### 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-06-01 2



# DRAFT Environmental Effects Analysis Report Underwater Ship Husbandry

August 2003

## DRAFT

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 AgencyDRAFT

TABLE OF CONTENTS

1.0 INTRODUCTION

............................................................................................................... 1

2.0 SUMMARY OF EEA METHODOLOGY

........................................................................ 2

3.0 SUMMARY OF EEA RESULTS

....................................................................................... 3

3.1 B ASELINE D ISCHARGE (C URRENT P RACTICE )

............................................................ 4

3.1.1 Discharge Character ization Data

................................................................................... 4

3.1.2 Discharge Comparison to Criteria

................................................................................. 4

3.1.3 Discharge Toxicity (Hazard Index)

............................................................................... 5

3.1.4 Nonindigenous Sp ecies Release

.................................................................................... 6

3.1.5 Bioaccumulative Contaminants of Concern

.................................................................. 7

3.1.6 Constituent Mass Loading and To xic Pound Equivalents

............................................. 7

3.1.7 Other Potential Environmental Impacts

......................................................................... 8

3.1.8 Summary of Environmental Effects

............................................................................... 9
3.2 U NDERWATER S HIP H USBANDRY M ANAGEMENT P LAN (USHMP) MPCD

............ 10

3.2.1 Discharge Comparison to Criteria

............................................................................... 12

3.2.2 Discharge Toxicity (Hazard Index)

............................................................................. 13

3.2.3 Nonindigenous Sp ecies Release

.................................................................................. 13

3.2.4 Bioaccumulative Contaminants of Concern

................................................................ 15

3.2.5 Constituent Mass Loading and To xic 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 E XCEEDED W ATER Q UALITY C RITERIA
................................................................... 17

4.2 D ISCHARGE H AZARD I NDEX
...................................................................................... 17

4.3 N ONINDIGENOUS S PECIES R ELEASE

.......................................................................... 18

4.4 B IOACCUMULATIVE C ONTAMINANTS OF C ONCERN
................................................. 18

4.5 C ONSTITUENT M ASS L OADING AND T OXIC P OUND E QUIVALENTS

......................... 18

4.6 O THER P OTENTIAL E NVIRONMENTAL I MPACTS

...................................................... 18

4.7 C ONCLUSION

.............................................................................................................. 19

5.0 REFERENCES

.................................................................................................................. 20

APPENDIX A NARRATIVE WATER QUALITY CRITERIA ANALYSIS FOR UWSH UNDERWATER SHIP CLEANING DISCHARGE

......................................... 23DRAFT

LIST OF TABLES

Table 3-1. Constituents of Concern Identified in the Baseline Discharg e 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 Concentr ations (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 Cons tituents 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

........................................................................ 1 1DRAFT

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 Z one (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 Hu sbandry Management Plan
UWSH Underwater Ship Husbandry VOC Volatile Organic Compound WQS Federal Water Quality Standards or State Water Quality CriteriaDRAFT



### 1.0 INTRODUCTION

The Armed Forces perform hull cleaning operations to remove fouling organisms (i.e., biofouling) that have adhered to the underwat er 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, mate rials 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 cont ribute 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 remain ing seven activities identified in the Phase I TDD Nature of Discharge (NOD) report (i.e., fiberglass repair, we lding, 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 re sult in small discharge am ounts of a nature that results in a low potential for environmental e ffect (Navy and EPA, 2003a). Based on that determination, this environmental effects an alysis (EEA) addresses only underwater hull cleaning operations for the UWSH discharge.

The Navy usually conducts full hu ll cleanings when a fouling rating of FR-40 or greater is observed over 20 percent of the hu ll. 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 evid enced (e.g. speed degradation; fuel efficiency decrease). Additional information on hull clea nings and fouling ratings can be found in the Characterization Analysis Report (ChAR): UWSH (Navy and EPA, 2003b).

While there are several types of antifouling coat ings on the market, two types of coatings are approved for use on the hulls of Armed Forces vessels: (1) copper-con taining antifouling coatings and (2) “foul-release” ( non-biocide) coatings. The majo rity of Armed Forces vessel hulls are coated with copper-containing antifouli ng 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-con taining coatings. The vessels with foul-release or adva nced 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) dr ydock cycles less than five years, or (3) vessels th at have specialized acoustic pe rformance 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 evalua ted (Navy and EPA, 2003c). Additional information on the types of coatings, their a pplication, 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).DRAFT

The Phase I NOD report in the TDD identified only copper and zinc as co nstituents of concern for copper antifouling coating systems (EPA and DoD, 1999). In addition, data from previous Navy environmental re ports, 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 Vehicl e Operations Conducted on USS Saipon (LHA-2) (Navy, 2001), were used to characterize the UW SH discharge generated during hull cleaning operations. These reports provide sampling data collected during typi cal Navy underwater hull cleaning operations occurring piersi de. 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 op erated by divers. Data from the samples include chemical constituent concentrations; field measuremen ts of pH, biological oxygen demand (BOD), and total suspended solids (TSS). Samples were taken before, during, and after hull cleaning operations. Discharge characte rization was also supplemente d by process knowledge provided by Navy equipment experts. Details on the characte rization of this discharg e are contained in the Underwater Ship Husbandry ChAR (Navy and EPA, 2003b).

The USHMP provides for comprehensive contro l of materials disc harged during UWSH cleaning operations. The USHM P 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), appropr iate 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 “v essels cleaned while afloat” . A representative vessel cla ss 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 Vess els for Underwater Ship Husbandry (Navy and EPA, 2003f) for additional informa tion. Vessel grouping methodology is discussed further in the Development of Vessel Groups and Selec tion of Representative Vessels for Feasibility and Environmental Effects Analyses guidance document (Navy and EPA, 2000).

For the purpose of this EEA, the baseline disc harge (current practice) for the hull cleaning discharge is considered the same as the USHM P MPCD option. The resu lts presented in this report are based on the quantitative and qualitati ve 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, me thodology, and management practices.

Because the UWSH discharge is not released from a pipe, end- of-pipe (EOP) concentration is not directly applicable. Howeve r, to facilitate analysis, the DAT defined a surrogate resultant concentration as the increase in receiving water concentra tion adjacent to the hull over background (ambient) that result from the hu ll cleaning operations. This increase inDRAFT

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 bi ologically available (Z irino 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 co pper 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 conc entrations 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 av erage 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 formul ation, it provides the be st available approach for estimating dissolved zinc from dissolved copper concentrations. Use of this ratio implies that zinc is found in receiving waters surrounding vesse ls being cleaned in approximately the same ratio as zinc is found in antifouling paints prior to application (E PA and DoD, 1994).

Because of limited field data, alternative EO MZ 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 receivin g 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 mix ing 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 calculati ons. Annual mass loadings of copper and zinc were determined for all vessels that are cleaned during a typi cal year. Copper mass loadings were assumed to be identical among all clean we tted surface areas of vess el hulls. Calculated data are presented in the ChAR: UWSH (Navy and EPA, 2003b).

Methods for the evaluation of UWSH discha rge of nonindigenous spec ies (NIS) release, bioaccumulative contaminants of concern (BCC), and other potential environment impacts are identical to those presented in the Environmental Effects A nalysis Guidance Manual (EPA and Navy, 2000).



### 3.0 SUMMARY OF EEA RESULTS

This section summarizes the resu lts of the eight technical anal yses conducted for the baseline discharge (with current practices employed). The USHMP discharge is the same as the baselineDRAFT

discharge. Section 3.1 describes the baseline EEA. Section 3.2 describes the USHMP sensitivity analysis on the environmental bene fits of the current process.

3.1 B ASELINE D ISCHARGE (C URRENT P RACTICE )

The baseline discharge is defined as the release of constituents to the receiving water that occurs during the cleaning of hulls coated with antif ouling hull coating systems (i.e., copper-containing antifouling coating systems), when the cleani ng is conducted according to NSTM Chapter 081. These guidelines require that hull cleaning is performed unde r 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 ve ssels undergoing underwater hull cleanings were assembled from samples collected during hull cl eaning operations of several Navy vessels and supplemented by process knowledge from Navy equipm ent experts. The data analysis for this discharge identified two constituen ts 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 qual ity 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 disc harge characterization data (Navy and EPA, 2003b).

3.1.2 Discharge Comparison to Criteria

Sampling data and Navy process knowledge (N avy, 1994; Navy, 2001) was used to compare the UWSH discharge to Federal and State WQC. Vesse ls that produce UWSH discharge operate in saltwater and freshwater. However, hull cleanings have typically been performed at saltwaterDRAFT

ports. In the comparison of the baseline discha rge constituent data to numeric saltwater WQC, the dissolved copper values (1.1E+02 μ g/L) exceeded 14 of 14 numeric WQC (Table 3-1). The EOP concentration of dissolve d zinc did not exceed any num eric WQC (Table 3-1).

Table 3-1. Constituents of Concern Identified in the Baseline Discharge from Underwater Ship Cleanings with Compar isons to Numeric WQC

Constituents Estimated Concentration at EOP ( μ g/L) Criteria Exceeded Strictest Criterion

( μ g/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 narra tive WQC analysis incl uding 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 μ g/L] Turbidity Fail

3.1.3 Discharge Toxicity (Hazard Index)

Data from samples collected during and after se veral Navy hull cleaning ope rations were used to predict increases of dissolved c opper 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 μ g/L (above background concentration). A deta iled description is provided in the ChAR: UWSH (Navy and EPA, 2003b).

Because the dissolved copper concentration followi ng 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 di ssolved copper concen tration of 3.5E+01 μ g/L (above background at EOMZ). Samples taken between 20-50 m during a hull cleaning showed an increase in dissolved copp er concentration of 4.7E+00 μ g/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 μ g/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.DRAFT

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 ( μ g/L) Zinc, dissolved ( μ g/L)
Mass Dilution Calculati on 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 mode l method results in an HI > 1 (7.2E+00). Table 3-4 summarizes the results of the HQ and HI calcu lations 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 concentr ations above background conditions

An HI of 1.0 is the level consider ed to be protective of aquatic lif e 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]). Th e CMC is intended to protect most species most of the time (EPA, 1991). This level of pr otection is set near the concentration resulting in no observable effect on the most sensitive aquatic species, which EPA has determined will adequately protect aquatic commun ities. 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. Cons equently, cleaning operations have the potential to cause the release of nonindige nous 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 appropriateDRAFT

intervals decreases significant accumulation of or ganisms and improves the effectiveness of the antifouling coating system. Cleaning hulls at gr eater than FR-40 may increase the potential to release nonindigenous species because fouling comm unities 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 wate rs. Presently, hull cleaning operations do not consider any of these factors, and there are in sufficient data to correla te nonindigenous species release and colonization to hull cleaning operations. Hull cleanings at different fouling ratings have not been correlated with different type s 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 dur ing 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 St ate 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 c onstituents 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 cal culated 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.DRAFT

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 to tal 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 resu lting 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 fo r repainting. Limiting the need for repainting, whether small in-water recoating operations or drydocking for hull recoating reduces volatile organic compounds (VOCs) releas ed during painting operations. Painting copper-containing coatings is estimated to emit approximately 4.3E+00 pounds of VOCs per 100 ft 2 cleaned during the repainting process (Shimko, 2003b).

The discharge from cleaning operations has th e potential to release suspended solids and particulates, such as small particles from the hu ll coating and organic matter from the fouling organisms. The particles may settle to the sedi ment 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 susp ended 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 μ m) slowly settle to the bottom within 24 hours, while grass and other pl ant 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 cont ribute 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 quantit y 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 si ze of the particle wouldDRAFT

also increase the concentration as the surface area of these fine particles increase. Complexation capacity of the waterbody would in fluence the concentrations of dissolved copper that has been released from the paint particles.

However, the dissolved fraction of copper is likel y 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 particul ate 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 sedi ment biota under heavy loading and certain hydrologic conditions, such e ffects were not found in a previous study in San Diego Bay by Navy (1994). Appendix A provides th e endpoints for narrative criteria WQC.

3.1.8 Summary of Environmental Effects

The analysis of the baseline discharge identifi ed two COCs, copper and zinc. Table 3-7 details the concentrations of the COCs, their co rresponding 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 ( μ g/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 dissolv ed copper; no exceedances for dissolved zinc.

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

• Has EOMZ HI values rangi ng 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 comprisi ng approximately 100% of the total TPE.DRAFT

3.2 U NDERWATER S HIP H USBANDRY M ANAGEMENT P LAN (USHMP) MPCD

The USHMP will function to consolidate the curren t practices into a single document, thus the baseline discharge is the same as the MPCD di scharge (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 no t available; therefore, process knowledge was used to evaluate comparisons of each deviation from current practices.

Specific deviations to the curren t 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 Report23 July 2003Table 3-8. Summary of Projected Environmental ImpactsPracticeOperationWQC ExceedancesToxicity (HI) atEOMZNISIntroductionBCCMass Loading/ TPEOther ImpactsNumericNarrativeCurrent Practice(Cleaning atestablished foulingthreshold)Copper,dissolved(14 of 14)Color, TSS,turbidity, floatingmaterial, settleablematerialRange from HI = 1to 7.5Potential toreleaseCopper,ZincCu = 7.5E+02Zn = 3.0E+02Total TPE 3.8E+02Load to sedimentsCriteria ForCleaningClean at LowerThreshold (Cleanmore frequently)Copper,dissolved(14 of 14)Decreasedlikelihood toexceedIncreased relativeto current practiceImpactUnknownCopper,ZincIncreased massloadings and TPEIncreased VOCs withadditional painting(shorter coating life)Clean at HigherThreshold (Clean lessfrequently)Copper,dissolved(14 of 14)Increasedlikelihood toexceedIncreased relativeto current practiceIncreasedpotentialCopper,ZincIncreased massloadings and TPEIncreased VOCs withadditional painting(longer coating life)Current Practice (full,partial or interimcleaning; asappropriate)Copper,dissolved(14 of 14)Color, TSS,turbidity, floatingmaterial, settleablematerialRange fromHI = 1 to 7.5Potential toreleaseCopper,ZincCu = 7.5E+02Zn = 3.0E+02Total TPE 3.8E+02Load to sedimentsType ofCleaningMore Full Cleanings(fewer partial orinterim cleanings)Copper,dissolved(14 of 14)Same or increasedlikelihood toexceedIncreased relativeto current practiceDecreasedpotentialCopper,ZincIncreased massloadings and TPEIncreased VOCs withadditional painting(shorter coating life)Fewer Full Cleanings(more partial orinterim cleanings)Copper,dissolved(14 of 14)Same likelihood toexceedDecreasedrelative to currentpracticePotential toreleaseCopper,ZincDecreased massloading and TPENo change fromcurrent practiceNo CleaningsNoneNoneNoneIncreasedpotentialNoneNoneIncreased VOCs withadditional painting(shorter coating life)Current Practice(Selecting the properequipment)Copper,dissolved(14 of 14)Color, TSS,turbidity, floatingmaterial, settleablematerialRange fromHI = 1 to 7.5Potential toreleaseCopper,ZincCu = 7.5E+02Zn = 3.0E+02Total TPE 3.8E+02SedimentsEquipmentSelectionMore AggressiveCopper,dissolved(14 of 14)Increasedlikelihood toexceedIncreased HIvaluesIncreasedpotentialCopper,ZincIncreased massloadings and TPEIncreased VOCs withadditional painting(shorter coating life)Less AggressiveDecreasedexceedancesof copperDecreasedlikelihood toexceedDecreased HIvaluesIncreasedpotentialCopper,ZincDecreased massloadings and TPEDecreased VOCswith additionalpainting (longercoating life)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 num eric or narrative WQC exceedances. Copper releases are expected to continue to exceed the same 14 numeric WQC by approximately the same magnitude regardless of devi ations. 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 cau sing 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, increas ed cleaning frequencies would be expected to result in a lower likelihood of causing narrative criteria ex ceedances 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 cl eaning to conduct (partial, interim or full) depends on the degree of biofouling identified, along w ith 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 performe d, 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 re sult in poor cleaning performance. Using a more aggressive brush or inappropriate equipmen t 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 ag gressive brush or ina ppropriate equipment may not remove all of the materials present on the hull. The likelihood of exceeding additional numeric WQC for hull cleanings conducted with in appropriate equipment is not expected. In addition, similar exceedances of one of more narra tive 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 th e MPCD discharge, actual HI calculations for the USHMP MPCD option will be the same as the baseli ne discharge (current practice). The mixing of the discharge with the bac kground 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 affect ed 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, pa rtial, or interim) does not affect the mixing of the discharge. Therefore, changes from current practices are no t expected to change th e EOMZ concentrations of copper or zinc. It is expect ed 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 we re performed, no release of a discharge would occur and th e toxicity would be zero.

Equipment Selection
The type of brush (more aggressive versus less aggressive) or equipmen t selected for cleaning does not affect the mixing of the di scharge 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 equi pment selected. Use of more aggressive equipment may increase the quantity of biofouling and constituents released and may increase HI values. Hull cleanings perf ormed 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 impelle r 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 caus e 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 hul l cleanings may decrease the transmission of nonindigenous species. A fouled hull is more likel y to provide habitat (a nd transport) for new organisms than a clean hull. A hull that is cl eaned before deployment and operated continuously (as vessels on deployment are) provides a hull su rface 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 antifouli ng paint. Nonindigenous species can be introduced from hulls that have not been cleaned ad equately or frequently enough, and consequently have well-developed biofouling comm unities 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 occu r on the hull. It is anticipated that increased growth and colonization on the hull would incr ease the potential fo r nonindigenous release.

Type of Cleaning
Nonindigenous species can be intr oduced 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 releas e nonindigenous species is expected when proper hull cleanings are conducted. The type of cl eaning conducted (partial, interim or full) is dependent upon the degree of biof ouling 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 releas e. Conducting a full cleaning when a partial or interim clean ing is more appropriate would increase the amount of unfouled hull area cleaned, but should not affect the potent ial to introduce nonindige nous 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 ar e conducted using the proper equipment. Inappropriate equipment sele ction may increase the am ount of paint particles and TSS released into the marine environmen t and damage the hull coating. Inadequately cleaned hulls can result in we ll-developed biofouling communiti es adhering to the hull, increasing the potential to intr oduce nonindigenous species. An aggressive cleaning device may remove biofouling adhered to the hull. The majo rity 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 no nindigenous species releas e, as the organisms would not be removed sufficiently from the hull and may continue to de velop 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 id entified in this discharge, these constituents are expected to remain in the discharge regardle ss 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 in itial release of copper and zinc, the mass loadings from the discharge may change if cleanings are performed at signif icantly greater or less er foul ratings. A hull that is not regularly cleaned near to FR- 40 is susceptible to coa ting degradation and may require more frequent hull coating applications . The vessel would spend more time with a new hull coating and its correspondi ngly 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 rate s for copper (Navy, 2002b). Static testing was conducted using stationary steel pane ls, 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 MS DS paint lists (Navy and EPA, 2003e). The copper leachate rate from the hull coating syst em decreases significantly over time. More frequent hull cleanings may increase the amount of biofouling and constituen ts released into the marine environment over time, which potentially could increase the mass loading of copper. Less frequent hull cleanings may create an incr ease 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 increas e the likelihood of coating system failures requiring removal and reapplication of the coat ing 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 performi ng 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 aggres sive device is applied to a fouled hull; thereby increasing the biofouling and constituents releas ed into the marine environment, and thusDRAFT - 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 decr easing 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 in crease 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 freque nt drydocking and hull coating app lications. An increase in the frequency of coating applications may cause air qu ality 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 consum ption and exhaust emissions) and may release additional VOCs into the air. In addition, more frequent hull coating appl ications 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 sh ells), settle in the sediment close to where the hull cleaning operations are conduc ted. Unnecessary hull cleanings or inappropriate equipment selection may increase the amount of paint const ituents released to the sediment. Cleaning less frequently is expected to incr ease 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 th e potential to leach copper into the water column due to the increased surf ace area of the particle s discharged. Results of limited studies conducted on the time dependency of dissolved c opper 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 cleani ng 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, th e 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 cu rrent practice (or USHMP) are:

• Not expected to result in any additional num eric WQC exceedances for dissolved copper (14 of 14) or zinc (no exceedances) if clean ings 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 narrativ e 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 in appropriate equipment is selected.

• More likely to introduce NIS if hulls are clean ed 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 biofouli ng, variation in cleaning types, age of the vessel and coating system, and variations in equi pment/operator reliability. Due to these many factors, sampling obtained from earlier Navy resear ch studies were used as a “snapshot” of the discharge composition, which was then used to co mplement available process knowledge.

4.1 E XCEEDED W ATER Q UALITY C RITERIA
Copper concentration data was obtained from Navy research studies. These studies include results from San Diego Bay waters sampled be fore, during, and after underwater hull cleaning operations. The measurement of dissolved copper at any one point is tr ansitory, 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 D ISCHARGE H AZARD I NDEX
The HI approach used in this environmental effect s analysis estimates the aggregate toxicity of a baseline discharge. The uncertainty of HI valu es is primarily based on (1) the uncertainty in sample data both from receiving water studies an d 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 si ze and configuration, age of paint, tidal conditions, temperature, etc. The uncertainty associated with the mass dilution method can be characterized as an overly simp lified approach – “real world” mixing is not performed in a uniform fashion and all constitu ents 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 N ONINDIGENOUS S PECIES R ELEASE
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 de ployment 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 organism s that are more likely to reproduce than younger organisms. The uncertainty associated with the re lease of NIS is attributed to the variability in the colonization and organization of marine or ganisms on the hull surface. A few factors contributing to the variety of marine growth in clude the vessel location (waterbody), depth of hull, and effect of hull coating biocidal propertie s. In addition, the variability of the receiving waters (i.e., water temperatures, season, tidal fl ow) can affect the potential for invasion by a nonindigenous species.

4.4 B IOACCUMULATIVE C ONTAMINANTS OF C ONCERN
Two reduction BCCs, copper and zinc, were identif ied for the discharge. There is little uncertainty related with the identification of the BCCs reported as th e these are the only BCCs present in the MSDS paint lists for the hull coa tings applied to Armed Forces vessels. The only uncertainty with this approach is the dependenc e on the MSDS paint list information, which is not comprehensive.

4.5 C ONSTITUENT M ASS L OADING AND T OXIC P OUND E QUIVALENTS
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 c onstituent 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 associat ed with the discha rge, refer to the ChAR: UWSH, which provides details on the assumptions made to determine the gene ration rates (Navy and EPA, 2003b).

4.6 O THER P OTENTIAL E NVIRONMENTAL I MPACTS
As mentioned previously, the char acterization and freque ncy 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 biofouli ng, variation in cleaning types, age of the vessel and coating system, and variations in equipm ent/operator reliability. The uncer tainty associated with benthic impacts includes the dynamics of the receiving water and sediments (deposition, redistribution, and export rates and patterns), the physico-ch emical conditions of both water and sediments (parameters such as particle size distributions , pH and redox states, di ssolved 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 wh at the impacts of sediment containing copper may pose. The uncertainty associated with ai r impacts may include the operational aspects of repainting (e.g., occu rrence in non-attainment areas), controls for VOC emissions, and weatherDRAFT - Underwater Ship Husbandry – Environmental Effects Report 23 July 2003

conditions (Shaner, 2003). All of these factors cont ribute to other pote ntial environmental effects and the uncertainty of these effects.

4.7 C ONCLUSION
Variations from the management plan may increa se the potential to exceed WQC (narrative and numeric) and may show an incr ease 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 impact s to receiving waters while balancing the necessity and feasibility of cleani ng hulls of Armed Forces vessels. Performing hull cleanings at the prescribed intervals, base d on environmental cons iderations and feas ible and practical solutions, such as biofouling rating guidelines , cleaning types, appropriate equipment, and trained divers is the best practi ce 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 St andards for Vessels of the Armed Forces. Phase I Final Rule. 10 May 1999.

Brent, R. 2001. Whole Effluent Toxicity Test Analysis for the Unif orm National Discharge Standards Program. DynCorp Information & Enterprise Technology, Inc. Alexandria, VA. 19 February 2001.

EPA. 1991. Technical Supporting Document for Water Quality-ba sed 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 Di scharge 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 Vehi cle Operations Conducted on USS SAIPAN (LHA 2). Naval Surface Warfare Center, Carderock Division, Code 632 (Pollution Prevention & Material Safety Branch), Be thesda, 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 Su rface 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 Hu sbandry Non-Cleaning Activities. Naval Sea Systems Command, Code 00C, Wa shington, 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 Cleani ng Guidance in NSTM Chapter 081. Naval Sea Systems Command, Code 00C, Wa shington, 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 Di vision, 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 Clea ning 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 (F FG-46) Hull Coatings Study April 20-30 2002. U.S. Navy, Marine Environmental Support Office, SPAWARSYSCEN 23621, San Di ego, CA. 24 July 2002.

Navy and EPA. 2000a. Development of Vessel Gr oups and Selection of Representative Vessels for Feasibility and Environmental Effects Analyses. U.S. Navy, Naval Sea Systems Command, Washington, DC and U.S. Envi ronmental Protection Agency, Office of Water, Washington, DC. 19 September 2000.

Navy and EPA. 2000b. Environmental Effects An alysis Guidance for Phase II of the Uniform National Discharge Standards for Vessels of the Armed Forces. U.S. Environmental Protection Agency, Office of Water, Washi ngton, 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 Fo rces Uniform National Discharge Standards (UNDS) Phase II. U.S. Environmental Prot ection Agency, Office of Water, Washington, DC and U.S. Navy, Naval Sea Syst ems Command, Wash ington, DC. 2001.

Navy and EPA. 2003a. Frequency of Non-Cleani ng Maintenance Activities White Paper. U.S. Navy, Naval Sea Systems Command, C ode 05M4, Washington, DC and U.S. Environmental Protection Agency, Office of Water, Washington, DC. July 2003.

Navy and EPA, 2003b. Characteriza tion Analysis Report: Underwater Ship Husbandry. U.S. Navy, Naval Sea Systems Command, Wash ington, DC and U.S. Environmental Protection Agency, Office of Wate r, 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, Washingto n, DC. Meeting held on 27 March 2003.

Navy and EPA. 2003d. Environmental Effects Anal ysis Report: Hull Coating Leachate. U.S. Navy, Naval Sea Systems Command, Wash ington, DC and U.S. Environmental Protection Agency, Office of Water, Wa shington, 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: Underw ater Ship Husbandry. U.S. Navy, Naval Sea Systems Command, Washington, DC and U.S. E nvironmental 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, Sa n Diego, CA. Re: UWSH EEAR. 13 May 2003.

Shimko. 2003a. Email to Ms. Kimberly Robe rtson, Booz Allen Hamilton, Arlington, VA from Mr. Michael Shimko, M. Rosenblatt and Son/AM SEC, 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. Coppe r Chemistry, Toxicity, and Bioavailability and Its Relationship to Regulation in the Marine Environment. Technical Document 3140. Office of Naval Research Second Workshop Re port. 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 nuisanc e 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 μ g/L total nitrogen (nitrate + nitrite + KJN), 10.0 μ g/L of ammonia nitrogen, 15 μ g/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 μ g/L of total phosphorus at EOP

Odor Cu = 7.7E+00 μ g/L Zn = 2.9E+00 μ g/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 μ g/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 measureDRAFT - 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 μ g/L Zn = 2.9E+00 μ g/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

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