002b. Meeting with Mr. Thomas McCue of Naval Sea Systems Command, Code 

00C, Washington, DC. 21 November 2002. 

McCue, T. 2003. Rationale for Changing Cleaning Guidance in NSTM Chapter 081. Naval Sea 

Systems Command, Code 00C, Washington, DC. January 2003. 

Navy. 1981. Draft Environmental Statement for the In Situ Removal of Marine Fouling 

Organisms from Naval Ships. Naval Ocean Systems Center Code 5132, San Diego, CA. 

June 1981. 

Navy. 1994. Environmental Effects from In-Water Hull Cleaning of Ablative Copper 

Antifouling Coatings. Technical Document 2662. Naval Command, Control and Ocean 

Surveillance Center RDT&E Division, San Diego, CA. July 1994. 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

Navy. 2001. Characterization of Effluent from Navy Advanced Underwater Hull Cleaning 

Vehicle Operations Conducted on USS SAIPON (LHA-2). Naval Sea Systems 

Command, SEA 05R24. June 2001. 

Navy. 2002a. Waterborne Underwater Hull Cleaning of Navy Ships. Naval Ships’ Technical 

Manual Chapter 81. Naval Sea Systems Command, Washington, DC. S9086-CQ-STM010/CH-81R4. 01 April 2002. 

Navy. 2002b. Copper Release Rate Findings from USS RENTZ (FFG-46) Hull Coatings Study 

April 20-30 2002. U.S. Navy, Marine Environmental Support Office, 

SPAWARSYSCEN 23621, San Diego, CA. 24 July 2002. 

Navy and EPA. 2000a. Development of Vessel Groups and Selection of Representative Vessels 

for Feasibility and Environmental Effects Analyses. U.S. Navy, Naval Sea Systems 

Command, Washington, DC and U.S. Environmental Protection Agency, Office of 

Water, Washington, DC. 19 September 2000. 

Navy and EPA. 2000b. Environmental Effects Analysis Guidance for Phase II of the Uniform 

National Discharge Standards for Vessels of the Armed Forces. U.S. Environmental 

Protection Agency, Office of Water, Washington, DC and U.S. Navy, Naval Sea Systems 

Command, Washington, DC. November 2000 (Draft). 

Navy and EPA. 2001a. Method for Assessing the Toxicity of Multiple Contaminants in 

Discharges from Vessels of the Armed Forces Uniform National Discharge Standards 

(UNDS) Phase II. U.S. Environmental Protection Agency, Office of Water, Washington, 

DC and U.S. Navy, Naval Sea Systems Command, Washington, DC. 2001. 

Navy and EPA. 2003a. Frequency of Non-Cleaning Maintenance Activities White Paper. U.S. 

Navy, Naval Sea Systems Command, Code 05M4, Washington, DC and U.S. 

Environmental Protection Agency, Office of Water, Washington, DC. July 2003. 

Navy and EPA, 2003b. Characterization Analysis Report: Underwater Ship Husbandry. U.S. 

Navy, Naval Sea Systems Command, Washington, DC and U.S. Environmental 

Protection Agency, Office of Water, Washington, DC. July 2003. 

Navy and EPA. 2003c. Discharge Assessment Team (DAT) Meeting Minutes. U.S. Navy, 

Naval Sea Systems Command, Washington, DC and U.S. Environmental Protection 

Agency, Office of Water, Washington, DC. Meeting held on 27 March 2003. 

Navy and EPA. 2003d. Environmental Effects Analysis Report: Hull Coating Leachate. U.S. 

Navy, Naval Sea Systems Command, Washington, DC and U.S. Environmental 

Protection Agency, Office of Water, Washington, DC. Version 1, February 2003. 

Navy and EPA. 2003e. Characterization Analysis Report: Hull Coating Leachate. U.S. Navy, 

Naval Sea Systems Command, Washington, DC and U.S. Environmental Protection 

Agency, Office of Water, Washington, DC. Version 1, February 2003. 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

Navy and EPA. 2003f. Vessel Grouping: Underwater Ship Husbandry. U.S. Navy, Naval Sea 

Systems Command, Washington, DC and U.S. Environmental Protection Agency, Office 

of Water, Washington, DC. February 2003. 

Shaner. 2003. E-mail to Ms. Jennifer Salerno, Booz Allen Hamilton, Arlington, VA, from Mr. 

Steven Shaner, Booz Allen Hamilton, San Diego, CA. Re: UWSH EEAR. 13 May 

2003. 

Shimko. 2003a. Email to Ms. Kimberly Robertson, Booz Allen Hamilton, Arlington, VA from 

Mr. Michael Shimko, M. Rosenblatt and Son/AMSEC, Inc., Washington, DC. Re: Foul 

release coatings. 3 July 2003. 

Shimko. 2003b. E-mail to Ms. Kimberly Robertson, Booz Allen Hamilton, Arlington, VA from 

Mr. Michael Shimko, M. Rosenblatt and Son/Washington, DC. Re: Volatile Organic 

Compound Emissions. 11 February 2003. 

SPAWAR. 2003. Model Run: Underwater Ship Husbandry for CVN-68. May 2003. 

Zirino, A. and P.F. Seligman, eds. 2002. Copper Chemistry, Toxicity, and Bioavailability and 

Its Relationship to Regulation in the Marine Environment. Technical Document 3140. 

Office of Naval Research Second Workshop Report. SSC San Diego, CA. August 2002. 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

APPENDIX A NARRATIVE WATER QUALITY CRITERIA ANALYSIS 

FOR UWSH UNDERWATER SHIP CLEANING 

DISCHARGE 

Narrative 

Criteria Characterization Category 

Category Data EEA Endpoint Evaluation Determination Rationale 

Discharges to Saltwater 

BOD/DO Biological Oxygen 

Demand (BOD5) 

= 2.6 E-03 mg/L 

The discharge shall not depress 

receiving water dissolved oxygen 

concentration (1) by more than 

10%, or (2) to a level that 

produces nuisance conditions. 

PASS The discharge passes the category 

because it has the potential to exceed 

receiving water DO levels by more 

than 10%. Receiving water BOD 

impacts were approximated by the 

dilution factor (1.89) to the EOP BOD 

level (2.6 mg/L). Assuming the BOD is 

fully consumed, the reduction in DO 

(1.38 mg/L) does not exceed the 

minimum allowable 10% reduction 

(1.42 mg/L) to below established 

endpoints [2.3 mg/L, Ambient Aquatic 

Life WQC for DO (saltwater): Cape 

Cod to Cape Hattaras. EPA Nov. 

2000]. 

Color Milky with tint of 

black or red 

depending on 

coating system 

The discharge shall not (1) exceed 

15 color units at EOP, and (2) 

exceed natural conditions or be 

visually noticeable in the receiving 

FAIL The discharge fails the category 

because process knowledge indicates 

the discharge is cloudy with a tint of 

color in the receiving water. 

water. 

Floating Paint chips and The discharge shall not release or FAIL The discharge fails the category 

Materials particulates create floating solids in the because process knowledge indicates 

receiving waters. the discharge is has the potential to 

release soft fouling, paint particles and 

particulates in the receiving water. 

Nutrients The discharge shall not exceed 

300 μg/L total nitrogen (nitrate + 

nitrite + KJN), 10.0 μg/L of 

ammonia nitrogen, 15 μg/L nitrate 

PASS The discharge passes the category 

because sample data and process 

knowledge do not indicate the 

presence of nutrients. 

+ nitrite, or 60.0 μg/L of total 

phosphorus at EOP 

Odor Cu = 7.7E+00 μg/L 

Zn = 2.9E+00 μg/L 

The discharge shall not (1) impart 

unpalatable flavor to food fish or 

(2) result in offensive odors in the 

PASS The discharge passes the category 

because process knowledge does not 

indicate the presence of an odor and 

vicinity of the receiving water. do not exceed organoleptic criteria. 

Oil & Grease Not measured The discharge shall not (1) have 

an EOP concentration of bulk oil 

and grease greater than 5 mg/L; 

(2) cause receiving water EOMZ 

concentration of bulk oil and 

PASS The discharge passes the category 

because process knowledge does not 

indicate the presence of oil and 

grease. 

grease greater than 15 μg/L; or (3) 

cause a sheen anywhere in the 

receiving water. 

Pathogens Not measured The discharge shall not cause 

receiving water to exceed at the 

EOMZ: (1) a geometric mean of 8 

enterococci/100 ml or an 

instantaneous level of 54 

PASS The discharge passes the category 

because process knowledge does not 

indicate a problem or concern with 

pathogens. 

enterococci/100 ml; (2) a 

geometric mean of 126 E. coli/100 

ml or an instantaneous level of 

406 E. coli/100 ml; or (3) 50 fecal 

coliform/100 ml by any measure 
DRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003 

Narrative 

Criteria Characterization Category 

Category Data EEA Endpoint Evaluation Determination Rationale 

Settleable Paints, biofouling The discharge shall not release FAIL The discharge fails the category 

Materials organic matter, and settleable materials other than of because process knowledge indicates 

particulates local and natural origin. the discharge is has the potential to 

release paint particles and particulates 

in the receiving water. 

Suspended Total Suspended The discharge shall not exceed FAIL The discharge fails the category 

Solids Solids = 2.7E-02 25-mg/L daily average or 45 mg/L because the EOP concentration (27 

mg/L daily maximum concentrations of mg/L) exceeds the daily average 

TSS. endpoint of 25 mg/L. 

Taste Cu = 7.7E+00 μg/L 

Zn = 2.9E+00 μg/L 

The discharge shall not impart 

unpalatable flavor to food fish, 

shellfish, and wildlife. 

PASS The discharge passes the category 

because process knowledge does not 

indicate the presence of a taste. 

Organoleptics were not tested for this 

discharge. 

Temperature Ambient The discharge shall not cause the PASS This discharge passes the category 

EOMZ temperature to increase because the discharge is expected to 

>0.3°C. approximate the ambient temperature 

of the receiving waters. The discharge 

is not expected to change ambient 

water temperature upon release. 

Turbidity/ Transparency = Turbidity of the discharge, FAIL The discharge fails the category 

Colloidal Not measured including that caused by colloids, because process knowledge indicates 

Matter Turbidity = 

Not measured 

shall not be (1) visually noticeable 

in the receiving waters; (2) 

turbid conditions (cloudy/milky). 

deposited to such an extent that it 

will detrimentally affect bottom or 

shoreline biota; and (3) produce a 

substantial increase in turbidity.