U.S. Environmental Protection Agency

Office of Water, Water Permits Division

EPA

- 833

- K

- 11

- 102

March 201 3 

# Summary of the VGP Vessel Universe :

Information Submitted by Vessel Owner /Operator s

for Coverage under the 2008 Vessel General Permit (VGP)The primary technical contacts for this document are:

Kathryn Kelley

(202) 564

- 7004 (telephone)

Ryan Albert

(202) 564

- 0763 (telephone)

U.S. Environmental Protection Agency

Office of Water (Mail Code: 4203M)

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Cover Photo Credits

1. MS Nieuw Amsterdam

– Holland America Inc.

2. MSC Beatrice

– World Shipping Council

3. Nanticoke

- Vane Line Bunkering

4. Maersk Magellan

– A.P. Moller

– Maersk Group

5. Donna Rushing

– The American Waterways Operators 1 2

3

4 5Summary of the VGP Vessel Universe March 2013

3 Table of Contents

1 Introduction

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

1.1 Purpose of Report

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

1.2 NOI Requ irements

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

1.3 Uncertainty and Supplementing NOI information

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

2 NOI Vessel Universe

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

2.1 Overview of Vessels by Vessel Type

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

2.2 Comprehensive Summary and Analysis of NOI Vessel Universe

........................... 9

2.2.1 Vessel General Characteristics and Voyage Related Information

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

2.2.1.1 Vessel Subtypes

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

2.2.1.2 Vessel size and age

................................ ................................ .......................... 11

2.2.1.3 Dates of Dry Docking

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

2.2.1.4 Home/Most Frequented Port and Geographical Area of Operation

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

2.2.1.5 Crew and Passengers

................................ ................................ ....................... 21

2.2.2 Ballast Water and Related Information

................................ ................................ ... 24

2.2.2.1 Ballast Water Capacity

................................ ................................ .................... 24

2.2.2.2 Ballast water management, tank cleaning, and sediment disposal

.................. 28

2.2.2.3 Experimental ballast water treatment systems and discharge of residual

biocides 32

2.2.3 Applicable Discharges and Related Information

................................ .................... 32

2.2.3.1 Applicable discharges

................................ ................................ ...................... 32

2.2.3.2 Onboard treatment systems for generated waste streams

................................ 34

2.2.4 Anti

- fouling Hull Coatings and Related Information

................................ ............. 35

2.2.4.1 Type of coating

................................ ................................ ................................ 35

2.2.4.2 Anti

- fouling hull coating application and hull husbandry practices

................ 35

2.3 Characterization of Vessels with Missing Information

................................ .......... 37

2.3.1 Data Sources

................................ ................................ ................................ ........... 37

2.3.2 Methodology

................................ ................................ ................................ ........... 38

2.3.3 Summary and Analysis of NOI Vessels with Incomplete Information

.................... 39

3 Summary

................................ ................................ ................................ ............................... 40

4 References

................................ ................................ ................................ ............................. 43

Appendix A : Comparison of th e NOI Universe of Vessels versus the Universe of Vessels in the

Final 2008 VGP Economic and Benefit Analysis

................................ .............................. A

- 1

Appendix B : Summary of vessel characteristics where NOI information was incomplete

....... B

- 1

Barges

................................ ................................ ................................ ....................... B

- 2

“Other” Vessels

................................ ................................ ................................ ............... B

- 3

Oil or Gas Tankers

................................ ................................ ................................ .......... B

- 4

Miscellaneous Vessel Types

................................ ................................ ........................... B

- 5Summary of the VGP Vessel Universe March 2013

4 List of Tables

Table 2.1. Number of respondents who further classified their vessel by writing in a subtype on

their NOI.

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

Table 2.2. Cargo carrier type specified within the “Other” vessel category.

................................ 11

Table 2.3. Statistic al distribution of tonnage (GT) of NOI vessels by vessel type.

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

Table 2.4. Statistical distribution of length (feet) of NOI vessel s by vessel type.

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

Table 2.5. Statistical distribution of age a (years) of NOI vessels by vessel type.

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

Table 2.6. Statistical distribution of the time interval since the last dry docking by vessel type (by

years).

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

Table 2.7. Top fifteen home/most frequent port cities for barges.

................................ ............... 14

Table 2.8. Top ten home/most frequented port cities for oil and gas tankers.

.............................. 16

Table 2.9. Home/most frequented port for large ferries.

................................ .............................. 17

Table 2.10. Top seven home/most frequented port cities for research vessels.

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

Table 2.11. Top 10 Home/most frequented port cities for “Other” vessels.

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

Table 2.12. Summary statistics on maximum persons (crew and passengers) aboard NOI vessels.

................................ ................................ ................................ ................................ ........... 21

Table 2.13. Statistical summary of ballast capacity for vessels in the NOI.

................................ . 24

Table 2.14. Percentage o f vessels within a given type where use/non

- use of a ballast water

management plan (BWMP) has been indicated.

................................ ............................... 28

Table 2.15. Summar y of the frequency of ballast tank cleaning for vessel types (Values reflect

percentage of vessels for which a response was provided).

................................ .............. 29

Table 2.16. Summary of ballast water sediment disposal methods for vessel types (Values reflect

percentage of vessels for which a response was provided).

................................ .............. 29

Table 2.17. Percentage of vessels where the applicable discharge listed is reported. (Note: the 26

applicable discharges listed represent the possible discharges listed on the 2008 VGP

NOI. The top five applicable discharge s for each NOI vessel type are shaded.)

............. 33

Table 2.18. Presence of onboard treatment systems per vessel type and a summary of the t ypes of

generated waste streams that were treated (values reflect percent of the total number of

vessels for which response was provided, with the corresponding percentage within a

class of vessels in parentheses).

................................ ................................ ........................ 34

Table 2.19. Summary of anti

- fouling hull coatings used on vessels as reported on the vessels’

NOIs. (Values reflect percent of the total number of vessels for which resp onse was

provided, with the corresponding percentage within a class of vessels in parentheses).

.. 35

Table 2.20. Summary statistics d epicting number of years since last anti

- fouling hull coating at

time of NOI coverage.

................................ ................................ ................................ ....... 36

Table 2.21. Summary of the frequency with which hull husbandry practices were utilized for

vessels. (Values represent actual number of responses).

................................ .................. 36

Table 2.22. Summary of h ull husbandry cleaning practices for NOI vessels. (Values represent

actual number of responses).

................................ ................................ ............................. 37

Table 3.1. Summary of key vessel characteristics reported in the NOI database by vessel type. 42Summary of the VGP Vessel Universe March 2013

5 List of Figures

Figure 2.1

- 1: NOI vessels by vessel type.

................................ ................................ ...................... 9

Figure 2.2

- 1: Distribution of barges by geographic region.

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

Figure 2.2

- 2: Distribution of large ferries by geographic region.

................................ ................ 17

Figure 2.2

- 3: Primary area of operation reported for large cruise ships.

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

Figure 2.2

- 4: Primary area of operation for medium cruise ships.

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

Figure 2.2

- 5: Distribution of maximum persons (crew and passengers) aboard vessels of a given

type.

................................ ................................ ................................ ................................ ... 22

Figure 2.2

- 6 : Distribution of maximum persons (crew and passengers) aboard vessels of a given

type (continued).

................................ ................................ ................................ ............... 23

Figure 2.2

- 7: Relationship between vessel tonnage (GT) and ballast water capacity for vessels

identified in the NOI database.

................................ ................................ ......................... 25

Figure 2.2

- 8 : Relationship between vessel tonnage (GT) and ballast water capacity for vessels

identified in the NOI database (continued).

................................ ................................ ...... 26

Figure 2.2

- 9: Relationship betwe en vessel length and ballast water capacity for vessels identified

in the NOI database.

................................ ................................ ................................ .......... 27

Figure 2.2

- 10: Relationship between vessel length and ballast water ca pacity of for vessels

identified in the NOI database (continued).

................................ ................................ ...... 28

Figure 2.2

- 11: Sediment disposal methods based on NOI submittals.

................................ ........ 30

Figure 2.2

- 12: Sediment disposal methods based on NOI submittal (continued).

...................... 31

Figure 2.3

- 1: MISLE and NBIC compatible vessels.

................................ ................................ .. 39Summary of the VGP Vessel Universe March 2013

6 1 Introduction

The United States Environmental Protection Agency’s (EPA) National Pollutant Discharge

Elimination System ( NPDES ) vessel program regulates incidental discharges from the normal

operation of vessels operating in a capacity as a means of transportation. In 2008, EPA issued its

first Vessel General Permit ( VGP ) (EPA, 2008a)

. When finalizing that permit, EPA estimated

th at approximately 70,000 vessels would be eligible for coverage under the VGP. Part 1.5.1.1 of

the 2008 VGP requires owners or operators of vessels that are greater than or equal to 300 gross

[registered] tons or have the capacity to hold or discharge more than 8 cubic meters (2,113

gallons) of ballast water to submit a complete and accurate Notice of Intent (NOI) in accordance

with Part 10 of the VGP to obtain authorization to discharge . Owners and operators of existing

vessels had until September 19, 2009 to submit an NOI to seek coverage under the VGP

. 1

V essels less than 300 gross tons that do not have the capacity to hold or discharge more than 8

cubic meters (m 3 ) of ballast water are authorized to discharge without having to submit an NOI

.

1.1 Purpose of Re port

Th e purpose of this report is to provide a summary of the characteristics and conditions of vessel

discharges based on information submitted in NOIs filed under the 2008 VGP. This report

presents NOI data reported by owners/operators (respondents/per mittees) who applied for

coverage under the VGP during the period of June 1, 2009 (the launch of the electronic NOI

system (eNOI)) through August 5, 2010, and represents the first comprehensive summary of

vessel information for vessels authorized to discha rge under the VGP . This information is stored

within an EPA NOI database. Information about individual NOIs is available to the public at

http://cfpub.epa.gov/npdes/vessels/vesselsnoisearch.cfm

1.2 NOI Requirements

Submission of NOIs requires the following information: vessel type, Employer Identification

Number ( EIN ) , company International Maritime Organization ( IMO ) number, vessel identifier,

certifying official data, vessel weight, vessel ballast water capacity, frequency and location of

ballast tank sediment disposal, waste discharges generated by the vessel, hull husbandry best

management practices (BMPs), indicat ion of travel outside the U.S. exclusive economic zone

(EEZ), etc. For NOIs submitted that were missing a significant amount o f mandatory data, EPA

retained the option to contact the responder to collect the missing data for that vessel

owner/operator to secure coverage under the VGP

. Note that because the eNOI system does not automatically verify user entries (e.g., to identify

and correct misspellings), for the purpose of this analysis, EPA has:

unified terminology or classification used by responders wh en necessary, and

made other minor modifications for clarity or to facilitate data summary when entries

contained obvious errors

.

1 EPA's NPDES vessels program regulates incidental discharges from the normal operation of vessels. The NPDES

vessels program does not regulate discharges from military vessels or recreational vessels. Instead, those are

regulated by other EPA programs under sec tion 312 of the Clean Water Act (CWA).Summary of the VGP Vessel Universe March 2013

7 For example, EPA standardized entries for “NOLA” and New Orleans, LA as a home/most

frequented port. EPA also developed a codi ng system to sort and categorize reported information

on hull husbandry practices and frequency with which those practices were implemented.

1.3 Uncertainty and Supplementing NOI information

In the VGP (Part 1.5.1.1), EPA limited which vessels had to submit an NOI to focus data

collection on vessels with larger volumes of permitted discharges (see Part 3.7.1 of the VGP Fact

Sheet for further discussion) (EPA, 2008 b )

. As of August 5, 2010, approximately 43,431

uniquely identified vessels

, 2 owned/operated by 3, 430 different permittees , had active NOI

coverage . There is uncerta inty as to the exact number of permittees because of different spellings

that in fact may be the same permittee

.

In summarizing and comparing the characteristics of the vessel population, EPA assumed the

data submitted by each respondent w ere accurate, unless the data w ere found to be clearly

erroneous (e.g., a vessel noted to be over 650,000 feet in length)

. T o acco unt for error

, the upper

range of quantitative values submitted for select characteristics (e.g., vessel weight and length,

ballast water capacity, etc.) has been truncated to the 90 th percentile value. For 6,468 out of the

43,431 uniquely identified vesse ls

, the information provided by the respondent was incomplete

or in sufficient (e.g., did not include a specific entry/value for tonnage or ballast water capacity)

and was not included in the overall analysis . Instead, EPA complemented the incomplete or

in sufficient data with information from two databases: the U.S. Coast Guard’s Marine

Information for Safety and Law Enforcement (MISLE) database (USCG, 2009) and National

Ballast Water Information Clearinghouse (NBIC). MISLE provides a wide range of information

regarding vessel characteristics, hailing ports, and other pertinent information tracked by the U.S.

Coast Guard

. EPA used the MISLE database to support vessel characteriz ations in their 2010

Report to Congress. 3 NBIC provides data on ballast water management practices of commercial

ships that operate in the waters of the United States.

These two data bases were used to develop estimat es of the number of vessels eligible for

coverage under the VGP (Abt Associates, 2008). T o check the accuracy of EPA’s original

estimates and to evaluate whether vessels that should be seeking coverage actually were doing

so, EPA compared the number of NOIs submitted to the MISLE and NBIC estimates , as

summarized in section 2.3 of this document. Furthermore, Appendix A of this report provides a

compar ison of the information contained in the NOI database with estimates developed as part of

the economic analys is for the 2008 VGP

.

2 In t his analysis, EPA defines uniquely identified vessels as those that are certified and have active permits. These

vessels all have a unique IMO registration or other vessel identifier number; vessel name; and/or call sign in the NOI

database, as well as a permit status labeled as either ‘Active’ or ‘ Certified’. EPA determined that 43,431 out of

53,567 total vessels currently meet these criteria. Vessels that are not considered in this analysis include 3,563

vessels with an archived status and 2,692 vessels with a terminated status. EPA notes that owner/operators of some

vessels with an archived status intended to seek active coverage, but did not take all necessary steps in the

electronic NOI system to finalize that coverage.

3 U.S. EPA, 2010. Report to C ongress: Study of Discharges Incidental to Normal Operation of Commercial Fishing

Vessels and Other Non

- Recreational Vessels Less than 79 Feet . Report EPA 833

- R

- 10

- 005. August 2010.Summary of the VGP Vessel Universe March 2013

8 2 NOI Vessel Universe

This section of th is document provides a comprehensive summary of vessel information

submitted by vessel owner/ operators in their NOI s

. The EPA NOI database (dated August 5,

2010) includes data for 43,431 vessels with an active or certified NOI 4 status that operate in U.S.

waters, including 6,468 vessels for which tonnage and/or ballast water capacity is missing

(Figure 2.1

- 1)

. Section 2.2 of this document presents results from 36,642 5 uniquely identified

vessels that submitted complete NOIs

. Section 2.3 compares the insufficient NOI data with

MISLE and NBIC databases for the remaining 6,468 vessels

.

2.1 Overview of Vessels by Vessel Type

Vessel owner/operators can classify their vessel under Question B.5 on the VGP NOI form as

one of eight listed vessel types (plus an “other” category)

. Of the 36,642 uniquely identified

vessels , 24,241 vessels were listed under one of th es e eight classifications ( in order of number of

vessels identified ):

Bar ges of all types;

Oil or Gas Tankers;

Commercial Fishing Vessel s with Ballast Water (hereinafter Commercial Fishing

Vessel s ) ;

Large Ferries (250+ passengers or more than 100 tons of cargo, e.g., cars, trucks, trains,

or other land

- based transportation);

Large Cruise Ship s (500+ passengers);

Research Vessels;

Emergency Vessels ;

Medium Cruise Ship s (100 to 499 passengers)

.

Of these 24,241 vessels, barges

, followed by oil and gas tankers , represent the largest percentage

of vessels (Figure 2.1

- 1)

. C ommerc ial fishing vessels with ballast water, large ferries, large and

medium cruise ships, and research and emergency vessels , combined, represent about one

percent or so of the total

.

The remaining 12,401 vessels were identified as “other,” making this the second largest category

of vessels overall . Many vessel operators who checked “O ther” also filled in a secondary vessel

type (see additional details provided in section 2.2.1.1 of this document ).

4 An active NOI refers to those for which the 30

- day waiting period has be en completed and no additional issues

have been identified, whereas a certified NOI is one that is in the 30

- day waiting period prior to becoming active.

Note: not all NOIs in the current system are active (see footnote 2 ).

5 The values reported for vessel tonnage and/or ballast capacity for 321 vessels with active or certified NOI status

are less than 300 gross registered tons and 8 m 3 , respectively, and therefore, are also excluded from the more

detailed examination of vessel characteristics data summarized in this report.Summary of the VGP Vessel Universe March 2013

9 Figure 2.1

- 1 : NOI vessels by vessel t ype

. 6

2.2 Comprehensive Summary and Analysis of NOI Vessel Universe

S ection 2.2 of this document presents vessel characteristic data reported in the NOI for the

36,642 uniquely identified vessel s for the following four types of information :

Vessel General Characteristics and Voyage Related Information

– vessel subtypes; tonnage,

l ength , and age; date of last dry dock; h ome / m ost f requented port; and crew size /passenger

capacity

.

Ballast Water and Ballast Water Treatment

– ballast water capacity; ballast water

management plan

, tank cleaning and sediment disposal; and experimental ballast water treatment

system s and associated disch arge of residual biocides

.

6 Source: EPA NOI database, August, 5, 2010. Note : Percentage s are based on the total number of vessels within a

given type out of the total 43,431 uniquely identified vessels in the NOI. The subset of 6,468 vessels within the

“Uncertain” group and identified as “Lacking Information” consist s of those vessels for which t he information

reported in the NOI regarding tonnage or ballast w ater capacity wa s missing. These vessels are discussed further in

Section 2.3 of th is document, and have been excluded from the more detailed data summary and analysis included in

section 2.2 of this document . Again, EPA did not an alyze the 321 vessels identified as “Not Applicable” because the

tonnage and ballast water capacity reported in the NOI for these particular vessels are less than 300 gross tons and /or

8 m 3 , respectively. However, EPA notes that these vessels may have chosen to submit an NOI despite being smaller

than these thresholds, or if the vessel is below 79 feet, may be seeking coverage for the ballast water discharges only

as authorized in Part 1.2.1 of the VGP.Summary of the VGP Vessel Universe March 2013

10 Vessel Discharge and Treatment System

– a pplicable discharges and o nboard treatment

systems and the waste

- streams they are designed to treat.

Anti

- fouling Hull Coatings

– type of coating ; interval since last application ; and hull husbandry

practices , including the frequency with which the practices are implemented

.

2.2.1 Vessel General Characteristics and Voyage Related Information

2.2.1.1 Vessel Subtypes

Respondents who selected one of the eight listed vessel types also had an opportunity to further

classify their vessel. Table 2

. 1 shows the number of owners/operators who either selected

“other” or specif

ied a sub type in addition to one of the eight ves sel types

. The percentage of

vessels that were further specified as a subtype was highest for emergency vessels (79 percent)

and commercial fishing vessels ( 57 percent ). Notably, of the 12,401 respondents who classified

their vessel type exclusively as “Other” only 21 percent actually wrote in a specific subtype as

requested by the NOI form

.

Table 2

. 1 . Number of respondents who further classified their vessel by writing in a

sub type o n the ir NOI

.

Subty pe

Specification Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Yes 106 82 84 7 1 1 2 44 2,562

No 20,304 3,198 62 111 126 21 80 12 9,839

Total 20, 410 3,280 146 118 127 22 82 56 12,401

Subtype Specified (%) <1 % 2.5 % 57 % 5.9 % <1 % <1 % 2.4 % 79 % 21 %

Barges

Of the 20,410 barges , less than one percent (106 barges) were sub

- classified by respondents. T he

largest number were designated dredge attendant plants (50 barges), followed by dredgers (15),

deck barges for construction materials (13), oil and gas or other tank barges (10), and cranes of

various types (10).

Oil and Gas Tankers

O f the 3,280 oil and gas tankers , only 2.5 percent we re specifically sub

- classified

, with the

largest number identified as either chemical tankers (51) or barge or tank barges (20).

Commercial Fishing Vessels

Roughly 58 percent of commercial fishing vessels (84 out of 146 vessels) were sub

- classified as

bulk carrier s , cargo or container vessel s (56), with a much small er number sub

- classified as

tug/towboat s (6), barge s (5), or off

- shore supply vessel s (5).

Large Ferries, Large and Medium Cruise Ships, and Research Vessels

Very few ferries and large and medium cruise ships were sub

- classified. O f the 118 large ferries

, four are sub

- categorized as large cruise ships and three as medium cruise ships . O f the 127 l arge

c ruise ships

, one was sub

- classified as a barge. Of the 22 medium cruise ships

, one was sub

-Summary of the VGP Vessel Universe March 2013

11 classified as a large ferry. Likewise, only two of the 56 research vessels were sub

- classified , with

both identified as workboats.

Emergency Vessels

In contrast

, 44 of 56 eme rgency vessels were sub

- classified; 43 as oil recovery vessels and one a s

a research vessel.

“Other” Vessels

Respondents were also given the choice to exclusively select “Other” and write in a specific

vessel type. Of the 12,401 “O ther” vessels

, only 2, 562 respondents (21 percent) wrote in a

subtype as requested by EPA, while 9,839 respondents (79 percent) did not. Furthermore, out of

the 2,562 respondents who wrote in a specific vessel type, 67 respondents provided an entry that

matched one of the eight vessel types listed in the NOI form.

C argo carriers ( See Table 2.2 below ) comprised the vast majority of the “O ther ” vessels (2,044

v essels), followed by tug s /tow boat s (143), crew/supply/support vessels (115), chemical/oil

tankers (83), barges (3 4), and passenger vessel s (18).

Table 2

. 2

. C argo carrier type specified within the “Other” vessel category.

CARGO CARRIER TYPE # Vessels

General Cargo (Not Otherwise Specified) 1,870

Car/Truck Carrier 74

Refrigerated Cargo 47

Log/Lumber/Woodchip Carrier 25

Roll

- on Roll

- off Cargo 19

Cement Carrier 3

Grain/Ore Carrier 2

Irradiated Nuclear Fuel Carrier 2

Ore/Bulk/Oil Carrier 2

2.2.1.2 Vessel s ize and a

ge

Tonnage

Table 2

. 3 provides a summary of the statistical distribution of tonnage 7 of NOI vessels by vessel

type. Median tonnage ranges from 563 gross tons ( GT ) for emergency vessels to 53,526 GT for

large cruise ships

. Barges

, in general

, are lighter than other vessel types with 90 percent of the

b arges weighing less than 1,065 GT

.

7 Vessel tonnage is reported in terms of gross ton s (GT) here and throughout the remainder of this data summary

report. For purposes of this analysis, where data was entered as gross registered tons (GRT), values were converted

to GT using a multiplication factor of 0.592885 (or approximately 300 GT per 506 GRT) to standardize numbers

. This conversion factor was recommended by the U.S. Coast Guard (personal communication between Jordan

Gilliland, Environmental Scientist, EPA NOI Processing Center (staffed by the Avanti Corporation), and the U.S.

Coast Gu ard; December 2010). EPA recognizes that calculation of GRT is complex and does not necessarily result

in a linear relationship between GT and GRT. Thus values for vessel tonnage may be over

- or under

- estimated in

this report for certain vessels.Summary of the VGP Vessel Universe March 2013

12 Table 2

. 3 . Statistical distribut ion of tonna ge (GT) of NOI vessels by vessel type

.

Statistic Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other 8

Minimum 5 25 58 99 391 99 82 70 9

10th Percentile 418 6,039 117 374 8,767 395 174 94 189

25th Percentile 453 14,224 325 498 33,094 1,147 682 488 3,904

Median 705 24,908 1,997 1,451 53,526 4,584 1,780 563 15,939

75th Percentile 788 46,730 15,542 3,216 81,984 17,951 2,925 2,711 27,681

90th Percentile 1,065 93,033 26,512 9,149 101,415 27,993 5,606 7,905 43,286

N (sample size) 20,364 3,244 145 118 127 22 81 56 12,241

Length

A summary of the statistical distribution of vessel length among vessels in the NOI is provided in

Table 2

. 4

. M edian length ranges from 200 feet for emergency vessels and barges to over 85 7 feet

for large cruise ships

. Cruise ships are the longest vessels overall followed by oil and gas tankers.

Table 2

. 4 . Statistical distribution of length (feet) of NOI vessels by vessel type.

Statistic Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Minimum 14 27 65 91 142 95 87 64 30

10th Percentile 190 412 114 139 477 119 124 96 122

25t Percentile 195 577 147 180 713 292 187 156 371

Median 200 620 265 260 857 420 224 194 600

75th Percentile 200 818 554 364 962 594 283 286 738

90th Percentile 264 1,034 628 583 1,021 613 321 322 915

N (sample size) 20,256 3,274 146 118 127 22 77 55 12,151

Age

Table 2

. 5 provides the distribution of the age of vessels by vessel type. The median age of all

vessel types is approximately 18 y ears old , ranging from six years for oil and gas tankers to 26

years fo r large ferries and emergency vessels. O il and gas tankers and large cruise ships tend to

be newer with 90 percent of these vessels equa l to or less than 18 and 20 year s old, respect ively.

In contrast, large ferries tend to be older

.

8 As di scussed previously, “other” vessels comprise a wide variety of vessel types; hence, the summary statistics for

the “other” vessels have a wide distribution

.Summary of the VGP Vessel Universe March 2013

13 Table 2

. 5 . Statistical distribution of age a (years) of NOI vessels by vessel type

.

Statistic Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Minimum 1 1 1 1 1 2 2 3 1

10th Percentile 4 2 7 7 3 10 8 18 2

25th Percentile 9 3 12 12 7 11 14 18 5

Median 15 6 23 26 11 20 23 26 11

75th Percentile 29 12 32 42 16 26 34 35 22

90th Percentile 33 18 38 54 20 37 42 43 33

N (sample size) 20,307 3,267 146 118 127 22 81 56 12,262

a Age determined by subtracting year built from 2011.

2.2.1.3 Dates of Dry Docking

Table 2

. 6 summarizes the time interval since the last drying docking for vessels by vessel type.

Among vessels that have been dry docked, the median length of time (in years) that elapsed since

the la st dry dock is from 2 to 4 years with 3 years being the most common . The longest time that

elapsed since the last dry dock for any vessel was 37 years. Overall, the time since the last dry

dock is longest for barges. With the exception of barges, at least 90 percent of all other vessels

have been dry docked within the past 5 years.

Table 2

. 6

. Statistical distribution of the time interval since the last dry dock ing by vessel

type (by years)

.

Statistic Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Minimum 1 1 1 2 2 1 1 2 1

10th Percentile 2 2 2 2 2 2 2 2 2

25th Percentile 2 2 2 2 3 2 2 3 2

Median 4 3 3 3 3 2 3 3 3

75th Percentile 6 4 4 3 4 3 4 4 4

90th Percentile 9 5 4 5 5 3 4 5 5

Maximum 23 7 28 37 7 4 6 7 32

N (sample size) 6,943 1,507 135 111 93 18 80 56 7,113

2.2.1.4 Home/Most Frequented Port and Geographical Area of Operation

The information submitted regarding home/ most frequented port city 9 and/or general geographic

area of operation varies greatly both between and within vessel types , and is summarized by

vessel type below.

9 Note here that vessels may not always operate in their home/most frequented port, or remain at t heir home/most

frequented port for significant intervals of time. Many vessels might travel/work between numerous ports. Because

it is difficult for EPA to discern which city listed in the NOI is the primary home/most frequented port city, when

more than o ne city was entered, the first city in the list was assumed to be the primary home/most frequented port

city.Summary of the VGP Vessel Universe March 2013

14 Barges

Information on home/most frequented port was provide d for 15,641 barges, 11,480 of which

ac tually listed a specific city (equivalent to a 56 percent response rate for the 26,410 uniquely

identified barges in the NOI database) , and is summarized in Table 2

. 7

. Of the approximately

2 40 cities cited as home/ most frequented port, New Orleans, LA and Jeffersonville, IN were the

most frequently listed ( at 24 and 22 percent of barges, respectively ).

The top 15 home/ most frequented port cities are host to approximately 85 percent of the barges

(9,787) . Of the top 50 home/ most frequented port s, port cities along the Ohio River Valley are

host to 42 percent of the barges, followed closely by Gulf Coast cities (33 percent) and more

distantly by cities along th e Mississippi River (10 percent) and Atlantic Coast (6 percent),

respectively

. The distribution of barges by geographic region is provided in Figure 2.2

- 1

. Assuming most owners/operators listing home/most fr equent port cities in the G ulf C oast region

have done so because their barges only operate along the Mississippi and Ohio R iver s , this

means up to 85 percent of covered barges are likely operating within the larger Mississippi

- Ohio

R iver system.

Only 2 pe rcent of barges (361 of 19,558 reported ) travel beyond the U.S. EEZ and more than 200

nm from any shore. Similarly, only 2 percent of barges (344 of 19,595 reported ) engage in

Pacific nearshore voyages. These 344 barges represent approximately three quarters of the total

number of barges where home/most frequented port city was provided as being on the West

Coast or Hawaii.

Table 2

. 7 . Top fifteen home/most frequent port cit ies for barges

.

Home /Most Frequented U.S. Port # Vessels

New Orleans, LA 2,771

Jeffersonville, IN 2,513

Pittsburgh, PA 981

St Louis, MO 823

Metropolis, IL / Davant, LA 675

New York, NY 353

Cincinnati, OH 277

Houston, TX 242

Tuscaloosa, AL 229

Houma, LA 197

Ashland, KY 191

Boston, MA 153

Seattle, WA 147

Baton Rouge, LA 124

Grand Rivers, KY 111

Total o ther (non

- descript) home ports:

Inland Waterway Systems

Seaboard and Gulf Coast (ports)

- (Ports in) Coastal Waters

4,161

4,117

24

20

Grand Total 15,641Summary of the VGP Vessel Universe March 2013

15 Figure 2.2

- 1 : Distribution of barges by geographic region

. 10

Oil and Gas Tankers

Table 2

. 8 summarizes the home/most frequented port for 2,350 oil and gas tankers reporting this

information . The top ten most commonly cited home/most frequented port cities are in the

following states : Texas, New York, California, Louisiana, and Pennsylvania (in order of

prevalence) . Houston , Texas was the most common city

, representing approximately 40 percent

of the total oil and gas tankers . Of the top 10 home/most frequented port cities, approximat ely 46

percent are from the Gulf Coast, nine percent are from the East Coast, and five percent are from

the West Coast. The top ten cities identified represent more than half o f the entries listed under

home /most frequented port for oil and gas tankers

.

10 Geographic region ass igned by EPA based on home /most frequented port city

.Summary of the VGP Vessel Universe March 2013

16 Table 2

. 8 . Top ten home/ most frequent ed port cities for oil and gas tankers.

Home/Most Frequented U.S. Port # Vessels

Houston, TX 811

New York, NY 183

Texas City, TX 74

Galveston, TX 70

Los Angeles, CA 70

New Orleans, LA 55

Long Beach, CA 49

Louisiana Offshore Oil Port 36

Philadelphia, PA 34

Lake Charles, LA 32

Total # Vessels for which Home Port was provided 2,350

Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from

any shore was provided for 3,114 oil and gas tankers . Of those, 95 percent (2,966 of 3,114) were

reported to travel outside the U.S. EEZ . Twenty

- four percent (627 o ut of 2,617 tankers) were

reported as being engaged in Pacific nearshore voyages.

Commercial Fishing Vessels

Informati on on home/most frequented port was provided for 84 commercial fishing vessels. The

top three most commonly cited port cities were Dutch Harbor, AK ; Seattle, WA a nd New

Orleans, LA. Of the 24 home/most frequented port cities, 54 percent are from the West Coast, 33

percent from the Gulf Coast, and five percent from the East Coast.

Information about whether the vessel travels beyond the U.S . EEZ and more than 200 nm from

any shore was provided for 146 commercial fishing vessels. Of those vessels, 75 percent (110

vessel s ) were reported to travel outside the U.S. EEZ. Only 23 percent (33 vessels ) were reported

to engage in Pacific nearshore v oyages.

Large Ferries

Table 2

. 9 summarizes the home/most frequented port for large ferries. The ho me/ most

frequented port s of operation for 51 of 116 ferries (44 percent) are located along the Northeast

Atlantic coast

, concentrated in the cities of New York, NY ; Burlington, VT ; Woods Hole, MA ;

and Cape May, NJ

. The highest home/most frequented port cit y listed for large ferries is Seattle,

WA , where 23 large ferries (20 percent) are located

.Summary of the VGP Vessel Universe March 2013

17 Table 2

. 9

. Home/most frequented port for large ferries

.

Home/Most Frequented U.S. Port City # Vessels

Seattle, WA 23

New York, NY 8

Burlington, VT 6

Woods Hole, MA 6

Cape May, NJ 5

Galveston, TX 5

Larkspur, CA 5

Cedar Island, NC 4

Juneau, AK 4

Ketchikan, AK 4

Hatteras, NC 3

Mobile, AL 3

New London, CT 3

Pittsburgh, PA 3

Port Hueneme, CA 3

Total # Vessels for which Home Port was provided 116

Figure 2.2

- 2 shows the distribution of large ferries by general geographic region of operation.

Figure 2.2

- 2 : Distribution of large ferries by geographic region.

Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from

any shore was provided for 118 large ferries . Of those, 10 were reported to t r avel outside the

U.S. EEZ , while 17 were identified as being engaged in Pacific nearsho re voyages.Summary of the VGP Vessel Universe March 2013

18 Large Cruise Ships

Home/most frequented port cities for 67 of the 112 large cruise ships are located on the East

Coast of the United States

. Fifteen of these vessels operate in and out of New York, NY and

three operat e out of Boston, MA. Forty

- seven of the large cruise ships have home/most

frequented ports listed along the Atlantic coast of Florida, primarily in Miami (17), Port

Everglades (11), Port Canaveral (9)

, and Fort Lauderdale (8). There are 17 large cruise ships

with port cities l ocated along the West Coast, while eight ships have home ports along the Gulf

Coast

. Thirteen large cruise ships have home ports located outside of the U.S. Home/most

frequented p ort was not listed by 15 respondents

. Figure 2.2

- 3 shows the distribution of large

cruise ships by primary area of operation.

Figure 2.2

- 3 : Primary area of operation reported for large cruise ships

.

Information about whether the vessel travels beyo nd the U.S. EEZ and more than 200 nm from

any shore was provided for 114 large cruise ships . Of those, 84 (74 percent) were reported to

trav el outside the U.S. EEZ while 34 were engaged in Pacific nearshore voyages.

Medium Cruise Ships

The home/most frequented ports listed for six of the 22 medium cruise ships were located along

the Florida coast . F our ships operate along the Northeast Atlantic Coast in New York City , NY

, Boston, MA and Newport, RI

. F our medium cruise ships operate alon g the Alaskan and

Hawaiian coasts and two operate in the Caribbean . Figure 2.2

- 4 shows the distribution of

medium cruise ships by primary area of operation

.Summary of the VGP Vessel Universe March 2013

19 Figure 2.2

- 4 : Primary a rea of o peration for m edium c ruise s hips

.

Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from

any shore was provided for 19 medium cruise ships. Thirteen of the 19 medium cruise ships (68

percent) travel outside the U.S. EEZ and only four are report ed to engag e in Pacific nearshore

voyages.

Research Vessels

Table 2

. 10 provides information on the h ome /most frequented port information , for which 70 of

the 82 research vessels (85 percent) provided information

. Eleven vessels list ed Seattle, WA as

their home/ m ost frequented port city , followed by Galveston, TX (8) and Honolulu, HI (6). A

total of 33 U.S. cities were listed, of which 20 were listed as home /most frequented port for only

a single vessel. The seven cities listed in Table 2

. 10 account for 41 of the 70 (59 percent)

research vessels.

Table 2

. 10 . Top seven home/ most frequent ed port cities for research vessels.

Home/Most Frequent U.S. Port # Vessels

Seattle, WA 11

Galveston, TX 8

Honolulu, HI 6

Guam 5

Houston, TX 5

Pascagoula, MS 3

Tampa, FL 3

Total # Vessels for which Home Port was provided 70

Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from

any shore was provided for 79 research vessels : 67 of these (85 percent) traveled outside the U.S.

EEZ and 33 engaged in Pacific nearshore voyages.Summary of the VGP Vessel Universe March 2013

20 Emergency Vessels

Informat ion on home/most frequented port city was provided for 55 of the 56 emergency vessels,

which include d a total of 34 different U.S. cities/ports

. Only three cities ( Galveston, TX, Long

Beach, CA, and Port Angeles, WA ) were reported to have f our or more covered emergency

vessels.

A total of 50 of the 56 emergency vessels (89 percent) reported travel ling beyond the U.S. EEZ,

and 42 (75 percent) reported engaging in Pacific near shore voyages.

Other Vessels

Information on home/most frequente d port was provided for a total of 8,323 “Ot her ” vessels,

6,356 of which provided a specific city. While a number of r esponses contained multiple

home/most frequented cities , a total of 212 unique cities were identified. New Orleans, LA was

the highest ran king home /most frequented port (22 percent), followed by Houston, TX (10

percent) and Los Angeles, CA (6 percent) . The top 10 home/most frequented port cities account

for over 61 percent of the “O ther ” vessels ( Table 2

. 11 ). On a regional basis, the Gulf Coast

account s for 49 percent of the home /most frequented ports, followed by the Northeast coast (16

percent) and Southwest coast (12 percent). Inland ports accounted for seven percent of

home /most frequented ports, while Alaskan and Hawaiian cities each accounted for less than one

percent.

Table 2

. 11 . Top 10 Home/ most frequent ed port cities for “O ther ” vessels.

Home / Mos t Frequent US Port # Vessels

New Orleans, LA 1,405

Houston, TX 669

Los Angeles, CA 400

New York, NY 347

Port Fourchon, LA 225

Long Beach, CA 214

Baltimore, MD 176

Seattle, WA 176

Norfolk, VA 163

Houma, LA 152

Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from

any shore was provided for 11,627 “O ther ” vessels : 9,105 (over 78 percent ) were reported to

travel outside the U.S. EEZ . Permittees reported 2,272 “Other” vessels (o ut of 9,659 responses)

were engaged in Pacific nearshore voyages.Summary of the VGP Vessel Universe March 2013

21 2.2.1.5 Crew and Passengers

Table 2

. 12 provides a summary of the maximum crew and passenger capacity for vessels having

submitted an NOI

. As shown, the large/medium cruise ships and large ferries have a greater

capacity for person s (includes crew and passengers) onboard than other vessel types

. The

maximum number of people (crew and passengers) aboard large cruise ships and ferries is at

least an order of magnitude greater than for any other vessel type. Barges , on the other hand, tend

to operate with fewer persons on board , and are assumed to be unmanned in many cases. T he

majority of barge operators ( approximately 6,900 ) did not list any information for maximum

capacity

. EPA assumes that th ese barges are unmanned and/or unpowered, and that a blank

response likely meant “zero persons. ” The distribution of maximum persons aboard any given

type of vessel is graphically displayed in Figures 2.2

- 2 and 2.2

- 6

.

Table 2

. 12

. Summary s tatistics of m aximum crew and passenger capacity for vessels having

submitted an NOI

.

11 EPA notes that more than 6,900 owners/operators of barges did not s ubmit any information on the maximum

number of persons. As discussed above, s ince the vast majority of barges are unmanned, EPA assumes that barges

that did not respond are unmanned. S tatistic Barge Comm.

Fishing Oil and

Gas

Tanker s Large

Ferr ies Large

Cruise

Ship s Med.

Cruise

Ship s Research Emerg

. Other

Min imum 1 4 2 8 560 95 5 6 2

25th percentile 2 11 25 307 1,900 208 33 16 20

Median 4 22 29 559 3,455 315 41 16 25

75th percentile 20 35 32 1,042 4,200 557 60 50 30

Max imum 336 192 70 6,012 8,460 800 150 56 6,014

# Non

- zero

R esponses 284 78 2,530 115 113 19 81 53 9,129

S tatistic Barge 11 Comm.

Fishing Oil and

Gas

Tanker s Large

Ferr ies Large

Cruise

Ship s Med.

Cruise

Ship s Research Emerg

. Other

Min imum 1 4 2 8 560 95 5 6 2

25th percentile 2 11 25 307 1,900 208 33 16 20

Median 4 22 29 559 3,455 315 41 16 25

75th percentile 20 35 32 1,042 4,200 557 60 50 30

Max imum 336 192 70 6,012 8,460 800 150 56 6,014

# Non

- zero

R esponses 284 78 2,530 115 113 19 81 53 9,129Summary of the VGP Vessel Universe March 2013

22 Figure 2.2

- 5 : Distribution of maximum persons (crew and passengers) aboard vessels of a

given type.Summary of the VGP Vessel Universe March 2013

23 Figure 2.2

- 6 : Distribution of maximum persons (crew and passengers) aboard vessels of a given

type (continued).Summary of the VGP Vessel Universe March 2013

24 2.2.2 Ballast Water and Related Information

2.2.2.1 Ballast Water Capacity

Table 2

. 13 provides a summary of ballast water capacity 12 for vessels within the NOI database

. Oil and gas tankers possess substantially greater ballast water ca pacity (median capacity of

23,893 m 3 ) compared to other vessel types

. V essels designated as “Other” in the NOI database

tend to have a much larger ballast capacity (median ballast capacity is 10,198 m 3 ) than for

vessel s specifically identified by type

, reflect ing the large number of cargo carr iers sub

- classified

under “Other” by respondents (see section 2.2.1.1 of this document ).

Table 2

. 13 . Statistical summar y of ballast capacity for vessels in the NOI.

Statistic Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Minimum 0.76 34 0.09 17 19.4 9 14 12 1

10th Percentile 143 4

, 279 41 32 752 33 79 36 83

25th Percentile 166 17

, 049 168 97 2,151 204 206 200 1,710

Median 206 23

, 893 1,388 404 3,136 364 425 332 10,198

75th Percentile 1,030 42

, 350 6,775 1,631 4,334 742 814 552 23,497

90th Percentile 1,665 68

, 306 25,756 9,141 6,563 2,043 2,278 14,775 34,405

N (sample size) 4,849 2,650 129 43 105 17 72 37 9,587

The relationship between vessel tonnage and ballast water capacity is compared to the

relationship between vessel length and ballast water capacity in Figure 2.2

- 3 through Figure

2.2

- 4

. Overall, vessel tonnage is a slightly better predictor of ballast water capacity than length

except for emergency vessels. Note: the distribution of b allast water capacity displayed in the

figures has been truncated as appropriate to eliminate the influence of obvious outliers ( as

discussed in section 1.3 of this document ).

12 All values for ballast water capacity here and throughout this documen t have been converted to cubic meters (m 3 )

assuming 1 m 3 equals 264.17 gallons.Summary of the VGP Vessel Universe March 2013

25 Figure 2.2

- 7 : Relationship between vessel tonnage (GT) an d ballast water capacity for

vessels identified in the NOI database

.Summary of the VGP Vessel Universe March 2013

26 Figure 2.2

- 8 : Relationship between vessel tonnage (GT) an d ballast water capacity for

vessels identified in the NOI database (continued)

.Summary of the VGP Vessel Universe March 2013

27 Figure 2.2

- 9 : Relationship between vessel length and ballast water capacity for vessels

identified in the NOI database

.Summary of the VGP Vessel Universe March 2013

28 Figure 2.2

- 10 : Relationship between vessel length and ballast water capacity of for vessels

identified in the NOI database (continued)

.

2.2.2.2 Ballast water management, tank cleaning, and sediment disposal

Ballast Water Management

R esponses on the NOI regarding whether a vessel has a ballast water management plan (BWMP)

is summarized by vess el type in Table 2

. 14 . Nearly all oil and gas tankers

, most large cruise

ships

, and vessels designated as “Other” indicated having a BWMP

. M ost large ferries indicated

in their NOI that they d id not have a BWMP

. Approximately half (50 percent) of barges did not

identify whether they had a BWMP

.

Table 2

. 14 . Percentage of vessels within a given type where use/non

- u se of a ballast water

management plan (BWMP) has been indicated.

Existing BWMP? Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Yes 23 % 98 % 82 % 15 % 91 % 73 % 78 % 88 % 91 %

No 27 % 1 % 13 % 78 % 8 % 27 % 6 % 12 % 7 %

Not Indicated 50 % 1 % 5 % 7 % 1 % 0 % 16 % 0 % 2 %

Tank Cleaning Frequen cy

Responses on NOIs regarding the frequency of ballast tank cleaning var y widely as summarized

in Table 2

. 15

. The frequency of b allast tank cleaning for most vessels occurs every 1 to 5 years

and coincides with dry dock ing . Notable exceptions include large cruise ships

, where ballast

tanks are cleaned more frequent ly (less than one year)

, an d barges

, where ballast tanks are rarely

cleaned. The frequency of b allast tank cleaning varies most within oil and gas tankers.Summary of the VGP Vessel Universe March 2013

29 Table 2

. 15 . Summary of the fre quency of ballast tank cleaning for vessel types (V alues

reflect percentage of vessels for which a response was provided)

.

Frequency Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Every 5 years or more

(i.e., rarely) 47 % 2 % 14 % 0 % 14 % 6 % 16 % 9 % 1 1 %

Other (periodical,

mostly at dry dock) 30 % 42 % 19 % 27 % 1 4 % 38 % 19 % 1 0 % 5 4 %

Every 1 to 5 years 1 % 29 % 45 % 25 % 26 % 12 % 2 3 % 77 % 21 %

Less than 1 year 1 % 23 % 9 % 0 % 4 1 % 19 % 31 % 2 % 10 %

Every voyage 0 % 2 % 0 % 0 % 0 % 0 % 0 % 0 % 0 %

Not applicable/

No Ballast 21 % 2 % 1 3 % 48 % 5 % 25 % 11 % 2 % 4 %

Total # Responde nts 7,427 2,554 127 69 1 05 16 7 4 56 8,724

Sediment Disposal

B allast water sediment disposal methods by vessel type are summarized in Table 2

. 16 . Ballast

water sediment disposal for most vessels occurs onshore at shipyards via a third party during dry

docking. L arge and medium cruise ships, oil and gas tankers, and “Other” vessels als o identified

offshore /overboard ballast sediment disposal as a commonly used method ( Figures 2.2

- 11 and

2.2

- 12).

Table 2

. 16 . Summary of ballast water sediment disposal methods for vessel types ( V alues

reflect percentage of vessels for which a response was provided ).

Methods Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Onshore at shipyards

via third party 7 8 % 37 % 81 % 50 % 72 % 49 % 55 % 8 4 % 7 0 %

Onshore/Landfill 0.2 % 4 % 0 % 2 % 0 % 0 % 2 % 4 % 0 %

Onshore or Offshore 0 % 19 % 0 % 0 % 10 % 13 % 7 % 4 % 7 %

Offshore/overboard 0.8 % 37 % 6 % 6 % 18 % 19 % 8 % 5 % 1 6 %

Not applicable/

No Ballast 21 % 3 % 13 % 42 % 0 % 19 % 28 % 3 % 7 %

Total # Respond ents 6,950 2,521 123 62 97 16 74 56 8,529Summary of the VGP Vessel Universe March 2013

30 Figure 2.2

- 11 : Sediment disposal methods based on NOI submittals

.Summary of the VGP Vessel Universe March 2013

31 Figure 2.2

- 12 : Sediment disposal methods based on NOI submittal (continued)

.Summary of the VGP Vessel Universe March 2013

32 2.2.2.3 Experimental ballast water treatment systems and d ischarge of residual biocides

The use of an experimental ballast water treatment system that results in the discharge of residual

biocides was indicated by 26 vessels ( two oil and gas tankers

, one medium c ruise ship

, and 23

“Other” vessels )

. One oil and gas tanker reported a residual discharge of bi

- sulfite (the other oil

and gas tanker did not provide information on discharge type)

, and the medium cruise ship

reported a residual discharge of sodium hypochl orite.

Of the 23 “O ther” vessels, five of them were cargo carriers and 18 were an unspecified subtype.

Information on the type of residual biocide present in the discharge was provided for only one of

the 23 vessels. The residual biocide discharged was total residual chlorine.

2.2.3 Applicable Discharge s and Related Information

2.2.3.1 Applicable discharges

The 2008 VGP NOI identified 26 types of vessels discharges

. Table 2

. 17 pro vides a rank of the

vessel discharges reported by vessel type (from high to low ). The five most prevalent discharges

for each type of vessel are indicated by light gray shading and bold type font. Deck washdown

and runoff is reported as a top five discharg e in all nine vessel types/categories . A nti

- fouling

hull coatings is a top five discharge in seven vessel types/categories, followed by cathodic

protection and ballast water (6 vessel types/categories each), firemain systems (5), seawater

cooling overboar d discharge (4), bilgewater/oily water separator effluent (3), and graywater (2).

Aqueous film forming foams (AFFF) is a top five discharge in emergency vessels, while

underwater ship husbandry and welldeck discharge s are top five discharges in barges ( Table

2

. 17 ). The top 10 discharges of the “ Other ” vessel type/category largely reflect those reported for

cargo carriers.Summary of the VGP Vessel Universe March 2013

33 Table 2

. 17

. P ercentage of vessels where the applicable discharge listed is reported.

(Note: the 26 applicable discharges listed represent the poss ible discharges liste d on the 2008 VGP NOI

. T he top five applicable discharges

for each NOI vessel type are shaded. )

Applicable discharge Type Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Ballast Water 29 % 99 % 87 % 28 % 90 % 74 % 82 % 96 % 94 %

Seawater Cooling Overboard Discharge <1 % 97 % 53 % 73 % 96 % 100 % 15 % 2 % 14 %

Deck Washdown and Runoff 99 % 97 % 67 % 9 8 % 99 % 95 % 90 % 96 % 96 %

Graywater <1 % 97 % 59 % 28 % 65 % 79 % 29 % 48 % 35 %

Firemain Systems <1 % 95 % 59 % 91 % 96 % 95 % 24 % 11 % 41 %

Chain Locker Effluent <1 % 90 % 51 % 25 % 62 % 68 % 73 % 57 % 72 %

Bilgewater/Oily Water Separator Effluent 25 % 89 % 23 % 38 % 58 % 68 % 87 % 57 % 85 %

Boiler / Economizer Blowdown <1 % 89 % 7.2 % 24 % 58 % 63 % 29 % 9 % 61 %

Cathodic Protection 9.4 % 88 % 54 % 8 2 % 95 % 100 % 80 % 95 % 82 %

Anti

- fouling Hull Coatings 5.3 % 87 % 55 % 82 % 90 % 95 % 88 % 91 % 78 %

Refrigeration and Air Condensate Discharge <1 % 82 % 54 % 48 % 85 % 79 % 16 % 4 % 19 %

Distillation or Reverse Osmosis Brine <1 % 72 % 5.8 % 3.4 % 85 % 58 % 13 % 0 % 12 %

Non

- oily Machinery Wastewater 2.6 % 71 % 16 % 38 % 55 % 68 % 5 % 5 % 13 %

Aqueous Film Forming Foams <1 % 68 % 9.4 % 50 % 51 % 37 % 54 % 82 % 43 %

Small Boat Engine Wet Exhaust <1 % 67 % 9.4 % 42 % 76 % 63 % 9 % 4 % 3.5 %

Underwater Ship Husbandry 26 % 64 % 10 % 12 % 76 % 58 % 1 % 34 % 2.5 %

Controllable Pitch Propeller Hydraulic Fluid <1 % 64 % 12 % 42 % 82 % 79 % 73 % 54 % 55 %

Seawater Piping Biofouling Prevention <1 % 60 % 3. 6 % 10 % 73 % 16 % 0 % 2 % 1.1 %

Exhaust Gas Scrubber Washwater Discharge <1 % 56 % 2. 2 % 3.4 % 30 % 11 % 0 % 0 % <1 %

Graywater Mixed with Sewage 1.4 % 53 % 48 % 29 % 54 % 53 % 4 % 2 % 4.5 %

Freshwater Layup <1 % 35 % 8.7 % 15 % 32 % 26 % 5 % 2 % 9 %

Gas Turbine Wash Water <1 % 22 % 2.2 % 4.3 % 27 % 0 % 0 % 2 % 1.6 %

Welldeck Discharges 22 % 17 % 2.9 % 7.8 % 28 % 16 % 4 % 0 % 1.4 %

Motor Gasoline and Compensating Discharge <1 % 13 % 2.2 % 4.3 % 27 % 5.3 % 0 % 2 % 1.3 %

Elevator Pit Effluent <1 % 11 % < 1 % 19 % 42 % 37 % 1 % 0 % 1.3 %

Sonar Dome Discharge <1 % 3.3 % <1 % 4.3 % 27 % 0 % 4 % 0 % 0 %

Percentage of owners/operators responding 96 % 82 % 95 % 98 % 89 % 86 % 100 % 100 % 80 %Summary of the VGP Vessel Universe March 2013

34 2.2.3.2 Onboard treatment systems for generated waste streams

Indication of o nboard treatment systems and the corre sponding treated waste stream is summarized in Table

2

. 18

. The majority of oil and gas tankers and large cruise ships (approximately 80 percent ) have onboard

treatment systems of some type . Many of the se vessels have multiple treatment systems for a variety of waste

streams. The mo st common generated waste streams were oily water

, bilgewater and sewage/sanitary water

. 13

V ery few barges reported having onboard treatment systems for generated waste streams

.

Within the large subset of “O ther ” vessels sub

- classified as cargo carriers, a pproximately 88 percent (1,774 of

2,044) reported an onboard treatment system

. The type of w aste stream treated was identified by 1,607 cargo

carriers (79 percent ). T he most prevalent waste stream treated aboard bulk cargo carriers w as oily water (82

percent ), followed by sewage/sanitary water (54 percent). Bilgewater was reported at 28 percent (see footnote

“a” in Table 2

. 18 below)

.

Table 2

. 18

. Presence of onboard treatment systems per vessel type and a summary of the types of

generated waste streams that were treated

( Note: values reflect the number of vessels responding with the percentage for that class of vessels in

parentheses )

.

Onboard Treatment

Systems? Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

No 18,970

( 93 ) 156

(5) 82

(56 ) 65

(55) 14

(11) 8

(36) 16

(20) 32

(57) 2,377

(19)

Yes 114

( 1 ) 2,551

(78) 60

(41 ) 53

(45) 100

(79) 11

( 50) 64

(78) 24

(43) 7,586

(61)

Total # Respondents

(Percent ) 19,084

(94) 2,707

(83) 142

(97 ) 118

(100) 114

(90) 18

(82) 80

(98) 56

(100) 9,963

(80 )

Type of Generated Waste Stream and the Corresponding N umber (#) of Vessels that Treated it.

Unspecified / Response

Not provided 65 1,361 19 42 13 3 50 21 2,370

Wastewater (AWS) 17 79 0 0 18 0 0 0 0

Graywater 11 44 2 7 17 2 2 1 351

S ewage /Sanitary 10 629 4 8 18 3 14 1 2,433

Oily water a 13 1,413 31 0 36 3 26 0 3,9 26

Bilgewater a 3 500 8 1 53 6 11 3 1,588

Sludge 0 0 0 0 1 0 2 0 0

Lube oil separator 0 0 0 0 1 0 0 0 0

Incinerator 0 0 0 0 0 0 2 0 218

Seafood processing

waste 0 0 2 0 0 0 0 0 0

AWS = Advanced Wastewater System

.

a Though o ily water and bilgewater are generally considered the same waste stream generated/ treated aboard vessels , t hese waste streams are listed

separately in this table to reflect the actual description provided by NOI respondents.

13 As discussed in Part 1.2.3.2 of the VGP, discharges of sewage are regulated under section 312 of the CWA and do not require a n

NPDES permit.Summary of the VGP Vessel Universe March 2013

35 2.2.4 Anti

- fouling Hull Coatings and Related Information

2.2.4.1 Type of coating

Table 2

. 19 provides a summary of anti

- fouling hull coatings used on vessels. With the exception of barges, t he

use of an anti

- fouling hull coating was reported for 80 percent or more of vessels

. M ost w ere organo tin

- free

,

copper

- based anti

- fouling paints that are complia nt with current IMO regulations (e.g., International

Inter clene TM 245 or International Intersmooth TM 640, AmeronTM ABC #3, Hempel OlympicTM 7660 ). In a

limited number of instances

, the hull c oating reported w as “ anti

- foulant free ” epoxy coating.

O f the 12,401 vessels categorized as “O ther ” in the NOI database, 42 percent (5,155) reported the application of

a tributyltin (TBT)

- free anti

- fouling hull coating, while 24 percent indicated a copper

- based anti

- fouling paint

used to coat the hull of their vessel.

Table 2

. 19 . Summary of anti

- fouling h ull coatings use d on v essels as reported on the vessels’ NOI s

. ( Note:

v alues reflect the total numb er of vessels for which a response was provided, with the corresponding

percentage within a class of vessels in parentheses).

Anti

- fouling Hull

Coating ? Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

No 8,542

(42) 8

(0.2) 10

(7) 13

(11) 0 0 2

(3) 2

(4) 912

( 8 )

Yes 838

( 4 ) 2,630

(80) 124

(85) 102

(86) 107

(84) 18

(82) 78

(95) 54

(96) 8,072

(65)

Uncertain 149

(<1) 21

(0.6) 0 1

(0.8) 3

(2) 1

(5) 0 0 539

(4 )

Total # Respondents

(Percent of total) 9,529

(47 ) 2,659

(81 ) 135

(92 ) 116

(98 ) 1 09

(86 ) 19

(83 ) 80

(98 ) 56

(100) 9,523

(77 )

2.2.4.2 A nti

-

fouling hull coa ting application and hull husbandry practices

Hull Coating Applications

Table 2

. 20 provides a summary of the number of years since the last ant i

- fouling hull coating was applied.

With the exception of barges, most vessels (90 percent) received an anti

- fouling hull coating within the last

three to five years. The shortest median time interval between hull coatings was two years for medium cruise

ships , and the longest was 5 years fo r barges. The longest overall time interval between hull coatings was 81

years for a barge built in 1930.

T he date of last application of anti

- fouling coating and last dry dock coincide for a large portion of vessels ( e.g.,

approximately 43 percent of oi l and gas tankers and bulk cargo carriers and 70 percent of barges )

.Summary of the VGP Vessel Universe March 2013

36 Table 2

. 20 . Summary statistics depicting number of years since last anti

- fouling hull coating was applied.

Statistic Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Minimum 1 1 1 1 1 1 1 2 1

10th Percentile 2 2 2 2 2 2 2 2 2

25th Percentile 3 2 2 2 3 2 2 3 2

Median 5 3 3 3 3 2 3 4 3

75th Percentile 8 4 4 4 4 3 4 4 4

90th Percentile 11 5 4 5 5 3 5 6 5

Maximum 81 19 12 37 7 4 6 7 68

N (sample size) 2,011 2,606 127 117 109 18 80 23 8,80 5

Table 2

. 20

, depicting the number of years since last anti

- fouling hull coating at the time of NOI coverage

, is

consistent with Table 2

. 21 showing the frequency with which hull husbandry practices were employed. Most

vessel s for which NOI data are available are cleaned at either a dry doc k

, every 2 to 5 years

, or as needed

. EPA

categorized the information received int o hull husbandry practices done in association with dry docking and

hull husbandry practices not done in association with dry docking.

Table 2

. 21 . Summary of the frequency with which hull husbandry practices are utilized for vessels

. (V alues represent actual number of responses)

Frequency Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Frequency of hull husbandry practice employed not associated with dry dock

Annual (or less) 12 75 0 6 25 3 10 2 294

Every 2 to 5 years 183 201 64 7 23 0 7 6 901

Less than once per 5

years 82 33 0 0 0 0 0 0 0

As needed 233 256 0 4 3 4 1 1 1,530

Frequency of dry docks when hull husbandry practices employed

At dry dock

unspecified 378 960 22 25 11 5 24 2 3,361

Annual (or less) 0 75 1 0 0 0 0 0 6

E very 2 to 5 years 84 414 25 20 18 7 27 42 1,154

L ess than once per 5

years 15 109 1 0 0 0 0 1 0

As needed 5 49 2 0 10 0 3 1 290

Hull Husbandry Practices

Table 2

. 22 highlights some of the more common hull husbandry practices for NOI vess els and the number of

respondents who listed them. The m ost common practices includ e the use of power washing or a

scraping / power washing / sand blasting combination, after which the anti

- fouling coating is re

- applied, as

needed.Summary of the VGP Vessel Universe March 2013

37 Table 2

. 22 . Summary of hull husbandry cleaning practices for NOI vessels

. ( Note: v alues represent actual number of responses)

. 14

Practice Barges Oil and

Gas

Tankers Comm.

Fishing Large

Ferries Large

Cruise

Ship Med.

Cruise

Ship Research Emerg. Other

Power washing only 523 992 31 21 12 3 14 45 1,723

Power washing +

sand blasting 141 0 0 15 2 3 6 3 1,630

Sand blasting only 137 294 4 7 4 0 6 0 771

Scraping + power

washing 55 0 0 0 0 0 4 0 106

Scraping only 21 381 4 0 0 0 5 0 64

Scraping + sand

blasting 19 0 0 0 0 0 5 0 81

Scraping, power

washing and/or sand

blasting 13 0 14 0 0 0 1 0 112

Hosed off with water

only 6 0 0 1 6 1 2 0 79

Light scraping /

Scrubbing with or w/o

D etergent 3 0 0 3 33 4 0 0 126

Underwater Divers 0 0 0 1 24 1 0 0 566

Othe r 0 225 1 0 0 0 0 0 380

Contingent on

Shipyard practice 0 170 0 0 0 0 0 0 0

2.3 Characterization of Vessels with Missing Information

The NOI database includes data for 43,431 vessels with an active or certified NOI status

, 6,468 of which have

missing tonnage and/or ballast water capacity information. This section of the document characterizes the 6,468

vessels with incomplete NOI s using information from other data sources.

2.3.1 Data Sources

A primary data source on vessel population characteristics is the U.S. Coast Guard’s MISLE database (USCG,

2009) which contains a wide range of information on vessel characteristics, accidents, marine pollution

incidents, and other pertinent information tracked by the U.S. Coast Guard. The database has a broad scope and

encompasses information on vessels covered in other public dat a sources such as the U.S. Coast Guard’s

Merchant Vessels of the United States ( VESDOC ) data file for documented vessels and the U.S. Army Corps of

Engineers’ Waterborne Transportation Lines of the US (WTLUS) data.

N early one million vessels that operate in U.S. waters are included in the MISLE database with vessel data

including :

Identification number(s)

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

Size (e.g., weight, length, breadth, depth)

Area of operation (e.g., hailing port, route type)

Pas senger and crew capacity

Propulsion (i.e., method, engine type, and horsepower)

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

Year built or age

14 The number of hull husbandry pr actices used may be underrepresented. When respondents listed multiple practices on their NOI,

only the first listed practice was used for this data set.Summary of the VGP Vessel Universe March 2013

38 In compiling MISLE data, the U.S. Coast Guard largely relies o n documents submitted by vessel owners or

operators in accordance with vessel documentation requirements (e.g., certificate of documentation) or on

information gathered by U.S. Coast Guard staff directly (e.g., during inspections, vessel boardings, or acci dent

investigations). T he scope of the data included in MISLE is driven in part by the regulatory requirements to

which different types of vessels are subject and by activities conducted by U.S. Coast Guard offices. Therefore,

MISLE is generally most compr ehensive for those vessels that are documented, state registered, and/or subject

to inspection requirements. Thus, the vessels in the MISLE database are often times the same vessels that are

required to submit a completed NOI for coverage under the VGP. T his overlap help ed EPA bolster NOI forms

that we re submitted with missing or incomplete information.

The U.S. Coast Guard maintains a separate database, the NBIC , with information from ballast water reports

submitted by all ballast tank

- equipped vessels entering U.S. waters. The information provided in NBIC

includes :

V essel name

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

Area of operation ( hailing port, or state )

Route information ( arrival date and last port at which the vessel was called )

I n formation on ballast water management practices (e.g., ballast capacity, volume discharged).

EPA obtained NBIC data on foreign and domestic flag arrivals to U.S. ports during calendar year 2005. These

data were used to estimat e the economic benefits of the final VGP (Abt Associates, 2008). When the MISLE

data failed to fully complete the missing information on a vessel’s NOI, NBIC data w ere used to fill in data

gaps where possible

.

2.3.2 Methodology

EPA used the Call Sign, Primary VIN, and IMO Number fields to match NOI data to entries in the MISLE

database. 15 E ntries listed as blank, “N/A,” “None,” “na,” or “Unknown” in the NOI form were not compared to

the database.

For the vessels in the NOI database where information is incompl ete

, EPA used the information from MISLE

only if the MISLE record was deemed sufficiently reliable based on the matched information. 16 In general, data

compared between the NOI and MISLE databases match ed reasonably well

. Of the 32,199 17 vessels that were

found to match between the NOI and MISLE databases ( based on their Call sign, Primary VIN, or IMO

number), 54 percent have names that match exactly. In other instances, the names are only slightly different

(e.g., “IB935” vs. “IB 935” or “M/V Mendocino” v s. “Mendocino ”). Over three quarters of the matched vessels

(79 percent) have values reported for vessel tonnage that are exactly the same in the two databases, while about

86 percent have values that are within 10 percent of each other (difference often s eemingly due to rounding). 18

15 Note that while the call sign, VIN, and IMO number should be unique to each vessel, both the NOI an d MISLE databases contain

multiple entries for the same identifier (not necessarily corresponding to each other). For example, in cases where a matching

algorithm identified multiple vessels with the same identifier, the matched information did not always correspond to the same vessel.

16 EPA deemed the MISLE data sufficiently reliable if at least one of the following MISLE entries corresponded to the NOI data:

vessel name matched, the vessel tonnage was within 10%

, or the vessel length s were within 10%

. 17 Out of the 43,431 uniquely identified vessels with active NOIs

. 18 Note that MISLE does not specify if the vessel tonnage, which is recorded in the field “gross tons”, is reported as gross ton s (GT) or

gross registered tons (GRT). For the purpose of this an alysis, EPA compared the exact values in MISLE to the values reported in the

NOIs and did not adjust for potentially different units. EPA noticed when reviewing data for vessels for which the identifyin gSummary of the VGP Vessel Universe March 2013

39 Over half of the vessels (56 percent) have the exact same length, while 84 percent have lengths that are within

10 percent of each other.

This high matching rate suggests that MISLE may be a reasonable source of data from which to draw additional

information when the NOI contains insufficient information.

2.3.3 Summary and Analysis of NOI Vessels with Incomplete Information

Of the 6,468 vessels for which NOI information was m issing or insufficient, vessel tonnage recorded in MISLE

( or ballast capacity recorde d in NBIC ) was available to supplement the NOI for slightly more than a quarter

(1,80 1) of these vessels

. As shown in Figure 2.3

- 1 , o ver half of the barges, roughly a third of the “Other”

vessels

, and just under 10 percent of the oil or gas tankers with incomplete NOI forms were able to be

supplemented by data from either the MISLE or the NBIC . Information on vessel tonnage and/or ballast

capacity remains missing or insufficient fo r 4,667 of the 43,431 uniquely

- identified vessels in the NOI

.

Figure 2.3

- 1 : MISLE and NBIC compatible vessels.

See Appendix B for more detail s regarding the summary of 6,468 vessels with incomplete information.

Generally, EPA found that characteristics of these vessels w ere similar to those discussed in section 2.2 of this

document for which NOI data were sufficient

.

information matched in both databases, that values i n the NOI database reported as GRT often matched values in the MISLE GT field,

suggesting that units may not be defined consistently in the MISLE database as GT.Summary of the VGP Vessel Universe March 2013

40 3 Summary

This document summar izes vessel information in EPA’s NOI database and was prepared to provide useful

information about VGP regulated vessel s and the characteristics and conditions of the ir discharge s

.

The NOI data summarized in this document includes 36,642 uniquely identified vessels that submitted a

complete NOI and 1,801 vessels where vessel tonnage and/or ballast water capacity wa s initially missing. For

this latter group of vessels, EPA used the MISLE and NBIC databases to h elp fill in critical missing information

to better characterize these 1,801 vessels.

Table 3

. 1 below summar izes key characteristics according to vessel type based on the information provided for

the 36,642 ves sels that submitted complete NOIs. In general, the following can be concluded :

General Characteristics and Voyage Related Information

Oil and gas tankers and large cruise ships are the largest of the NOI vessels and also generally the

newest in terms of vessel age.

The maximum passenger and crew capacity for passenger transport and leisure vessels (large cruise

ships, medium cruise ships, and large ferries) greatly exceeds that of any of the other NOI vessel types.

A r elatively large pro portion of commercial fishing and emergency vessels are use d for other purposes,

as noted by the high degree of sub

- classification

. The Gulf Coast is the primary geographic region of operation for working boats (i.e., barges, oil and gas

tankers, commercial fishing vessels) while the Paci fic (Northwest especially)

, Northeast

, and Florida

Atlantic c oasts appear to be the primary regions for passenger transport and leisure vessels (large cruise

ships, medium cruise ships, and large ferries)

. A s ignificant proportion of NOI vessels , except fo r barges and large ferries

, travel beyond the US EEZ

.

Ballast Water and Treatment Related Information

The ballast water capacity of oil and gas tankers greatly exceeds that of oth er NOI vessels

. Ballast sediment is disposed of predominantly onshore, with the exception of a relatively large portion

(37 percent) of oil and gas tankers, which discharge sediment outside of waters covered by the VGP.

Except for barges

, which tend to have comparatively low ballast water capacity, the majority of ballast

wa ter tanks aboard vessels are cleaned at least once every 1 t o 5 years

. Few experimental ballast water treatment systems currently exist aboard NOI vessels.

Discharges and Discharge Related Information

Deck washdown and runoff is the predominant discharge reported for all NOI vessels, followed by anti

fouling hull coatings, cathodic protection, ballast water, and firemain systems

. More than half of the oil and gas tankers, large cruise ships

, and research vessels reported having

onboard treatment systems for generated waste streams

. As would be expected, b arges had the fewest

onboard treatment systems for their generated waste streams.

Oily/bilgewater, sewage/sanitary

, and graywater are the predominant waste streams treated aboard NOI

vessels.Summary of the VGP Vessel Universe March 2013

41 Anti

- fouling Hull Coatings and Related Information

Except for barges, the hulls of greater than 80 percent of all NOI vessels are pr otected with an a nti

fouling hull coating

. Anti

- fouling hull coatings are generally applied at least every 3 years for mo st vessels

. The hulls of all NOI vessel types are cleaned predominantly via power /pressure washing

, with some

vessels also using underwater divers and scrubbing.

The use of the U.S. Coast Guard’s MISLE and NBIC databases was a means of completing critical information

(e.g., vessel tonnage and ballast water capacity) for NOI vessels where such information was lacking. Of the

6,468 vessels for which NOI information was missing or insufficient, vessel tonnage recorded in MISLE or

ballast ca pacity ecorded in NBIC is available for slightly more than a quarter (1,801) of those vessels

. The

characteristics of these vessels (predominantly barges, oil and gas tankers, and “Other” vessels) are similar to

those of vessels for which more complete inf ormation is available in the NOI database

.Summary of the VGP Vessel Universe March 2013

42 Table 3

. 1 . Summary of key vessel characteristics reported in the NOI database by vessel type

.

Subcategory Vessel Type

Barge Oil and Gas Comm. Fishing L arge Ferry Large Cruis e Med ium Cruise Research Emergency

General Characteristics and Voyage Related Information

Median Tonnage (GT)

Median Length (ft)

Median Age (yrs) 705

200

15 24,908

620

6 1,997

265

23 1,451

260

26 53.526

857

11 4,584

420

20 1,780

224

23 563

194

26

Median Dry Dock Interval (yrs ) 4 3 3 3 3 2 3 3

Top Home

/Most Frequented

Ports New Orleans, LA

Jeffersonville, IN

Pittsburgh, PA

St. Louis, MO

Metropolis, IL Houston, TX

New York, NY

Texas City, TX

Galveston, TX

Los Angeles, CA Dutch H arbor

, AK

Seattle, WA

New Orleans, LA Seattle, WA

New York, NY

Burlington, VT

Woods Hole, MA Miami, FL

Pt Everglades, FL

Pt Canaveral, FL

San Diego, CA New York, NY

Boston, MA

Newport, RI Seattle, WA

Galveston, TX

Honolulu, HI Galveston, TX

Long Beach, CA

Port Angeles, WA

Primary Geo Regions Inland

– Ohio R.

Gulf Coast Gulf Coast West Coast

Gulf Coast NE Atlantic

Pacific NW Florida Coast

West Coast NE Atlantic Pacific NW/Hawaii

Gulf Coast Pacific NW

Gulf Coast

Travel Beyond EEZ (%) 2 95 76 8.5 74 68 85 89

Pacific NS Voyage (%) 2 24 23 14 29 21 41 75

Max Crew/Passeng er (Median) 4 22 29 559 3,455 315 41 16

Ballast Water and Related Information

Median Capacity (m 3 ) 206 23,893 1,388 404 3,136 364 425 332

Existing BWMP (%) 2 3 98 82 15 91 73 78 88

Cleaning Frequency 47 % 5 yrs + 42% periodical

(1

- 5 yrs or less) 45 % 1 to 5 yrs 52 % periodical

(1

- 5 yrs) 41 % 1 yr or less 38% periodical

(1 yr or less) 31% 1 yr or less 54% periodical

(1 to 5 yrs)

Discharges and Discharge Related Information

Top Discharges Deck wash/runoff

Ballast water

Underwater Hus

Bilge/Oily water

Welldeck Ballast water

Seawater cooling

Deck wash/runoff

Graywater

Firemain Ballast water

Deck wash/runoff

Graywater

Firemain

Anti

- fouling hull Deck wash/runoff

Firemain

Cathodic Protect

Anti

- fouling Hull

Seawater cooling Deck wash/runoff

Seawater cooling

Firemain

Cathodic Protect

Anti

- fouling hull Seawater cooling

Cathodic Protect

Deck wash/runoff

Firemain

Anti

- fouling hull Deck wash/runoff

Anti

- fouling hull

Bilge/Oily water

Ballast water

Cathodic Protect Deck wash/runoff

Ballast water

Cathodic Protect

Anti

- fouling hull

Aq. Film Foams

Treatment Systems (%) <1 78 42 45 79 50 78 43

Waste Streams Treated with

Systems Wastewater

Graywater

Sewage /Sanitary Oily/Bilge water

Sewage /Sanitary Oily/Bilge water Sewage /Sanitary

Graywater Oily/Bilge water

Sewage /Sanitary

Graywater Oily /Bilge water

Sewage /Sanitary

Graywater Oily/Bilge water

Sewage /Sanitary Oily/ Bilgewater

Anti

- fouling Hull Coatings and Related Information

Antifouling Coating (%) 4 80 85 86 84 82 9 5 96

Yrs Since Last Appl ication

(Median) 4 3 3 3 3 2 3 4

Most Common Husbandry

Practice Pressure wash Pressure wash Pressure wash Pressure wash Scrubbing/D ivers Pressure wash Pressure wash Pressure washVGP NOI Vessel Universe Summary Report March 2013

43 4 References

Abt Associates

, 2008. The Economic and Benefit Analysis of the Final Vessel General Permit . Abt Associates,

Inc., Cambridge, MA.

US C oast Guard (USCG)

, 2009. Marine Information for Safety and Law Enforcement (MISLE) Database . U.S.

Coast Guard, Washington, D.C.

USEPA

, 2008a. Vessel General Permit (VGP). U.S. Environmental Protection

Agency. ( http://www.epa.gov/npdes/pubs/vessel_vgp_permit.pdf ).

USEPA

, 2008b. Final Issuance of National Pollutant Discharge Elimination System (NPDES) Vessel General

Permit (VGP) for Discharges Incidental to the Normal Operation of Vessels: Fact Sheet. U.S. Environmental

Protection Agency.

US EPA, 2010. Report to Cong ress: Study of Discharges Incidental to Normal Operation of Commercial

Fishing Vessels and Other Non

- Recreational Vessels Less than 79 Feet . Report EPA 833

- R

- 10

- 005. August

2010.VGP NOI Vessel Universe Summary Report March 2013

A

- 1 Appendix A

Comparison of the NOI Universe of Vessels versus

the Universe of Vessels in the Final 2008 VGP Economic and Benefit AnalysisVGP NOI Vessel Universe Summary Report March 2013

A

- 2 This appendix summarizes findings from EPA’s comparison of data submitted on NOI s (from June 1, 2009

through August 5, 2010) with prior EPA estimates of the universe of vessels subject to NOI requirements, as

determined during the development of the VGP . The purpose of the comparison is to identify, and wher e

possible

, explain difference s between the expected and actual vessel universe.

The Economic and Benefit Analysis of the Final Vessel General Permit (Abt Associates, 2008) provides

estimates of the number of vessels that would be subject to the VGP in the first five years of the permit period,

including estimates of the number of vessels that would need to submit a completed NOI to EPA. These

estimates were derived mostly from public data sources, namely: (1) the WTLUS data file compiled by the

W aterborne Commerce Statistics Center of the U.S. Army Corps of Engineers (USACE) Navigation Data

Center, (2) the VESDOC data file compiled by the U.S. Coast Guard, and (3) information submitted by the

International Association of Drilling Contractors on mo bile offshore drilling units. Using these data, the number

of vessels required to submit an NOI was estimated at 49,736, including 41,906 domestic vessels and 7,830

foreign vessels. Table A

- 1 summarizes the distribution of vessels required to submit an NOI, by vessel

provenance and class.

Table A

- 1 . Estimates of n umber of vessels required to s ubmit NOI (reproduced from Abt Associates,

2008; Table 3

- 1 and Table 3

- 2 ). 19

Vessel Classes Domestic Vessels Foreign Vessels TOTAL

Count % of Total Count % of Total Count % of Total

Commercial Fishing 26 <1

- - 26 <1

Freight Barge 30,961 74 125 2 31,086 63

Freight Ship 469 1 5,577 71 6,046 12

Passenger Vessel 1,270 3 146 2 1,416 3

Tank Barge 4,808 11 30 <1 4,838 10

Tank Ship 117 <1 1,891 24 2,008 4

Utility Vessel 4,255 10 61 1 4,313 9

Total 41,906 100 7,830 100 49,736 100

Information in EPA’s current NOI database indicate s that 43

, 110 vessels have active coverage under the VGP

as of August 5, 2010

, 20 or about 15 percent less than EPA’s estimate of 49,736 vessels (see Figure A

- 1 and

Table A

- 2 below). Based on these data, EPA overestim ated the number of vessels that would have to submit an

NOI when compared to those that did (41,906 vessels estimated and 29, 278 vessels with active VGP coverage ),

while EPA underestimated the number of foreign vessels that would be required to submit an NOI (7,830

vessels estimated and 13,832 vessels with active VGP coverage ). 21 Much of the differenc e between the pre

permit issuance estimates and number of vessels with active VGP coverage in the NOI is accounted for by

freight barges: over 9,000 fewer fre ight barges than expected submitted an NOI to EPA. The numbers of freight

19 Due to gaps in the publicly available data on domestic vessel tonnage , the estimates develo ped for the VGP conservatively assumed

that, when tonnage information was missing, vessels greater than 78 feet in length were likely to be 300 GT, and therefore, would be

required to submit an NOI.

20 This total includes vessels for which NOI applicabilit y is still uncerta in due to incomplete NOI information (see s ection 2.3 of this

document), but excludes the very small subset of 321 vessels identified as “Not App licable” in section 2.1 which are identified as such

because the tonnage and ballast water capacity reported in the NOI for these particular vessels a re less than 300 GT and /or 8 m 3

, respectively

. 21 To determine do mestic versus foreign vessels, EPA used the Country and State fields. Then, w here those fields were blank, EPA

manually checked the address and company name to determine the country of origin.VGP NOI Vessel Universe Summary Report March 2013

A

- 3 ships, tank ships, and other vessels that submitted NOIs partly offset th is discrepancy, with the actual number of

vessels covered under the VGP exceeding pre

- permit issuance estimat es by about 2,000 vessels in each of the

categories.

Figure A

- 1 : Comparison of number of vessels subject to NOI requirements

– Actual number versus the

number based on earlier VGP estimates.

Table A

- 2. Comparison of a ctual NOI vessels and earlier VGP e stimates

.

Vessel Class NOI Applies Earlier VGP Estimates

Difference Domestic Foreign Total Domestic Foreign Total

Commercial Fishing

Vessel 102 8 1 183 26 26 (157)

Freight Barge 2 1

, 684 123 21, 807 30,961 125 31,086 9, 2 79

Freight Ship 417 7, 5 30 7,947 469 5,577 6,046 (1,901)

NA 1

- 1

- - - (1)

Other 574 1, 724 2, 2 98

- - - (2, 29 8 )

Passenger Vessel 4 50 6 1 511 1,270 146 1,416 905

Public Vessel,

Unclassified 11

- 11

- - - (11)

Tank Barge 3, 362 8 3,370 4,808 30 4,838 1,468

Tank Ship 167 4, 145 4,312 117 1,891 2,008 (2,304)

Utility Vessel 2, 510 160 2,670 4,255 61 4,316 1,646

Grand Total 2 9

, 278 1 3

, 832 43, 110 41,906 7,830 49,736 6, 6 26VGP NOI Vessel Universe Summary Report March 2013

A

- 4 Several factors may explain differences between the vessel population estimate and NOI vessels with active

VGP coverage. Main reasons include:

Missing or incorrect data in vessel databases . While EPA found that public data sources generally

provide reasonably accurate information fo r vessels that submitted an NOI, it is possible

– and even

likely

– that outdated or incomplete data in the public databases used to derive pre

- permit issuance

estimates resulted in an overestimation of vessels subject to NOI requirements. For example, ret ired

vessels are not necessarily removed from the database even as new vessels are added, and duplicate

entries may be present in the database for the same vessel if the vessel information changed. 22

Further more , in cases when information was incomplete, EP A used conservative assumptions when

estimating the number of vessels that would need to submit an NOI ( e.g., in cases where data on vessel

weight was missing, all vessels above 78 feet were assumed to meet the tonnage threshold and to be

required to submit an NOI ) . This is not necessarily the case of actual vessels. In general, errors or

incomplete data in the public database tended to bias pre

- permit issuance estimates upward.

Failure to Submit an NOI or Failure to Correctly C ertify an NOI . It is possible that so me vessels

currently operating i n U.S. waters have not submitted an NOI even though they are required to do so.

Furthermore, some vessel operators may have thought they submitted an NOI successfully; however,

they may h ave failed to certify th e NOI, and therefore, did not receive active coverage. Approximately

3,6 00 vessels remain in archived status in the NOI database. To the extent that vessels otherwise

required to submit a completed NOI have not yet done so, the actu al NOI counts may under

- represent

the universe of vessels subject to NOI requirements.

22 For example, EPA noticed that some vessels with different names or operators share the same identification numbers (e.g., IMO

number), even though this identifier should be unique.VGP NOI Vessel Universe Summary Report March 2013

B

- 1 Appendix B

Summary of vessel characteristics where NOI information was incompleteVGP NOI Vessel Universe Summary Report March 2013

B

- 2 This section summarizes the vessel characteristic data for the 6,468 vessels that lacked complete NOIs

. Using

incomplete NOI data and supplementary data from MISLE or NBIC, as available

, vessel characteristics for each

vessel class are summarized below. A “response” or “information provided” as the terms are used below,

indicate information provided on an incomplete NOI for which the MISLE and NBIC data were used to better

characterize these vessels.

Barges

Vessel General Characteristics and Voyage Related Information

EPA used MISLE or NBIC to supplement incomplete NOI information for 1,029 barges. Only 13 of the 1,029

barges (1 percent ) were further sub

- classified , with those identified as either dredge attendant plants (1 1 barges)

or oil and gas tankers (2).

Consistent with the information provided for the barges with complete NOIs, t he median vessel tonnage, length,

and age of these barges is 764 GT

, 23 200 feet, and 9 years old, respectively

. ( S ee Table 2

. 3 through Table 2

. 5 )

Information on home/most frequented p ort was provided for 326 of these barges (32 percent). Of the 12 cities

indicated as home/most frequented port, St. Louis, MO (75 percent ) and New York, NY (2 1 percent ) were listed

most frequently.

Owners/operators of all but two of the approximately 330 barges for which a response was provided indicated

that their vessel is unmanned (zero maxi mum passengers and crew)

. EPA inferred from this result that the

majority of barges lacking a response for the maximum passengers or crew on their NOI form also were

unmanned.

Ballast Water and Related Information

The NBIC database did not contain any additional ballast water capacity information that could be used to fill in

the gap for the 1,029 barges with incomplete NOIs . Nevertheless, seven owner/operators out of the 342 who did

respond to this question on an incomplete NOI indicate d having an existing BWMP, and 11 owners/operators

provided information regarding ballast sediment disposal (onshore at shipyards via third party) and ballast tank

cleaning frequency (periodic ally ; mostly at dry dock).

No owners/operators indicated having an experimental ballast treatment system aboard their vessels.

Applicable Discharges and Related Information

Of the 26 listed applicable discharges that vessels may generate ( Table 2

. 17 ), the 1,029 barges i dentified only

nine discharge types

. The nine discharge types a re: d eck washdown and runoff (886 out of 1,029 barges),

cathodic protection (79 )

, bilgewater/oily water separator effluent (69), underwater ship husbandry (18), anti

fouling hull coatings ( 13 ), ballast water (5), small boat engine wet exhaust (1)

, exhaust gas scrubber washwater

discharge (1) , and welldeck disch arges (1). This list roughly coincides with the discharge types for barges listed

on complete NOIs ( Table 2

. 17 ).

23 This number assumes that MISLE information is reported as GT since the d atabase does not specify GT or GRT; also see footnote

15.VGP NOI Vessel Universe Summary Report March 2013

B

- 3 No information about o nboard treatme nt systems and corresponding waste streams generated/treated were listed

for any of the barges (i.e., 873 of the 1,029 responded in their NOIs that no systems were on board ; the

remainder did not respond).

Anti

- fouling Hull Coatings and Related Informatio n

Owners/operators of only seven of the 271 barges for which a response was provided in the incomplete NOI

indicated application of an anti

- fouling hull coating

. A ll seven respondents indicated coating their vessels

within the last eight years. Hull husban dry practices, according to the eighteen responders

, generally are

employed every 2 to 5 years or as needed using a power washer while the vessel is at dry dock.

“Other” Vessels

Vessel General Characteristics and Voyage Related Information

Missing information was confirmed using MISLE or NBIC for the 635 “Other” vessels in the NOI database

, only 3 of which were further sub

- classified by the respondents as oil or gas tankers

For these “Other” vessels, t he median vessel tonnage is 27,581

, 24 t he median length is 623 feet, and the median

age is 18 years old . This compares closely with “Other” vessels with complete NOIs which have a median

length of 600 feet and a median age of 11 years old, respectively (See Table 2

. 4 and Table 2

. 5 ).

Respondents provided information on home/most frequented port for only 32 of the 635 “Other” vessels with

incomplete NOIs (5 percent). Of the cities indicated as home/most frequented port (note: a total of only 13

different port cities were listed), 70% of vessels listed cities in Louisiana (Fourchon, New Orleans, Houma),

Alabama (Tuscaloosa, Mobile), or Texas (Houston, Texas City)

.

Where a response was provided regarding maximum passenge r size, 74 out of 77 “Other” vessels responded

that their vessel was unmanned (zero maximum passengers). Of the three remaining respondents, the maximum

passenger size was 2, 4

, and 10. Where a response was provided regarding maximum crew size, 115 “Other ”

vessels indicated a median of 30 maximum crew members. The combination of data for maximum passenger

size and maximum crew sizes results in a median similar to the median for “Other” vessels with complete NOIs

(see Table 2.12).

Ballast Water and Relate d Information

Information regarding ballast water capacity for 273 of 635 “Other” vessels with incomplete NOI data was

available via matching vessels to the NBIC database. The median ballast water capacity for these vessels is

18,707 m 3 , which is nearly tw ice as high as the median value of the “Other” vessels with complete NOIs ( Table

2

. 13 )

. However, these results are similar to the 90 th percentile ballast water capacity (approximately 34,000 m 3 )

.

Affirmative r esponses on NOIs from 476 owner/operators of “Other” vessels (94 p ercent) were provided

regarding the existence of a BWMP. Only 12 owners/operators provided information on their NOI regarding

ballast sediment disposal (11 of them indicating disposal onshore at shipyards via third party), and 13 provided

information on ba llast tank cleaning frequency (11 indicating that their vessel’s ballast tank is cleaned

periodically; mostly at dry dock).

24 This value assumes that this tonnage reflects GT since tonnage units are not specified in MISLE; this value could be over

- estimated

by a factor of approximately 1.7 since 76 respondents indicated that the reported vessel tonnage in the NOI is based on GRT.

Assuming instead that MISLE vessel tonnage values reflect GRT, the median value would be approximately 16,300 GT, which

coincides with the value described previously for the larger subset of “Ot her” vessels in the NOI (i.e., 15,939 GT, see Table 2

. 3 ).VGP NOI Vessel Universe Summary Report March 2013

B

- 4 No owners/operators indicated having an experimental ballast treatment system aboard their vessels.

Applicable Discharges and Rela ted Information

O nly 116 of the 635 “Other” vessels specified the ir generated discharge type on their NOI

. Of the 26 listed

possible applicable discharges, respondents indicate d generating 25 different types (the single exception being

sonar dome discharge ). Deck washdown and runoff and graywater were reported as being discharged from 115

“Other” vessels; cathodic protection, ballast water, and anti

- fouling hull coatings were reported as discharged

from over 90 vessels; and refrigeration and air condensate discharge, bilgewater/oily water separator effluent,

seawater cooling overboard discharge, and non

- oily machinery wastewater were reported as discharged from

over 80 vessels. The list of top five applicable discharges corresponds closely with that of the “ Other” vessels

with completed NOIs ( Table 2

. 17 ).

Onboard treatment systems and corresponding waste streams generated/treated were listed for only 78 of the

635 “Other” vessels. Bilgewater was listed as a waste stream treated by 37 of these vessels, oily water by 10

vessels, and raw sewage/sanitary by seven.

Anti

- fouling Hull Coatings and Related Information

Owners/operators of 71 of the 98 “Other” vessels for which a response was provided indicated application of an

anti

- fouling hull coating, 90 percent of which have coated their vessels within the last six years. Hull husbandry

practices, according to the very few owners/operators who responded (ap proximately 10), are employed as

need ed or every 2 to 5 years, largely while the vessel is at dry dock. Power washing is the hull husbandry

method most commonly employed for nine “Other” vessels

, 25 and scraping and underwater diving for one

vessel each.

Oil or Gas Tankers

Vessel General Characteristics and Voyage Related Information

Missing information in the NOI was confirmed using MISLE or NBIC for 125 oil or gas tankers. The median

vessel tonnage for this particular subset of oil or gas tankers is 57,162 (assumed GT), which is more than twice

the median vessel tonnage for oil or gas tankers with a complete NOI ( i.e., 24,908 GT, see Table 2

. 3 )

. H owever, the 90 th percentile vessel tonnages are relatively similar: approximately 83,700 and 93,000 GT,

respectivel y.

The median length of these vessels with incomplete NO I s is slightly higher (750 feet), and their age (7 years) is

slightly older compared with the information provided for the 3,280 oil or gas tankers with complete NOIs (i.e.,

620 feet and 6 years old , respectively; see Table 2

. 4 and Table 2

. 5 )

. A gain, the 90th percentile values are

relatively similar (i.e., 1,034 feet and 18 years old, respectively).

Home/most frequented port was not indicated for any of the 125 oil or gas tanker s with incomplete NOI forms

, and no information was provided regarding maximum passenger size. Owners/operators of 12 of these oil or gas

tankers did provide maximum crew size, which ranged from 25 to 35 maximum crew members, coincid ing with

the value desc ribed for oil and gas tankers with a complete N OI ( Table 2

. 12).

25 See footnote “a” in Table 2

. 18

.VGP NOI Vessel Universe Summary Report March 2013

B

- 5 Table 2

. 12

Ballast Water and Related Information

Information regarding ballast water capacity for 42 of the 125 oil or gas tankers with incomplete NOI s was

available via the NBIC database. The medi an ballast water capacity for these vessels is 37,866 m 3 , which is 1.6

times higher than the median capacity for oil or gas tankers with complete NOIs (23,893 m 3 ) ( Table 2

. 13 ) . The

90 th percentile ballast water capacity for these vessels , however, is 1.2 times lower than those oil or gas tankers

with complete NOIs (approximately 57,300 versus 67,300 m 3 , respectively).

All owner/operators of the 125 oil or gas tankers have an existing BWMP in place for their vessel, which is

consistent with 98 percent of oil and gas tankers indicated as having a BWMP that submitted a complete NOI

(see Table 2

. 14 ). Only one owner/operator provided information regarding ballast tank cleaning frequency

(every 1 to 5 years), and no respondents provided information in the NOI regarding ballast sediment disposal

for their oil or gas tanker.

No owners/operators indicated having a n experimental ballast treatment system aboard their oil or gas tanker.

Applicable Discharges and Related Information

Only 12 owner/operators of the 125 oil or gas tankers with incomplete NOI s specif ied the applicable discharges

their vessels generate d

. Of these twelve owner/operators , nearly all indicate d discharging 25 discharge types. A

few discharge types not listed as generated for each vessel includes : controllable pitch propeller hydraulic fluid

( only two vessels discharge), graywater mixed with se wage (only a single vessel discharges), welldeck

discharges (only a single vessel discharges), and no vessel reported discharging gas turbine wash water or sonar

dome discharge. This information is consistent with that of the oil or gas tankers with comple te NOIs described

previously in section 2.2.3 of this document

.

Responses affirming the use of an onboard treatment system were provided for only 12 of the 125 oil or gas

tankers; however none of the responses included the corresponding waste streams treated.

Anti

- fouling Hull Coatings and Related Information

Owners/operators of 13 of the 125 oil or gas tankers for which a response was provided ind icated application of

an anti

- fouling hull coating; all of which have coated their vessels within the last four years. No additional

information was provided regarding the hull husbandry practices employed aboard the se vessels, or the

frequency with which they may be implemented.

Miscellaneous Vessel Types S tatistic Barge Comm.

Fishing Oil and

Gas

Tanker s Large

Ferr ies Large

Cruise

Ship s Med.

Cruise

Ship s Research Emerg

. Other

Min imum 1 4 2 8 560 95 5 6 2

25th percentile 2 11 25 307 1,900 208 33 16 20

Median 4 22 29 559 3,455 315 41 16 25

75th percentile 20 35 32 1,042 4,200 557 60 50 30

Max imum 336 192 70 6,012 8,460 800 150 56 6,014

# Non

- zero

R esponses 284 78 2,530 115 113 19 81 53 9,129VGP NOI Vessel Universe Summary Report March 2013

B

- 6 Missing information was confirmed using MISLE or NBIC for an additional eight research vessels, three

commercial fishing vessels, and one medium cruise ship with an active or certified NOI. The vessel

ch aracteristic data provided in the NOI for these uniquely

- identified vessels is similar to the information

previously described for vessels with complete NOIs

.