United States Office of Water EPA 821-R-99-001

Environmental Protection 4303 April 1999

Agency

TECHNICAL DEVELOPMENT DOCUMENT

PHASE I

UNIFORM NATIONAL DISCHARGE

STANDARDS FOR VESSELS OF

THE ARMED FORCES

Technical Development Document

for

Phase I Uniform National Discharge Standards

for

Vessels of the Armed Forces

Naval Sea Systems Command

U.S. Department of the Navy

Arlington, VA 22202

and

Engineering and Analysis Division

Office of Science and Technology

Office of Water

U.S. Environmental Protection Agency

Washington, DC 20460

April, 1999

FOREWORD

This Technical Development Document was produced jointly by the Naval Sea Systems

Command of the United States Navy and the Office of Water of the United States Environmental

Protection Agency. The purpose of this document is to provide, in part, the technical background

that was used to develop the Phase I regulation that is issued under authority of the Uniform

National Discharge Standards provisions of the Clean Water Act, 33 U.S.C., 1322(n).

i

TABLE OF CONTENTS

EXECUTIVE SUMMARY .........................................................................................ES-1

CHAPTER 1. BACKGROUND OF THE UNIFORM NATIONAL

DISCHARGE STANDARDS

1.1 Background ............................................................................................................... 1-1

1.2 Legal Authority and Statutory Requirements for the UNDS Regulations................ 1-2

1.2.1 Discharges.................................................................................................. 1-2

1.2.2 Vessels ....................................................................................................... 1-2

1.2.3 Waters........................................................................................................ 1-3

1.3 UNDS Development Requirements.......................................................................... 1-3

1.4 References................................................................................................................. 1-5

CHAPTER 2. VESSELS OF THE ARMED FORCES

2.1 Introduction............................................................................................................... 2-1

2.2 Description of Vessel Classes and Types.................................................................. 2-2

2.2.1 Vessels of the U.S. Navy ........................................................................... 2-2

2.2.1.1 Navy Mission................................................................................ 2-2

2.2.1.2 Navy Vessel Description .............................................................. 2-2

2.2.2 Vessels of the Military Sealift Command.................................................. 2-5

2.2.2.1 Military Sealift Command Mission.............................................. 2-5

2.2.2.2 Special Mission Support Force..................................................... 2-6

2.2.2.3 Naval Fleet Auxiliary Force ......................................................... 2-6

2.2.3 Vessels of the U.S. Coast Guard................................................................ 2-7

2.2.3.1 Coast Guard Mission.................................................................... 2-7

2.2.3.2 Coast Guard Vessel Description................................................... 2-7

2.2.4 Vessels of the U.S. Army......................................................................... 2-10

2.2.4.1 Army Mission............................................................................. 2-10

2.2.4.2 Army Vessel Description............................................................ 2-10

2.2.5 Vessels of the U.S. Marine Corps............................................................ 2-12

2.2.5.1 Marine Corps Mission................................................................ 2-12

2.2.5.2 Marine Corps Vessel Description............................................... 2-12

2.2.6 Vessels of the U.S. Air Force................................................................... 2-12

2.2.6.1 Air Force Mission....................................................................... 2-12

2.2.6.2 Air Force Vessel Description ..................................................... 2-12

2.2.7 Vessels Not Covered by UNDS............................................................... 2-13

2.2.7.1 Army Corps of Engineers Vessels.............................................. 2-13

2.2.7.2 Maritime Administration Vessels............................................... 2-13

2.2.7.3 Vessels Preserved as Memorials and Museums......................... 2-14

2.2.7.4 Time- and Voyage-Chartered Vessels........................................ 2-14

2.2.7.5 Vessels Under Construction ....................................................... 2-14

2.2.7.6 Vessels in Drydock..................................................................... 2-14

2.2.7.7 Amphibious Vehicles................................................................. 2-14
ii

2.3 Locations of Armed Forces Vessels........................................................................ 2-15

2.3.1 Homeports................................................................................................ 2-15

2.3.1.1 Navy Ports.................................................................................. 2-15

2.3.1.2 Coast Guard Ports....................................................................... 2-15

2.3.1.3 Army Ports.................................................................................. 2-15

2.3.1.4 Military Sealift Command, Marine Corps, and Air Force

 Port Usage................................................................................ 2-16

2.3.2 Operation within Navigable Waters of the U.S. and the Contiguous

 Zone ..................................................................................................... 2-16

2.4 References............................................................................................................... 2-20

CHAPTER 3. DATA COLLECTION

3.1 Introduction............................................................................................................... 3-1

3.2 Surveys...................................................................................................................... 3-1

3.3 Consultations with Department of Defense Personnel Having Equipment

 Expertise .............................................................................................................. 3-2

3.4 Consultation and Outreach Outside the Department of Defense .............................. 3-3

3.4.1 Initial State Consultation Meetings............................................................ 3-4

3.4.2 Second Round of State Consultation Meetings ......................................... 3-4

3.4.3 Consultation with Environmental Organizations....................................... 3-5

3.4.4 UNDS Newsletter and Homepage ............................................................. 3-5

3.5 Sampling and Analysis.............................................................................................. 3-6

3.5.1 Approach to Identifying Discharges Requiring Sampling ......................... 3-6

3.5.2 Approach to Determining Analytes ........................................................... 3-6

3.5.3 Shipboard Sampling................................................................................... 3-7

3.5.4 Quality Assurance/Quality Control and Data Validation Procedures........ 3-8

3.6 References............................................................................................................... 3-10

CHAPTER 4. DISCHARGE EVALUATION METHODOLOGY

4.1 Introduction............................................................................................................... 4-1

4.2 Environmental Effects Determination ...................................................................... 4-1

4.2.1 Chemical Constituents............................................................................... 4-1

4.2.2 Thermal Pollution ...................................................................................... 4-5

4.2.3 Bioaccumulative Chemicals of Concern.................................................... 4-6

4.2.4 Nonindigenous Species.............................................................................. 4-7

4.2.5 Discharge Evaluation ................................................................................. 4-7

4.3 Nature of Discharge Analysis ................................................................................... 4-8

4.3.1 Nature of Discharge Report Contents........................................................ 4-9

4.3.2 Peer Review ............................................................................................. 4-10

4.4 MPCD Practicability, Operational Feasibility, and Cost Analysis ......................... 4-11

4.4.1 MPCD Practicability, Operational Feasibility, and Cost Report

 Contents................................................................................................. 4-11

4.5 References............................................................................................................... 4-12
iii

CHAPTER 5. PHASE I DISCHARGE DETERMINATIONS

5.1 Discharges Determined To Require MPCDs............................................................ 5-1

5.1.1 Aqueous Film-Forming Foam.................................................................. 5-3

5.1.2 Catapult Water Brake Tank and Post-Launch Retraction Exhaust .......... 5-4

5.1.3 Chain Locker Effluent.............................................................................. 5-5

5.1.4 Clean Ballast ........................................................................................... 5-6

5.1.5 Compensated Fuel Ballast........................................................................ 5-7

5.1.6 Controllable Pitch Propeller Hydraulic Fluid .......................................... 5-8

5.1.7 Deck Runoff............................................................................................. 5-9

5.1.8 Dirty Ballast ........................................................................................... 5-10

5.1.9 Distillation and Reverse Osmosis Brine ................................................ 5-11

5.1.10 Elevator Pit Effluent .............................................................................. 5-12

5.1.11 Firemain Systems................................................................................... 5-13

5.1.12 Gas Turbine Water Wash ...................................................................... 5-14

5.1.13 Graywater .............................................................................................. 5-14

5.1.14 Hull Coating Leachate ........................................................................... 5-15

5.1.15 Motor Gasoline Compensating Discharge ............................................. 5-16

5.1.16 Non-Oily Machinery Wastewater .......................................................... 5-17

5.1.17 Photographic Laboratory Drains............................................................ 5-17

5.1.18 Seawater Cooling Overboard Discharge................................................ 5-18

5.1.19 Seawater Piping Biofouling Prevention................................................. 5-19

5.1.20 Small Boat Engine Wet Exhaust............................................................ 5-20

5.1.21 Sonar Dome Discharge .......................................................................... 5-20

5.1.22 Submarine Bilgewater............................................................................ 5-21

5.1.23 Surface Vessel Bilgewater/Oil-Water Separator Discharge................... 5-22

5.1.24 Underwater Ship Husbandry.................................................................. 5-22

5.1.25 Welldeck Discharges.............................................................................. 5-23

5.2 Discharges Determined To Not Require MPCDs................................................... 5-25

5.2.1 Boiler Blowdown ................................................................................... 5-25

5.2.2 Catapult Wet Accumulator Discharge ................................................... 5-27

5.2.3 Cathodic Protection................................................................................ 5-28

5.2.4 Freshwater Lay-Up................................................................................. 5-29

5.2.5 Mine Countermeasures Equipment Lubrication .................................... 5-30

5.2.6 Portable Damage Control Drain Pump Discharge ................................. 5-31

5.2.7 Portable Damage Control Drain Pump Wet Exhaust............................. 5-32

5.2.8 Refrigeration /Air Conditioning Condensate ......................................... 5-33

5.2.9 Rudder Bearing Lubrication................................................................... 5-33

5.2.10 Steam Condensate.................................................................................. 5-34

5.2.11 Stern Tube Seals and Underwater Bearing Lubrication......................... 5-35

5.2.12 Submarine Acoustic Countermeasures Launcher Discharge ................. 5-36

5.2.13 Submarine Emergency Diesel Engine Wet Exhaust .............................. 5-37

5.2.14 Submarine Outboard Equipment Grease and External Hydraulics........ 5-38

5.3 References............................................................................................................... 5-39

GLOSSARY AND ABBREVIATIONS ....................................................................GL-1
iv

LIST OF TABLES

Table ES-1 Discharges Determined To Require MPCDs............................................ES-2

Table ES-2 Discharges Determined To Not Require MPCDs.....................................ES-4

Table 2-1 Armed Forces Vessels Subject to UNDS Regulations................................ 2-1

Table 2-2 Navy Vessel Classification.......................................................................... 2-4

Table 2-3 Military Sealift Command Vessel Classification ........................................ 2-7

Table 2-4 Coast Guard Vessel Classification .............................................................. 2-8

Table 2-5 Army Vessel Classification ....................................................................... 2-11

Table 2-6 Marine Corps Vessel Classification .......................................................... 2-12

Table 2-7 Air Force Vessel Classification ................................................................. 2-13

Table 3-1 Incidental Discharges from Vessels of the Armed Forces........................... 3-3

Table 3-2 States Involved in Initial Consultation Meetings......................................... 3-4

Table 3-3 States Involved in the Second Round of Consultation Meetings ................ 3-5

Table 3-4 Discharges Sampled During Phase I of UNDS ........................................... 3-6

Table 3-5 Type of Analysis According to Discharge................................................... 3-7

Table 3-6 Discharges Sampled by Ship ....................................................................... 3-9

Table 3-7 Analytes and Analytical Methods.............................................................. 3-10

Table 3-8 Classical Analytes and Methods................................................................ 3-10

Table 4-1 Aquatic Life Water Quality Criteria ............................................................ 4-3

Table 4-2 List of Bioaccumulative Chemicals of Concern.......................................... 4-7

Table 5-1 Discharges Requiring the Use of a MPCD and the Basis for the

 Determination ............................................................................................ 5-2

LIST OF FIGURES

Figure 2-1 Largest Navy Surface Ship and Submarine Homeports............................. 2-17

Figure 2-2 Coast Guard Ports with Three or More Vessels Equal to or Longer than

 65 Feet...................................................................................................... 2-18

APPENDICES

Appendix A Nature of Discharge (NOD) and Marine Pollution Control Device

 (MPCD) Reports..................................................................................... A-1

Appendix B Matrix of Navy Vessels and Discharges....................................................B-1

Appendix C Matrix of MSC Vessels and Discharges....................................................C-1

Appendix D Matrix of Coast Guard Vessels and Discharges........................................D-1

Appendix E Matrix of Army Vessels and Discharges...................................................E-1

Appendix F Matrix of Marine Corps Vessels and Discharges.......................................F-1

Appendix G Matrix of Air Force Vessels and Discharges..............................................G-1
ES-1

EXECUTIVE SUMMARY

This Technical Development Document provides the technical background for the Phase I

regulation that is issued under authority of the Uniform National Discharge Standards (UNDS)

provisions of the Clean Water Act (CWA). The purpose of Phase I of UNDS is to determine

those discharges that are incidental to the normal operation of Armed Forces vessels for which it

is reasonable and practicable to require the use of a marine pollution control device (MPCD) on

at least one vessel class, type, age, or size. An extensive data collection effort was conducted to

identify vessels of the Armed Forces producing discharges incidental to normal operations and to

characterize those discharges. Initial requests for information were made to each branch of the

Armed Forces to obtain discharge information and to help compile a list of vessels that could be

subject to UNDS requirements. EPA and DoD identified a list of 39 types of discharges

incidental to the normal operations of vessels of the Armed Forces and evaluated them during

Phase I of UNDS. Consultations with personnel having equipment expertise were held on each

discharge to identify available data and data gaps. Sampling data were collected from various

vessels, where needed, to supplement existing data. Concurrently, existing laws and regulations

were reviewed, including applicable international, Federal, State, and local standards. In

addition, consultation meetings were held with interested Federal agencies, States, and

environmental organizations.

The information collected from surveys, consultations, and discharge sampling and

analysis was used collectively to evaluate the 39 types of discharges. Phase I decisions were

made on these discharges according to the seven factors required to be considered by §

312(n)(2)(B) of the CWA:

• the nature of the discharge;

• the environmental effects of the discharge;

• the practicability of using a MPCD;

• the effect that installing or using the MPCD has on the operation or the operational

capability of the vessel;

• applicable United States law;

• applicable international standards; and

• the economic costs of installing and using the MPCD.

The Administrator of the Environmental Protection Agency (“Administrator”) and the

Secretary of Defense (“Secretary”) have determined that it is reasonable and practicable to

require MPCDs on at least one vessel class, type, age, or size for 25 of the 39 discharges to

mitigate adverse impacts or the potential for adverse impacts on the marine environment. These

discharges are listed in Table ES-1 along with a brief description of each. For these 25

discharges, assessments of the practicability, operational impact, cost, and environmental

effectiveness of potentially available MPCDs were conducted. The Administrator and the

Secretary also have determined that it is not reasonable and practicable to require MPCDs for the

remaining 14 discharges because these discharges exhibit a low potential to cause adverse
ES-2

impacts to the marine environment. These discharges are listed and briefly described in Table

ES-2.

Table ES-1. Discharges Determined To Require MPCDs

Discharge Description

Aqueous Film-Forming Foam The primary fire-fighting agent used for flammable liquid fires on vessels of the Armed

Forces. It is a concentrated liquid that is mixed with seawater to form a 3% to 6%

solution which is discharged during planned maintenance, testing, system inspections,

and flight deck certifications.

Catapult Water Brake Tank and

Post-Launch Retraction Exhaust

Discharge from the water brake and from retracting catapults on aircraft carriers during

aircraft launching operations and testing. Lubricating oil that is applied to the catapult

cylinder collects in the water brake tank during these operations and is eventually

discharged overboard. Also, expended steam and residual oil are released overboard

when the catapult is retracted between launchings and testings.

Chain Locker Effluent Seawater and debris that collects in the anchor chain storage locker as a result of

anchor chain washdowns, retrievals, and heavy weather. The liquid collects in a sump

and is removed by a drainage eductor powered by the shipboard firemain.

Clean Ballast Either seawater or freshwater that is transferred into and out of dedicated tanks to

adjust a surface ship’s draft and to improve stability under various operating

conditions. On submarines, seawater taken aboard into the main ballast system to

control buoyancy and into the variable ballast system to control trim, list, and to adjust

buoyancy. The discharge is generated when the ballast is no longer required and the

tanks are partially or completely emptied.

Compensated Fuel Ballast Seawater that is introduced into fuel tanks to maintain the stability of a vessel by

compensating for the weight of the expended fuel that is consumed. During refueling,

this seawater is displaced overboard.

Controllable Pitch Propeller

Hydraulic Fluid

Hydraulic oil that is released from controllable pitch propeller (CPP) systems under

three conditions: leakage through CPP seals, releases during underwater CPP repair

and maintenance, or releases from equipment used for CPP blade replacement.

Deck Runoff Water runoff from precipitation, freshwater washdowns, and seawater that falls on the

exposed decks of a vessel such as a weather deck or flight deck. This water washes off

residues from the deck and topside equipment, can be contaminated with materials

from other deck activities, and is discharged overboard to receiving waters.

Dirty Ballast Seawater that is occasionally pumped into empty fuel tanks for the specific purpose of

improving ship stability. Before taking on seawater, fuel in the tank to be ballasted is

transferred to another fuel tank or holding tank. Dirty ballast is comprised of residual

fuel mixed with seawater. The discharge is generated when the ballast is no longer

required and the tanks are partially or completely emptied.

Distillation and Reverse Osmosis

Brine

Seawater concentrate or “brine” that is left over by water purification systems that

generate freshwater from seawater for a variety of shipboard applications including

potable water for drinking. This “brine” is discharged overboard.

Elevator Pit Effluent Liquid from deck runoff and elevator equipment maintenance activities that collects in

the bottom of elevator shafts. The liquid waste is either directed overboard, collected

for shore-side disposal, or processed along with bilgewater.

Firemain Systems Seawater distributed for fire fighting and other services aboard ships. Discharges of

firemain water from normal operations occur during firemain testing, maintenance and

training activities, anchor chain washdown, and cooling of auxiliary machinery.

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

turbine components.
ES-3

Table ES-1. Discharges Determined To Require MPCDs (contd.)

Discharge Description

Graywater Wastewater from showers, galleys, laundries, deck drains, lavatories, interior deck

drains, water fountains, miscellaneous shop sinks, and similar sources.

Hull Coating Leachate Antifouling agents that leach into surrounding waters from hull coatings designed to

prevent corrosion and to inhibit biological growth on the hull surface.

Motor Gasoline Compensating

Discharge

Seawater used to compensate for expended motor gasoline (MOGAS) used to operate

equipment stored on some Navy vessels. MOGAS is stored in a compensating tank

system to which seawater is added to fuel tanks as fuel is consumed. The discharge

occurs as a result of refueling when the displaced water is discharged overboard.

Non-Oily Machinery Wastewater Generated from the operation of distilling plants, water chillers, low- and high-pressure

air compressors, and propulsion engine jacket coolers. The discharge is captured in a

dedicated system of drip pans, funnels, and deck drains to segregate the water from

bilgewater, and is either drained directly overboard or into dedicated collection tanks

before being discharged overboard.

Photographic Laboratory Drains Shipboard photographic lab wastes from processing color and black-and-white film.

Typical wastes include spent film processing chemical developers, fixer-bath solutions,

and film rinse water.

Seawater Cooling Overboard

Discharge

Seawater used to cool heat exchangers, propulsion plants, and mechanical auxiliary

systems.

Seawater Piping Biofouling

Prevention

Anti-fouling compounds such as sodium hypochlorite introduced in seawater cooling

systems to inhibit the growth of fouling organisms on interior piping and component

surfaces.

Small Boat Engine Wet Exhaust Seawater injected into the exhaust of small boat engines for cooling and to quiet

operation. Exhaust gas constituents are entrained in the injected seawater and

discharged overboard as wet exhaust.

Sonar Dome Discharge Some domes that house detection, navigation, and ranging equipment are filled with

freshwater and/or seawater to maintain their shape and pressure. The discharge occurs

when water from inside the dome is pumped overboard before performing maintenance

or repair on the dome and when materials leach from the dome exterior.

Submarine Bilgewater Sources of bilgewater include seawater accumulation, normal leakage from machinery,

and fresh water washdowns that collect in the bilge. On some submarines, oily

wastewater is separated from non-oily wastewater. The oily wastewater is held for

shore-side disposal and the non-oily wastewater is discharged overboard.

Surface Vessel Bilgewater/OilWater Separator DischargeSources include condensate from steam systems, boiler blowdowns, water fountains,

and machinery space sinks that drain to the bilge. Bilgewater is either held for shoreside disposal or treated in an oil-water separator before being discharged overboard.

Underwater Ship Husbandry Discharge from the grooming, maintenance, and repair of hulls and hull appendages

performed while a vessel is waterborne. Underwater ship husbandry includes hull

cleaning, fiberglass repair, welding, sonar dome repair, non-destructive testing, masker

belt repairs, and painting operations.

Welldeck Discharges Water and residuals from precipitation, equipment and vehicle washdowns, washing

gas turbine engines, graywater from stored landing craft, and general washdowns of

welldecks and vehicle storage areas.
ES-4

Table ES-2. Discharges Determined To Not Require MPCDs

Discharge Description

Boiler Blowdown Water removed from the boiler system to prevent particulates, sludge, and treatment

chemical concentrations from accumulating.

Catapult Wet Accumulator

Discharge

Steam and water discharged from the wet accumulator tank to keep the water level in

the accumulator within operating limits. The catapult wet accumulator provides steam

to operate the catapult during aircraft launching.

Cathodic Protection Zinc, aluminum, and chlorine-produced oxidants released during the consumption of

sacrificial anodes and the operation of impressed current cathodic protection systems.

The purpose of cathodic protection is to prevent hull corrosion.

Freshwater Lay-Up Freshwater used to fill condensers when submarine seawater cooling systems are

placed in stand-by mode, or “lay-up.” While the condenser is in lay-up mode, the

water is discharged and refilled approximately every 30 days.

Mine Countermeasures Equipment

Lubrication

Lubricating grease and oil released from mine countermeasures equipment that is

towed behind vessels to locate and destroy mines.

Portable Damage Control Drain

Pump Discharge

Seawater and harbor water that is discharged by the portable damage control drain

pumps during pump maintenance, testing, and training.

Portable Damage Control Drain

Pump Wet Exhaust

Water used to quiet and cool the exhaust from gasoline- and kerosene-fueled portable

damage control drain pumps. Portable damage control drain pump wet exhaust

discharge occurs during training and monthly planned maintenance activities.

Refrigeration /Air Conditioning

Condensate

Condensate from air conditioning, refrigerated spaces, and stand-alone refrigeration

units. The condensate is collected in drains and is either discharged directly overboard

or held in dedicated tanks before discharge.

Rudder Bearing Lubrication Grease and oil used to lubricate rudder bearings. The grease and oil can be released

while the vessel is moving, when the rudder is used, or when pierside because the oil

lubricant is slightly pressurized.

Steam Condensate Condensate from steam used to operate auxiliary systems, such as laundry facilities,

heating systems, and other shipboard systems, that drains into collection tanks and is

discharged overboard.

Stern Tube Seals and Underwater

Bearing Lubrication

Lubricants used in propeller support struts and bearings that can be released to the

environment.

Submarine Acoustic

Countermeasures Launcher

Discharge

Water contained in the acoustic countermeasures Mk 2 launch tube after the

countermeasures device is expelled.

Submarine Emergency Diesel

Engine Wet Exhaust

Water used to quiet and cool the exhaust of submarine emergency diesel engines.

These emergency diesel engines are operated for equipment checks that occur before

submarine deployment, during monthly testing, and during periodic trend analyses.

Submarine Outboard Equipment

Grease and External Hydraulics

Grease applied to a submarine’s outboard equipment. The grease is released to the

environment by erosion from mechanical action of seawater while the submarine is

underway and by slow dissolution of the grease into the seawater.
1-1

1. BACKGROUND OF THE UNIFORM NATIONAL DISCHARGE STANDARDS

This chapter provides background on and summarizes the requirements of the Uniform

National Discharge Standards (UNDS) legislation. Section 1.1 describes the evolution of the

UNDS legislation; section 1.2 cites the legal authority for the UNDS regulations and gives an

overview of the scope of UNDS, including key definitions; section 1.3 describes the multi-phase

UNDS development process; and section 1.4 lists the references cited in chapter 1.

1.1 Background

Armed Forces vessels produce liquid discharges that vary greatly in composition, amount,

and potential for causing adverse environmental effects. Many are common to nearly all vessels

while others are unique to specific vessel types. The composition and volume of a specific

discharge may also vary with vessel type and age, installed hardware, operating mode, external

environmental conditions, and other factors. Many discharges are discrete waste streams such as

graywater (which includes effluent from sources such as sinks, showers, and galleys) and

seawater cooling overboard discharge, while others, such as leachate from hull protective

coatings, lubricants from various external bearings and joints, and contaminants from other

external surfaces are released by direct contact with the marine environment or runoff from

precipitation.

In support of national defense and other missions assigned by the President, Armed

Forces vessels are required to operate in and visit coastal waters and ports throughout the United

States. The potential for different ship discharge requirements between local and State

jurisdictions makes it difficult for Armed Forces vessels to simultaneously ensure environmental

regulatory compliance and operational readiness. Clear, achievable, and uniform discharge

standards would enable the Armed Forces to design, build, and train their crews to operate

environmentally sound vessels and simultaneously maintain their ability to meet national defense

and other mission requirements. In addition, uniform national standards would result in

enhanced environmental protection because standards would be established for certain discharges

that presently are not comprehensively regulated. Establishing national standards for discharges

from the vessels of the Armed Forces is the purpose of the UNDS program.

In 1990, the Navy began preliminary discussions with various Federal agencies concerning the

need for uniform national standards to maintain operational flexibility while promoting

environmentally responsible ships. The U.S. Environmental Protection Agency (EPA), the Coast

Guard, the National Oceanic and Atmospheric Administration, and other agencies were

contacted. The Navy also actively solicited input from the States, recognizing that coastal States,

in particular, have a great interest in the quality of the water in and around their ports. State

briefings and discussions held before UNDS legislation was passed began in October 1993 and

continued through the winter of 1995.1 During the same period, the Navy hosted several

information sessions on UNDS with Federal and State environmental officials, environmental

interest groups, and congressional staff. As a result, legislation was drafted and sent to Congress.
1-2

Ultimately, Congress enacted UNDS legislation as part of the 1996 Defense Authorization Bill

and the President signed the bill into law as part of the National Defense Authorization Act of

1996.

The National Defense Authorization Act established that the purposes of UNDS are to:

• enhance the operational flexibility of vessels of the Armed Forces domestically and

internationally;

• stimulate the development of innovative vessel pollution control technology; and

• advance the development by the United States Navy of environmentally sound ships.

1.2 Legal Authority and Statutory Requirements for the UNDS Regulations

Section 325 of the National Defense Authorization Act of 1996, entitled “Discharges

from Vessels of the Armed Forces” (Pub. L. 104-106, 110 Stat. 254), amended § 312 and

§ 502(6) of the Federal Water Pollution Control Act (also known as the Clean Water Act or the

CWA) to require the Administrator of the EPA (“Administrator”) and the Secretary of Defense

(“Secretary”) to develop uniform national standards to control certain discharges from vessels of

the Armed Forces.

1.2.1 Discharges

The UNDS legislation specifies that standards would apply to discharges (other than

sewage) incidental to the normal operation of vessels of the Armed Forces unless the Secretary

finds that complying with UNDS would not be in the national security interests of the United

States (CWA § 312(n)(1)). The standards would apply anytime the vessel is waterborne in inland

U.S. waters or within 12 nautical miles (n.m.) from the United States or its territories, regardless

of whether the vessel is underway or pierside (see section 1.2.3). Discharges subject to UNDS

include discharges from the operation, maintenance, repair, or testing of vessel propulsion

systems, maneuvering systems, habitability systems, or installed major systems such as elevators

or catapults, and discharges from protective, preservative, or adsorptive hull coatings. UNDS

does not apply to discharges overboard of rubbish, trash, garbage, or other such materials; air

emissions resulting from a vessel propulsion system, motor driven equipment or incinerator; or

discharges that require permitting under the National Pollutant Discharge Elimination System

(NPDES) program, Title 40 Part 122 of the Code of Federal Regulations (CFR) (see CWA §

312(a)(12)). UNDS does not apply to discharges containing source, special nuclear, or byproduct

materials. These materials are regulated under the Atomic Energy Act of 1954, as amended (42

United States Code (USC) 2011). See Train v. CIPR, Inc., 426 U.S. 1 (1976).

1.2.2 Vessels

Armed Forces vessels subject to the UNDS regulations include most watercraft or other

artificial contrivances used, or capable of being used, as a means of water transportation by the

Armed Forces. Examples of such vessels are ships, submarines, barges, tugs, floating drydocks,
1-3

and landing craft, as well as boats of all sizes. Armed Forces vessels are any vessel owned or

operated by the Department of Defense other than time- or voyage-chartered vessels. This

includes vessels of the Navy, Army, Marine Corps, Air Force, and Military Sealift Command

(MSC). In addition, a vessel of the Armed Forces is defined as any vessel owned or operated by

the Department of Transportation (DOT) that is designated by the Secretary of the Department in

which the Coast Guard is operating as a vessel equivalent to a vessel of the DoD. The Secretary

of the DOT has determined that Coast Guard vessels are equivalent to DoD vessels and are

therefore included as vessels of the Armed Forces for the purposes of UNDS.

A vessel becomes a vessel of the Armed Forces when the government assumes overall

operational control of the vessel. Vessel discharges that occur before the government assumes

control of the vessel (e.g., vessels under construction) and those that occur during maintenance

and repair while the vessel is in drydock are addressed by the NPDES permits issued to the shore

facility or the drydock. Discharges related to a floating drydock’s function as a vessel are

covered by UNDS and do not require authorization by NPDES permits.

While the majority of Armed Forces vessels are subject to UNDS, there are several

classes of vessels that are not subject to UNDS. The Armed Forces vessels that are subject to

UNDS and those vessels not subject to UNDS are discussed in detail in chapter 2.

1.2.3 Waters

UNDS is applicable to discharges from Armed Forces vessels when they operate in the

navigable waters of the United States and the contiguous zone. As defined in § 502 of the CWA,

the term “navigable waters” means all inland waters of the United States, including the Great

Lakes, and all waters seaward from the coastline to a distance of three n.m. from the shore of the

States, District of Columbia, Commonwealth of Puerto Rico, the Virgin Islands, Guam,

American Samoa, the Canal Zone, and the Trust Territories of the Pacific Islands. The

contiguous zone extends from three n.m. to 12 n.m. from the coastline. Therefore, UNDS

applies to Armed Forces vessel discharges into inland waters and into waters from the shoreline

out to 12 n.m. of shore. UNDS is not enforceable beyond the contiguous zone.

1.3 UNDS Development Requirements

Section 312(n) of the CWA requires that UNDS be developed in three phases:

Phase I. The first phase of UNDS requires the Administrator and the Secretary to

determine for which Armed Forces vessel discharges it is reasonable and practicable to require

control with a marine pollution control device (MPCD) on at least one vessel class, type, age, or

size to mitigate potential adverse impacts on the marine environment (CWA § 312(n)(2)). The

UNDS legislation states that a MPCD may be a piece of equipment or a management practice

designed to control a particular discharge (CWA § 312(a)(13)). The Administrator and the

Secretary are required to consider the following seven factors when determining if a discharge

requires a MPCD:
1-4

• the nature of the discharge;

• the environmental effects of the discharge;

• the practicability of using the MPCD;

• the effect that installing or using the MPCD has on the operation or the operational

capability of the vessel;

• applicable United States laws;

• applicable international standards; and

• the economic costs of installing and using the MPCD.

The Administrator and the Secretary are required to consult with the Secretary of the

department in which the Coast Guard is operating (i.e., DOT), the Secretary of Commerce, and

interested States during Phase I rule development. The statute provides that after promulgation

of the Phase I rule, neither States nor political subdivisions of States may adopt or enforce any

State or local statutes or regulations with respect to discharges identified as not requiring control

with a MPCD, except to establish no-discharge zones (CWA § 312(n)(6)). A no-discharge zone

is an area of water determined by a State or the Administrator to need greater environmental

protection than that provided by UNDS. It can encompass one or more discharges that will be

prohibited from being released, either treated or untreated, into the waters of the no-discharge

zone. In addition, States and their political subdivisions will be similarly prohibited from

adopting or enforcing any statutes or regulations affecting discharges that require control with

MPCDs once “Phase III” regulations (see below) that govern the design, construction,

installation, and use of the MPCDs for those discharges are promulgated.

When there is new, significant information not considered during the Phase I rulemaking

that could result in a change to the Phase I discharge determination, § 312(n)(5)(D) of the CWA

authorizes the Governor of any State to submit a petition to the Administrator and the Secretary

requesting them to re-evaluate whether a discharge requires control. In addition, § 312(n)(5) of

the CWA requires the Administrator and the Secretary to review the Phase I determinations every

five years and, if necessary, revise the determinations based on significant new information.

Phase II. The second phase of UNDS requires the Secretary and the Administrator to

promulgate Federal performance standards for each MPCD determined to be required in Phase I

(CWA § 312(n)(3)). Phase II requires that the Secretary of the department in which the Coast

Guard is operating, the Secretary of State, the Secretary of Commerce, other interested Federal

agencies, and interested States be consulted. When developing performance standards for the

MPCDs during Phase II, the Secretary and Administrator must consider the same seven factors

that were considered during Phase I (see above), and may establish standards that:

• distinguish between vessel class, type and size;

• distinguish between new and existing vessels; and

• provide a waiver from UNDS requirements as necessary or appropriate for particular

classes, types, sizes, or ages of vessels.
1-5

The performance standards developed during Phase II are to be issued two years after the

Phase I regulation is issued, and reviewed every five years in accordance with § 312(n)(5) of the

CWA.

Phase III. The third phase of UNDS requires the Secretary, after consulting with the

Administrator and the Secretary of the department in which the Coast Guard is operating, to

establish requirements for designing, constructing, installing, and using the MPCDs identified in

Phase II (CWA § 312(n)(4)). These requirements will be codified under the authority of the

Secretary. Phase III is to be completed within one year after Phase II is promulgated. Following

completion of Phase III, neither States nor political subdivisions of States may adopt or enforce

any State or local statutes or regulations with respect to discharges identified as requiring control

with a MPCD, except to establish no-discharge zones (CWA §312(n)(6)).

1.4 References

1. Quinn, John P., Captain U.S. Navy. “Uniform National Discharge Standards for Armed

Forces Vessels: Enhancing Operational Flexibility and Environmental Protection.” Presented

at the 22nd Environmental Symposium and Exhibition of the American Defense Preparedness

Association. Orlando, Florida. 21 March 1996.

2-1

2. VESSELS OF THE ARMED FORCES

This chapter describes Armed Forces vessels, to which UNDS is applicable, and clarifies

which vessels do not qualify as such. Section 2.1 gives a brief overview of the vessels subject to

UNDS; section 2.2 provides a more detailed description of the different vessel types and lists the

vessel classes covered by UNDS in each branch of the Armed Forces and those not covered by

UNDS; section 2.3 discusses where these vessels operate; and references are listed in section 2.4.

2.1 Introduction

The UNDS legislation defines vessels of the Armed Forces as any vessel owned or

operated by the DoD, other than a time or voyage chartered vessel, or any vessel owned or

operated by the Department of Transportation (DOT) that is designated by the Secretary of the

department in which the Coast Guard is operating as being equivalent to a vessel of the Armed

Forces (CWA § 312(a)(14)). The branches of the Armed Forces that own or operate vessels that

are subject to UNDS are listed in Table 2-1 along with the number of vessels as of August 1997.

Table 2-1. Armed Forces Vessels Subject to UNDS Regulations

Branch of Armed Forces Branch

Abbreviation

Number of

Vessels

United States Navy USN 4,760

United States Coast Guard USCG 1,445

United States Marine Corps USMC 538

United States Army USA 334

Military Sealift Command MSC 57

United States Air Force USAF 36

TOTAL = 7,170

Categories of vessels that are not covered by UNDS include: commercial vessels;

privately owned vessels; vessels owned or operated by State, local, or tribal governments; vessels

under the jurisdiction of the Army Corps of Engineers; vessels, other than those of the Coast

Guard, under the jurisdiction of the Department of Transportation; vessels owned or operated by

other Federal agencies that are not part of the Armed Forces (i.e., Maritime Administration

(MARAD) vessels); vessels preserved as memorials and museums; time- and voyage-chartered

vessels; vessels under construction; vessels in drydock; and amphibious vehicles. Several

categories of these vessels are described in section 2.2.7.

The five largest Navy ports are Norfolk, VA; San Diego, CA; Pearl Harbor, HI; Puget

Sound (Bremerton), WA; and Mayport, FL. Numerous other naval ports are located around the

country. The largest Coast Guard base is located in Portsmouth, VA; with other major bases in

California, Florida, Hawaii, Massachusetts, South Carolina, Texas, and Washington. Fort Eustis,
2-2

VA, is the primary site for the Army vessels, but the Army also ports vessels in California,

Florida, Hawaii, Maryland, North Carolina, and Washington. Military Sealift Command vessels

make use of Navy ports, as available, and commercial ports at all other times. Neither the

Marine Corps nor the Air Force has a major port. Marine Corps craft are typically stowed aboard

larger Navy vessels and maintained and stationed ashore. Air Force vessels are located in

Florida, North Carolina, Virginia, New Mexico, and Nevada. Operating locations for Armed

Forces vessels are discussed in more detail in Section 2.3.

2.2 Description of Vessel Classes and Types

The number of specific vessel types within each branch of the Armed Forces constantly

changes due to vessel commissionings, decommissionings, and transfers within branches of the

Armed Forces. In order to maintain consistency, the Armed Forces vessel population as of

August 1997 was used in analyses supporting this rule.

2.2.1 Vessels of the U.S. Navy1-4

2.2.1.1 Navy Mission

The role of the U.S. Navy is to maintain an effective naval fighting force to defend the

U.S. during war, and to use this force to prevent conflicts and control crises around the world.

The Navy is responsible for organizing, training, and equipping its forces to conduct prompt and

sustained combat operations at sea. For combat, as well as humanitarian missions, the Fleet must

be capable of quick deployment, while being optimized for carrying personnel, weapons, and

supplies whenever and wherever needed.

2.2.1.2 Navy Vessel Description

There are approximately 4,800 Navy vessels (active and inactive), the majority of which

are small boats and service craft. Navy vessels can be categorized into eight groups according to

mission: aircraft carriers, surface combatants, amphibious ships, submarines, auxiliaries, mine

warfare ships, small boats and service craft, and inactive assets. Differences in vessel size,

mission, and mode of operation are explained below. Table 2-2 summarizes Navy vessel

characteristics including length, displacement, and mission for each vessel classification. A

summary of vessel-related abbreviations may be found in the Glossary and Abbreviations

section.

Aircraft Carriers. Aircraft carriers are the largest vessels in Navy service, averaging

approximately 1,100 feet long. They provide combat air support to the fleet. To accomplish this,

aircraft carriers have landing and launch platforms for fixed-wing aircraft and helicopters.

Carriers are classified as having either conventional propulsion (CV) or non-conventional

propulsion (CVN). The USS Nimitz (CVN 68) Class, is the largest class of carriers, composed

of ships that are intended to provide fleet support well into the next century. Aircraft carriers are

ocean-going vessels that typically operate within 12 n.m. only during transit in and out of port.

However, testing and maintenance activities may be conducted in port and during transits.
2-3

Surface Combatants. Surface combatants provide air defense, ballistic missile defense,

antisubmarine warfare support, antisurface warfare support, merchant and carrier group

protection, independent patrol operations, and tactical support of land-based forces. They

include cruisers (CG and CGN), destroyers (DD and DDG), frigates (FFG), and coastal patrol

craft (PC). The Navy’s surface combatants range from 171 feet long (for PCs) to 596 feet long

(for CGNs), and may have either conventional or non-conventional propulsion. Surface

combatants are ocean-going vessels that, for the most part, operate inside 12 n.m. only during

transit in and out of port and for short periods of time to meet mission requirements, such as

training. Testing and other systems maintenance activities may be done in port and during

transits.

Amphibious Ships. Amphibious ships provide a platform for vertical landing and takeoff of aircraft, primarily helicopters, and conduct launch and recovery operations of smaller

landing craft. They include command ships (LCC and AGF), assault ships (LHD, LHA, and

LPH), transport docks (LPD), and dock landing ships (LSD). Amphibious ships range from 522

to 844 feet long and use landing craft and helicopters to move Marine Corps equipment and

vehicles ashore. Amphibious ships are ocean-going vessels that operate inside 12 n.m. not only

during transit in and out of port, but also to train for and perform their designed mission as an

interface between water- and land-based operations. Testing and maintenance activities may be

performed in port and during transits.

Submarines. Submarines provide strategic missile, battlefield support, stealth strike,

special forces, littoral warfare, and other miscellaneous capabilities. They are categorized as

attack (SSN), ballistic missile (SSBN), and research and survey (AGSS) types. Navy submarines

range from 165 feet long for the research submarine to 560 feet long for ballistic missile

submarines. Nearly all submarines in active service have non-conventional propulsion, with the

exception of search and rescue types. Submarines are ocean-going vessels that operate inside 12

n.m. for transit in and out of port and to meet mission requirements, such as training. Testing

and maintenance activities may be performed in port and during transits.

Auxiliaries. Auxiliary ships provide logistical support, such as underway replenishment

of ordnance, fuel, and consumable products (AO and AOE); and rescue and salvage operations

(ARS). Submarine tenders (AS) provide maintenance facilities, weapon stores, hospital

facilities, and additional berthing space for submarines. Auxiliary vessels range in length from

255 feet to 795 feet. Auxiliaries are ocean-going vessels that typically operate inside 12 n.m. for

transit in and out of port or to meet mission requirements. Testing and maintenance activities

may be performed in port and during transits.

Mine Warfare Ships. Mine warfare ships (mine countermeasures ships (MCM) and

minehunter, coastal (MHC)) conduct minesweeping missions to find, classify, and destroy

moored and bottom mines. These vessels range in length from 188 to 224 feet long. Mine

warfare vessels primarily operate in coastal waters.
2-4

Small Boats and Service Craft. Due to their large numbers and diverse duties, small

boats and service craft have been summarized collectively in Table 2-2. The Navy owns and

operates approximately 4,200 small boats and service craft. Small boats are used as harbor patrol

boats, transport boats, work boats (WB), and utility boats (UB). Many of the service craft are

non-self-propelled “lighters,” or barges (YC, YFN, YON, and YRBM), used for berthing, office,

messing, or repair functions or to carry fuel or equipment. Other small boats and service craft

include: tugboats of various sizes (YTB, YTM, and YTL), training patrol craft (YP), landing

craft (LCU, LCM, CM, and PL), torpedo retrievers (TWR, TRB, and TR), floating drydocks

(AFDB, AFDL, AFDM, ARD, and ARDM), and rigid inflatable boats (designated RB or RIB).

Small boats are often kept out of the water when not in use to increase the vessels’ longevity or

for storage while transiting to operational areas. Small boats and service craft operate within the

waters of the homeport area and other coastal locations within 12 n.m. from shore.

Inactive Assets. The Navy owns and maintains additional surface ships in various states

of readiness. These inactive assets are comprised of numerous vessel types with varying

missions and capabilities. The Navy also owns and maintains inactive submarines. The

significant majority of these inactive assets are scheduled for scrapping or other permanent

disposal. Some surface ships might be transferred to MARAD to be made part of the National

Defense Reserve Fleet, or might be destined for sale to foreign nations. However, due to the

Navy’s retained ownership of these assets, pending final disposal, these vessels are covered

under UNDS. These inactive vessels are prepared for long-term storage with their systems and

equipment secured or removed and are not operated. They are moored in designated port

locations and typically not moved until final disposal.

Table 2-2. Navy Vessel Classification

Vessel Type Ship Class Number

Active

Class

Length

(ft)

Displacement

fully loaded

(tons)

Mission

Aircraft CV 59 1 1,056 82,360 Provide air combat support to

Carriers CV 63 3 1,046 81,985 the fleet with landing and

CVN 65 1 1,102 93,970 launch platform for airplanes

CVN 68 7 1,092 95,413 and helicopters

Surface CG 47 27 567 9,589 Provide air defense, missile

Combatants CGN 36 2 596 10,530 defense, antisubmarine and

CGN 38 1 585 11,400 antisurface warfare support,

DD 963 31 563 8,280 merchant and carrier group

DDG 993 4 563 9,574 protection, independent patrol

DDG 51 18 504 8,373 operations, and tactical

FFG 7 43 445 3,658 support of land-based forces

PC 1 13 171 329

Amphibious LCC 19 2 636 16,790 Provide a landing and take-off

Ships AGF 3 1 522 13,900 platform for aircraft, primarily

AGF 11 1 569 16,912 helicopters, and a means for

LHD 1 4 844 40,530 launching and recovering

LHA 1 5 834 39,967 smaller landing craft
2-5

Table 2-2. Navy Vessel Classification (contd.)

Vessel Type Ship Class Number

Active

Class

Length

(ft)

Displacement

fully loaded

(tons)

Mission

Amphibious LPD 4 3 569 17,595

Ships (contd.) LPD 7 3 569 17,595

LPD 14 2 569 17,595

LPH 2 2 602 18,300

LSD 36 5 553 13,680

LSD 41 8 609 16,165

LSD 49 3 609 16,695

Submarines SSN 671 1 315 5,284 Provide strategic missile

SSN 637 13 302 4,250 defense, search

SSN 688 56 360 6,300 and rescue, and research and

AGSS 555 1 165 860 survey capability

SSBN 726 17 560 16,754

Auxiliaries AOE 1 4 795 53,600 Provide logistical support,

AOE 6 3 755 48,800 such as underway

AO 177 5 708 37,866 replenishment, material

AS 33 1 644 19,934 support, and rescue and

AS 39 3 646 22,650 salvage operations

ARS 50 4 255 3,193

Mine Warfare MCM 1 14 224 1,312 Conduct minesweeping

Ships MHC 51 12 188 918 missions to find and destroy

mines

Small Boats YTB 760 68 109 356 Provide a variety of services.

and Service YTB 756 3 109 409 Includes: patrol training craft

Craft YTB 752 1 101 375 (YP), tug boats (YTB),

YTT 9 3 187 1,200 torpedo trials craft (YTT),

YP 654 1 -- -- landing craft, barges, transport

YP 676 27 -- -- boats, personnel boats, harbor

Various

others 4,089 12-192 --

patrol boats, work boats, utility

boats, floating drydocks, and rigid

inflatable boats

Inactive Assets Various

surface

ships

228 -- --

Vessels in various states of

readiness, the majority of which

are scheduled for

Various

submarines16 -- --

scrapping, transfer to MARAD,

or sale to foreign nations.

TOTAL Vessels = 4,760

2.2.2 Vessels of the Military Sealift Command1,5,6

2.2.2.1 Military Sealift Command Mission

The Military Sealift Command (MSC) transports DoD materials and supplies, provides

towing and salvage services, and conducts specialized missions for Federal agencies. To
2-6

accomplish this mission, the MSC maintains and operates a fleet of vessels classified within four

major maritime programs: the Special Mission Support Force (SMSF), the Naval Fleet Auxiliary

Force (NFAF), Strategic Sealift, and the Afloat Prepositioning Force (APF, which is sometimes

categorized under Strategic Sealift). Consistent with the definition of vessel of the Armed Forces

in CWA § 312(a)(14), UNDS does not apply to chartered Strategic Sealift and APF vessels.

Table 2-3 summarizes MSC vessel characteristics including length, displacement, and

mission for each vessel classification. MSC owned vessels are differentiated from Navy vessels

by the prefix, “T-” (e.g., T-AGOS and T-AGS). Although MARAD’s Ready Reserve Force

(RRF) ships come under the direction of the MSC and its Strategic Sealift program when

activated, they are normally maintained and crewed by MARAD. RRF ships are discussed in

section 2.2.7.2 in conjunction with other MARAD vessels.

2.2.2.2 Special Mission Support Force

The MSC’s Special Mission Support Force (SMSF) includes ships designed to support

the Navy, Air Force, and the Army in specialized military missions. SMSF vessels often operate

in remote areas to conduct undersea surveillance, missile range tracking, oceanographic and

hydrographic surveys, acoustic research, and submarine escort. SMSF vessels range from 234

feet to 595 feet long. They include the following vessel types: ocean surveillance (AGOS),

surveying (AGS), miscellaneous (AG) navigation test support and acoustic research; missile

range instrumentation (AGM), and cable repairing (ARC) vessels. The vessels are operated by

civil service mariners or mariners under contract to the MSC. SMSF vessels are ocean-going

ships that operate inside 12 n.m. during transit in and out of port or to meet mission

requirements. Additionally, cable repairing vessels may operate frequently inside 12 n.m. for

mission purposes. Testing and maintenance activities may be conducted in port and during

transits.

2.2.2.3 Naval Fleet Auxiliary Force

The MSC’s Naval Fleet Auxiliary Force (NFAF) is comprised of auxiliary ships that

provide underway replenishment services to Navy surface combatants, in addition to ocean

towing and salvage services. By transporting and delivering fuel, food, spare parts and

equipment, and ammunition, NFAF ships enable surface combatants to remain at sea for

extended periods. NFAF vessels are between 240 feet and 677 feet in length. The NFAF vessels

are ocean-going, and typically operate inside 12 n.m. only to transit in and out of port or to meet

certain mission requirements. Testing and maintenance activities may be conducted in port and

during transits.
2-7

Table 2-3. Military Sealift Command Vessel Classification6

MSC

Maritime

Program

Classification

Class/Ship Number

Active

Class

Length

(ft)

Displacement

fully loaded

(tons)

Mission

SMSF T-AGOS 5 234 3,438 Support the Armed

T-AGOS 4 285 2,558 Forces in specialized

T-AGS 9 442 12,208 missions such as

T-AG 2 455 11,860 undersea surveillance,

T-AGM 1 595 21,478 missile range tracking,

T-ARC 1 502 14,225 oceanographic and

hydrographic surveys,

acoustic research, and

submarine escort

NFAF T-AE 8 563 19,937 Provide underway

T-AFS 8 523 16,792 replenishment services

T-AO 12 677 40,700 (i.e., deliver fuel, food,

T-ATF 7 240 2,260 spare parts, equipment, and

ammunition) to Navy

surface combatants, as well

as ocean towing and salvage

services

TOTAL Vessels = 57

2.2.3 Vessels of the U.S. Coast Guard1,7,8

2.2.3.1 Coast Guard Mission

The Coast Guard is part of DOT and is responsible for enforcing laws on the waters of the

U.S., including coastal waters, oceans, lakes, and rivers that are subject to the jurisdiction of the

U.S. During war, the Coast Guard may become part of the Navy. The principal peacetime

missions of the Coast Guard are enforcing recreational boating safety, conducting search and

rescue operations, maintaining aids to navigation (e.g., lighthouses and navigational lights),

ensuring merchant marine safety (e.g., via vessel inspection and operator certification), providing

drug interdiction, and participating in environmental protection efforts. The Coast Guard also

carries out port safety responsibilities (e.g., icebreaking), enforces laws and treaties (e.g.,

customs, immigration, and fisheries law enforcement), and, ultimately, defends U.S. harbors and

coasts during war. Table 2-4 summarizes Coast Guard vessel characteristics including length,

displacement, and mission for each vessel classification.

2.2.3.2 Coast Guard Vessel Description

Cutters. Coast Guard cutters are vessels 65 feet or longer that are capable of

accommodating crew living on board. Cutters are used for patrol, air defense, search and rescue,

and drug interdiction. High endurance cutters (WHEC), medium endurance cutters (WMEC),
2-8

Table 2-4. Coast Guard Vessel Classification

Vessel

Classification

Ship Class Number

Active

Class

Length

(ft)

Displacement

fully loaded

(tons)

Mission

Cutters Hamilton

WHEC 715

12 378 3,050 Provide multi-mission capability,

including patrol,

Bear

WMEC 901

13 270 1,820 air defense, search and rescue,

and drug interdiction

Reliance

WMEC 615

16 210 1,007

Storis

WMEC 38

1 230 1,925

Escape

WMEC 6

1 213 1,745

Island

WPB 1301

49 110 155

Point

WPB 82301

36 82 69

Tenders Juniper

WLB 201

2 225 2,000 Used to maintain inland, river,

coastal, and offshore

Balsam

WLB 62

23 180 1,038 buoys and navigational aids, or

to serve as a construction

Ida Lewis

WLM

2 175 916 platform

Red

WLM

5 157 525

White

WLM

4 133 600

Buckthorn

WLI

1 100 200

Cosmos

WLI 293

1 100 178

Berry

WLI

4 65 71

Pamlico

WLIC

4 160 416

Cosmos

WLIC

3 100 178

Anvil

WLIC

7 75 145

Sumac

WLR

1 115 478

Kankakee

WLR

3 75 172
2-9

Table 2-4. Coast Guard Vessel Classification (contd.)

Vessel

Classification

Ship Class Number

Active

Class

Length

(ft)

Displacement

fully loaded

(tons)

Mission

Tenders

(contd.)

Gasconade

WLR

10 75 141

Ouachita

WLR

6 65 143

Icebreakers Polar

WAGB 10

2 399 13,190 Support the winter icebreaking

efforts in order to

Mackinaw

WAGB 83

1 290 5,320 maintain open waterways in the

Arctic, Antarctic, and the

northern regions of the U.S.

including the Great Lakes,

Northwest, and Northeast

Tugboats Bay

WTGB

9 140 662 Provide towing and support

services (icebreaking, search

Capstan

WYTL

11 65 72 and rescue, and law

enforcement) to other vessels

Small Boats and

Craft

Various 1,217 22-58 2-32 Used in harbors (drug

interdiction, port security, cable

repair, harbors and inland

waters, navigation aids, illegal

dumping, search and rescue,

etc.), in rough surf for rescue, for

inland river and lake patrol, as

transports, and for firefighting

Other Vessels Eagle

WIX 327

1 295 1,784 A sailing cutter used for training

TOTAL Vessels = 1,445

and patrol boats (WPB) have multi-mission capabilities due to features such as anti-ship missiles,

gun systems, and other weapon systems. Because of these capabilities, the cutters are

strategically stationed along the Atlantic and Pacific coasts of the U.S. The Coast Guard no

longer maintains anti-submarine warfare capability. WHECs perform patrol, air defense, and

search-and rescue operations, and can remain at sea for 30-45 days without support. This

compares to 10-30 days at sea for WMECs and 1-7 days for WPBs. The cutters range in length

from 82 feet to 378 feet. Cutters are ocean-going vessels. However, they operate inside 12 n.m.

during transit in and out of port, and during certain patrol or search and rescue missions. Testing

and maintenance activities may be performed in port and during transits.

Tenders. Tenders are a specific type of cutter used to maintain inland, river, inshore,

coastal, and offshore buoys and navigational aids, or to serve as a construction platform in inland

waters. Coast Guard tenders range in size from 65 to 225 feet in length to accommodate

numerous and diverse tasks. Tenders are operated frequently inside 12 n.m.
2-10

Icebreakers. Icebreakers have multi-mission capabilities and are often equipped with

hangar decks, flight decks, gun systems, and arctic or oceanographic laboratories. They primarily

support winter icebreaking efforts in order to maintain open waterways in the Arctic and

Antarctic, and the northern regions of the U.S. including the Great Lakes, Northwest (e.g.,

Alaska and Washington), and Northeast (e.g., Maine and Massachusetts). The Coast Guard

icebreakers range in length from 290 to 399 feet. Icebreakers are frequently operated inside 12

n.m.

Tugboats. Tugboats operate in various capacities, providing towing and support services

to other vessels. Icebreaking tugs (WTGB) are 140 feet long and specially designed to break

through thick ice. By joining this tug with a work barge, it can also be used to maintain aids to

navigation. Small harbor tugs (WYTL) are 65 feet long and, in addition to towing, can perform

law enforcement and search and rescue operations. They have also been used for small-scale

icebreaking, firefighting, delivering humanitarian aid, and assisting in spill containment.

Tugboats usually operate within 12 n.m. of shore; however, specific missions may require them

to operate beyond 12 n.m.

Small Boats and Craft. Small boats and craft are used for various harbor duties, rough

surf rescues, inland river and lake patrols, transporting equipment, and firefighting. Some of

these vessels can be transported by trailer and used on any inland waterway in the U.S. Due to

their numbers and diversity, small boats and craft of the Coast Guard have been summarized

collectively in Table 2-4.

Other Vessels. Coast Guard Academy cadets use the Coast Guard’s training cutter

(WIX), a multi-masted sailing vessel, as a summer training vessel.

2.2.4 Vessels of the U.S. Army1,9,10

2.2.4.1 Army Mission

The role of the Army is to preserve the peace and security, and provide for the defense of

the U.S., territories, commonwealths, possessions, and any areas occupied by the U.S. The Army

has land and aviation combat forces, augmented, in part, by waterborne transport vessels. Army

vessels are used primarily for ship to shore transfer of equipment, cargo, and personnel.

2.2.4.2 Army Vessel Description

The Army’s fleet is divided into three sections: the Transportation Corps, the Intelligence

and Security (I&S) Command, and the Corps of Engineers (COE). The COE operates survey and

construction craft, tugs, barges, and other utility craft. COE boats and craft are not covered by

UNDS as described in section 2.2.7.1.

The Army Transportation Corps operates lighterage and floating utility vessels.

Lighterage are craft used to transport equipment, cargo, and personnel between ships, from shipto-shore, and for operational mission support, and include logistics support vessels, landing craft,
2-11

and modular powered causeway ferries. Floating utility craft are used to perform port terminal

operations and include ocean and harbor tugs, floating cranes, barges, and floating causeways.

Army Transportation Corps vessels operate primarily within 12 n.m., with the exception of the

LSV, LCU-2000, and the LT-28, which are ocean-going.

Army I&S vessels are aerostat radar-equipped patrol ships operated in the Caribbean Sea

to counter illegal drug flights. The patrol ships operate within 12 n.m. during transit in and out

of port, but most often operate outside of 12 n.m. Table 2-5 summarizes Army vessel

characteristics including length, displacement, and mission for each vessel classification.

Table 2-5. Army Vessel Classification4, 8

Vessel

Type

Vessel

Classification

Number

Active

Class

Length

(ft)

Displacement

fully loaded

(tons)

Mission

Lighterage LSV 6 273 4,199 Transport equipment, cargo,

LCU-2000 35 174 1,087 and personnel between ships,

LCU -1600 13 135 390 from ship to shore, or for

LCM-8 104 74 111 operational mission support

CF 1 -- --

Floating BC 37 120 760 Perform port terminal

Utility BD 10 140 1630 operations

BG 8 120 763

BK 7 45 33

CHI 1 25 --

FB 2 75 64

HF 1 65 --

J-Boat 4 46 12

LT-128 6 128 1,057

LT-100 16 107 390

PB 10 25 --

Q-Boat 1 65 37

SLWT 4 -- --

ST-65 11 71 122

ST-45 2 45 29

T-Boat 1 65 --

Workboats 47 -- --

Patrol Ships ABT 7 190-194 1500-1,900 Perform drug interdiction in the

Caribbean Sea

TOTAL Vessels = 334
2-12

2.2.5 Vessels of the U.S. Marine Corps1,11

2.2.5.1 Marine Corps Mission

As part of the Department of the Navy and in conjunction with the other Armed Forces,

the Marine Corps develops the tactics, techniques, and equipment necessary to employ forces

onto land from the sea.

2.2.5.2 Marine Corps Vessel Description

The Marine Corps operates a large number of watercraft and amphibious craft used

during special operations. Assets that are primarily land-operated vehicles, such as the

amphibious assault vehicles (AAVs), are not included under UNDS. The watercraft consist of

inflatable combat rubber raiding craft (CRRC) and fiberglass rigid raiding craft (RRC). The

CRRCs are used for in-port, river, lake, and coastal operations, and can be transported to the

combat area by nearly all of the Navy’s vessels. The RRCs are normally deployed aboard Navy

transport dock ships (i.e., LPDs) for transport to the combat area. The CRRCs and RRCs operate

exclusively in coastal waters. Table 2-6 summarizes Marine Corps vessel characteristics

including length, weight, and mission for each vessel classification.

Table 2-6. Marine Corps Vessel Classification

Vessel

Type

Description Number

Active

Class

Length (ft)

Weight

(lbs)

Mission

RRC Rigid Raiding Craft 120 18 -- Perform offensive

CRRC Zodiak

(replacing RRCs)

418 15 265

(without

the

engine)

amphibious operations

TOTAL Vessels = 538

2.2.6 Vessels of the U.S. Air Force1

2.2.6.1 Air Force Mission

The U.S. Air Force defends the U.S. through control and exploitation of air and space.

The Air Force provides land and space-based air forces needed to establish air support for ground

forces in combat and the primary airlift capability for use by all of the nation’s military services.

The Air Force operates vessels to support this mission.

2.2.6.2 Air Force Vessel Description

Missile retrievers (MRs) are aluminum vessels used for the location and recovery of

practice missiles. MRs range in length from 65 to 120 feet. These vessels primarily operate

within 12 n.m.
2-13

Floating utility vessels provide logistics support for Air Force operations and include

utility boats (U), training and recovery boats (TR), and personnel boats (P) ranging in length

from 17 to 40 feet. These vessels operate almost entirely within 12 n.m. Table 2-7 summarizes

Air Force vessel characteristics including length, displacement, and mission for each vessel

classification.

Table 2-7. Air Force Vessel Classification

Vessel

Type

Vessel

Classification

Number

Active

Class

Length

(ft)

Displacement

fully loaded

(tons)

Mission

Missile

Retrievers

MR 5 65-120 90-133 Locate and recover practice

missiles

Floating U 27 17-33 -- Used for personnel and utility

Utility TR 2 21-25 -- transport, training, and repair

P 2 22-40 -- operations

TOTAL Vessels = 36

2.2.7 Vessels Not Covered by UNDS

UNDS applies only to Armed Forces vessels. UNDS does not apply to commercial

vessels; privately owned vessels; vessels owned or operated by State, local, or tribal

governments; or vessels owned or operated by Federal agencies that are not part of the Armed

Forces. In addition, several other categories of vessels are not covered by UNDS, including: 1)

vessels under the jurisdiction of the Army COE; 2) vessels, other than those of the Coast Guard,

under the jurisdiction of the DOT (e.g., MARAD vessels); 3) vessels preserved as memorials and

museums; 4) time- and voyage- chartered vessels; 5) vessels under construction; 6) vessels in

drydock; and 7) amphibious vehicles. These vessels are discussed below.

2.2.7.1 Army Corps of Engineers Vessels

Army Corps of Engineers vessels are typically used for civil works purposes. Congress

has consistently addressed the Army Corps of Engineers separately from other parts of the DoD

in both authorization and appropriations bills.12 The DoD and EPA do not consider that

Congress intended to apply UNDS to Army Corps of Engineers vessels. Therefore, vessels of the

Army Corps of Engineers are not covered by UNDS.

2.2.7.2 Maritime Administration Vessels

A number of vessels are operated or maintained by the Maritime Administration

(MARAD), which is a part of the DOT. As established in § 312(a)(14) of the CWA, the

definition of “vessel of the Armed Forces” includes those DOT vessels that are designated by the

Secretary of the department in which the U.S. Coast Guard is operating (currently the DOT) as

operating as a vessel equivalent to a DoD vessel. The Secretary of Transportation has
2-14

determined that MARAD vessels, including the National Defense Reserve Fleet, do not operate

equivalently to DoD vessels, and therefore, MARAD vessels are not covered by UNDS.13

2.2.7.3 Vessels Preserved as Memorials and Museums

Ships and submarines preserved as memorials and museums once served a military

mission. However, with the exception of one submarine, these vessels are no longer owned or

operated by the Armed Forces, and therefore, they are not vessels of the Armed Forces, and

UNDS does not apply to them. The Navy owns and operates the submarine Nautilus as a

museum; however, the vessel is stationary and its systems are not routinely operated. Therefore,

the EPA and DoD have excluded this vessel from the scope of UNDS.

2.2.7.4 Time- and Voyage-Chartered Vessels

Section 312(a)(14) of the CWA specifically excludes time- and voyage-chartered vessels

from the definition of “vessels of the Armed Forces.” Time- and voyage-chartered vessels are

vessels operating under a contract between the vessel owner and a charterer (in this case, the

Armed Forces) whereby the charterer hires the vessel for a specified time period or voyage,

respectively. Such vessels at all times remain manned and navigated by the owner, and they are

not owned and operated by the Armed Forces. Examples of chartered vessels are those operated

by the MSC in the APF and the Strategic Sealift Program.

2.2.7.5 Vessels Under Construction

EPA and DoD do not consider a vessel under construction for the DoD or Coast Guard,

and for which the Federal government has not taken custody, to be a “vessel of the Armed

Forces.” Therefore, UNDS does not apply to these vessels until the Federal government gains

custody.

2.2.7.6 Vessels in Drydock

The statutory definition of “discharge incidental to the normal operation of a vessel”

includes incidental discharges whenever the vessel is waterborne. See CWA § 312(a)(12).

UNDS does not apply to discharges from vessels while they are in drydock (either land-based or

floating) because they are not waterborne, even if the discharges would otherwise meet the

definition of a “discharge incidental to the normal operation of a vessel.”

2.2.7.7 Amphibious Vehicles

EPA and DoD do not consider amphibious vehicles as vessels for the purposes of UNDS

because they are operated primarily as vehicles on land. Water use of these vehicles is of short

duration for near-shore transit to and from vessels.
2-15

2.3 Locations of Armed Forces Vessels

2.3.1 Homeports

Homeports are the bases from which vessels perform the majority of their operations that

occur within 12 n.m. of shore, and thus give an indication of the zones where most vessel

discharges occur. The sizes and locations of Armed Forces homeports vary with the mission of

the vessels they service. Homeports provide pierside services (e.g., potable water, sewage and

trash disposal, and electrical power), supplies (e.g., repair parts, cleaning materials, and food);

and maintenance and repair functions (e.g., drydock, afloat, and shoreside services).

2.3.1.1 Navy Ports

Norfolk, VA; San Diego, CA; Mayport, FL; Puget Sound, WA; and Pearl Harbor, HI are

the five largest Navy ports based on the number of ships serviced. In addition to these five ports,

the Navy has many comparably sized and smaller ports throughout the U.S. UNDS evaluations

pertain to all U.S. ports, and are not limited to those mentioned above. Figure 2-1 shows the

location of homeports for Navy surface ships and submarines only, and the approximate vessel

distribution. Inactive vessels and vessels ported outside of the U.S. (e.g., in Japan or Bahrain) are

not shown, nor is the distribution of small boats and craft. Small boats and craft are widely

distributed with heavy concentrations near San Diego and Norfolk.

2.3.1.2 Coast Guard Ports

Coast Guard duty stations are found on coastal waters, as well as on rivers, lakes, and

other inland waterways throughout the U.S. Figure 2-2 shows the Coast Guard homeport

locations having three or more vessels that are 65 feet or greater in length. Using the number of

large vessels as an indication of base size, the largest Coast Guard bases are located in

Portsmouth, VA; Honolulu, HI; Boston, MA; Charleston, SC; Alameda, CA; Galveston, TX;

Seattle, WA; and St. Petersburg, FL. Some of the mid-sized bases are located in Corpus Christi,

TX; Key West, FL; Roosevelt Roads, PR; and Miami Beach, FL. There is a ship repair and

overhaul facility in Baltimore, MD. Ship repair and overhaul is usually done at a commercial

facility near the homeport of the vessel.

2.3.1.3 Army Ports

The Army has one major active-component port facility at Fort Eustis near Newport

News, VA. In addition, smaller active and reserve-component port facilities are located in

Accotink, VA; Baltimore, MD; Cieba, PR; Edgewood, MD; Ford Island, HI; Morehead City,

NC; Oakland, CA; Palakta, FL; St. Petersburg, FL; Stockton, CA; Tacoma, WA; and Virginia

Beach, VA. Repair, overhaul, and planned maintenance is performed at commercial shipyards

located near the homeport of the vessel.
2-16

2.3.1.4 Military Sealift Command, Marine Corps, and Air Force Port Usage

The Military Sealift Command makes use of Navy ports, as available, and commercial

ports at all other times. The Marine Corps and Air Force make use of local port facilities, since

they operate no major port facilities of their own. Air Force floating utility vessel locations

include Alamogordo, NM; Cape Canaveral, FL; Fayetteville, NC; Goldsboro, NC; Langley, VA;

Las Vegas, NV; Melbourne, FL; and Pensacola, FL. Air Force missile retrievers are located at

Panama City, FL; Key West, FL; and Carrabelle, FL.

2.3.2 Operation within Navigable Waters of the U.S. and the Contiguous Zone

UNDS applies to discharges from Armed Forces vessels in the navigable waters of the

U.S. and the contiguous zone. As defined in the CWA (§ 502(7)), the term “navigable waters”

means waters of the U.S., including the Great Lakes, and includes waters seaward from the

coastline to a distance of 3 nautical miles from the shore of the States, District of Columbia,

Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, the Canal Zone, and

the Trust Territories of the Pacific Islands. The contiguous zone extends from 3 nautical miles to

12 nautical miles from the coastline. Discharges that occur within this zone that extends 12 n.m.

from shore are addressed in following chapters. UNDS is not enforceable beyond the contiguous

zone.

The amount of time each vessel spends in its homeport varies based on factors such as

vessel class, command, assignment/demand, and budget. For the purposes of UNDS, the DoD

estimated the amount of time spent each year in waters subject to UNDS requirements for each

vessel type, as discussed below.

Ocean-going vessels operate inside 12 n.m. while transiting in and out of port.

Periodically, they may also be used for mission or training exercises within this zone. Service

craft and small boats operate far more frequently near the homeport and within 12 n.m. These

vessels may be stowed aboard ships while in transit to operational areas. When in port, small

boats and craft are often removed from the water until the next required use.

The DoD and EPA used five years of Navy, Coast Guard, and MSC vessel movement

data to support the estimation of time spent within 12 n.m..14 From this operational data, the

average number of port entries, port exits, and days spent in port was determined for most vessel

classes.

The DoD data on ship movement was originally organized as a series of trips from one

point to another for each ship. Each record contained a succeeding trip leg. For example, if a

ship went from Norfolk to Mayport, it may have been reported as a single trip with the date and

time of departure from Norfolk recorded as the departure, and the date and time it arrived in

Mayport as the arrival. It may also have been reported as a series of trips from Norfolk to some

latitude/longitude pair in the Atlantic, from that latitude/longitude to another, from the second

latitude/longitude to a third, etc., with the last entry being a trip from the last latitude/longitude to
2-17

Figure 2-1. Largest Navy Surface Ship and Submarine Homeports

PEARL HARBOR, HI (4a, 23s, 12sc)

NO

SAN DIEGO, CA (1a, 16am, 1c, 8s, 35sc)

MAYPOR

INGLESIDE, TX (21mw)

LIT

BANGOR, WA (9s)

KINGS B

PASCAGOULA, MS (4sc)

BREMERTON, WA (3a, 1c, 1sc)

EVERETT, WA (1c, 6sc)

 a = a am = a c = c mw = m s = s sc = s
2-18

Figure 2-2. Coast Guard Ports with Three or More Vessels Equal to or Longer than 65 Feet

PORTSMOUTH, VA (11)

ALAMEDA, CA (4)

HONOLULU, HI (7)

CAPE CANAVERAL, FL (3)

CORPUS CHRISTI, TX (3)

SEATTLE, WA (6)

NEWPORT, RI (4)

BOSTON, MA (5)

CHARLESTON, SC (5)

BAYONNE, NJ (4)

MOBILE, AL (7)

PHILADELPHIA, PA (3)

ROCKLAND, ME (5)

SAN PEDRO, CA (4)

NEW LONDON, CT (3)

NEW ORLEANS, LA (3)

ST. LOUIS, MO (3)

ROOSEVELT ROADS, PR (5)

GALVESTON, TX (5)

MAYPORT, FL (3)

KEY WEST, FL (4)

MIAMI BEACH, FL (9)

ST. PETERSBURG, FL (4)

CAPE MAY, NJ (7)

WOODS HOLE, MA (4)

SOUTH PORTLAND, ME (3)
2-19

Mayport. Each of the legs of the journey was recorded as a separate record. All of one ship’s

trips for the given year (1991, 1992, 1993, 1994, or 1995) were recorded in succession, before

going on to the next ship. Since the records were in order, it was obvious if there were missing

entries in the data. A missing entry consisted of a ship arriving at a location in one record, and

then departing from a different location in the next record.

The first step was to translate the data from the format received into a format that was

usable for the purposes of UNDS. For the purposes of UNDS, it was more useful to know when

the ship arrived at and departed from a specific location (i.e., a U.S. port), as opposed to looking

at individual trip legs. Therefore, the DoD created a simplified database that was obtained by

taking the arrival location and time from one record, and the departure time and location from the

next. At this point, the data was filtered to exclude data where the location began with a

latitude/longitude pair, and where the arrival location and departure location were not the same

(i.e., a missing entry).

The UNDS program only used the ship/year data from ships where complete data was

available for the entire year. If there was a complete record of where that ship was for the entire

year, the number of days that that ship spent in U.S. ports that year, and the number of times it

transited into and out of any U.S. port that year were recorded. The number of transits and days

in port were totaled for every ship in the class, and that total was divided by the number of shipyears compiled in order to derive averages for that ship class. These final numbers can be

interpreted as the number of transits into and out of U.S. ports and the number of days spent in

U.S. ports for a typical ship of that class.

These numbers vary widely between ship classes due to differing missions, operational

schedules, maintenance, etc.. For instance, a typical DDG 51 Class destroyer averages 101 days

per year in port with 11 transits in and out, compared to a typical ARS 50 Class salvage ship

which may spend an average of 208 days per year in port with 22 transits. The number of days

spent in port and the number of transits per year can vary significantly for the same vessel in

different years due to varying operational and maintenance schedules. For example, the aircraft

carrier CVN 68 spent 10 days in port with two transits in 1995, compared to 237 days in port and

nine transits in 1992. For non-self-propelled vessels (e.g., barges, cranes, and dry dock

companion craft) or harbor-oriented vessels (e.g., harbor utility craft, dredges, and harbor tugs), it

was assumed that the vessels operate within 12 n.m. from shore for the entire year.

By multiplying these typical numbers of days in port and number of transits by the

number of ships in that ship class in service in any given year, a reasonable approximation of the

total number of days spent in U.S. ports and the total number of transits into and out of U.S. ports

for all ships in that class during the year in question was calculated. These values were then used

in combination with pollutant concentration data to calculate mass loadings for vessel discharges.

Based on Navy and Coast Guard operational experience, four hours are typically required

for each one-way transit between port and 12 n.m. (The estimated vessel transit time from shore

to 3 n.m. is approximately 2-3 hours for most locations. A vessel typically requires one

additional hour in order to traverse to 12 n.m. from 3 n.m.) Significantly longer transits, such as
2-20

11 hours to travel 12 n.m. offshore from Puget Sound can occur, but are atypical. Ten hours may

be required in Puget Sound to travel 3 n.m. from the overall shoreline because the port is located

in an inlet at the southern end of the Sound, requiring travel through both the Sound and the

Straits of Juan de Fuca. This creates a transit distance that is actually greater than 3 n.m. when

measured from the port itself.

2.4 References

1. UNDS Vessel Database. August 1997.

2. Polmar, Norman. The Naval Institute Guide to the Ships and Aircraft of the U.S. Fleet, 16th

ed. Annapolis: Naval Institute Press. 1997.

3. Prezelin, Bernard (Ed.). The Naval Institute Guide to Combat Fleets of the World.

Compiled by A.D. Baker III. U.S. Annapolis: Naval Institute Press. 1995.

4. Naval Sea Systems Command. Data Book for Boats and Craft of the United States Navy,

NAVSEA 0900-LP-084-3010, Revision A. 15 May 1988.

5. Commander, Military Sealift Command. “Force Inventory.” Report # 3110-4. Publication

4. 1 June 1996.

6. Military Sealift Command. “Mission Service to Customers, MSC’s Five Programs.” 1997.

7. Saunders, N. T. (U.S. Coast Guard, Assistant Commandant for Operations). “Register of

Cutters of the U.S. Coast Guard.” COMDTINST M5441.5L. 18 November 1996.

8. Scheina, Robert L. U.S. Coast Guard Cutters & Craft 1946-1990. Annapolis: Naval Institute

Press. 1990.

9. Brown, Daniel G. (U.S. Army, Chief of Transportation). Army Watercraft Master Plan.

November 1996.

10. United States Army, Office of the Chief of Transportation (OCOT). “Marine Qualification

Division.” 10 June 1996.

11. Halberstadt, Hans. U.S. Navy Seals in Action. Motorbooks International. 1995.

12. Fatz, Raymond J. (Department of the Army, Deputy Assistant Secretary; Environment, Safety

and Occupational Health). Memorandum through Deputy Assistant Secretary of the Navy

(Environment & Safety). “Status of Army Actions on the Uniform National Discharge

Standards.” 19 May 1997.

13. Delpercio, M. Jr. (Department of Transportation, MARAD, Office of Ship Operations).

Letter to Capt. J. W. Taylor (U.S. Navy, CNO N45) regarding applicability of UNDS to the

Maritime Administration’s National Defense Reserve Fleet. 27 March 1997.

14. Pentagon. “USN, USCG, and MSC Vessel Movement Data from 1991-1995.
3-1

3. DATA COLLECTION

This chapter describes the efforts that were made to obtain information on the UNDS

discharges. An overview of the information collection effort is presented in section 3.1; the

surveys issued to gather discharge information are described in section 3.2 along with the list of

incidental discharges from Armed Forces vessels that resulted; the consultations with personnel

having discharge expertise to review information and identify data gaps are described in section

3.3; section 3.4 describes the consultation and outreach efforts with organizations outside DoD;

section 3.5 discusses the approach to discharge sampling and analysis; and section 3.6 lists the

references cited in Chapter 3.

3.1 Introduction

Section 312(n)(2)(B) of the CWA lists seven factors to consider when determining if a

vessel discharge should be controlled by a MPCD (see section 1.3). One of these factors is the

“nature of the discharge.” To comprehensively consider this factor as well as the other six

factors, EPA and DoD jointly established an UNDS Technical Working Group (TWG) composed

of representatives from EPA and the Armed Forces. The TWG gathered and analyzed technical

data to identify: 1) the universe of Armed Forces vessels subject to UNDS requirements

(described in chapter 2); 2) the characteristics of the vessel discharges, including sources,

frequencies, amounts, and specific constituents; 3) relevant U.S. laws, regulations, and

international standards that limit or otherwise set standards on the amount of contamination

allowed in the discharges; and 4) any controls that are currently in place.

Initial requests were made to each branch of the Armed Forces for discharge information

and for information that would allow a list of vessels subject to UNDS requirements to be

compiled. Personnel within and outside DoD with specific discharge expertise were consulted to

help identify additional available data and data gaps. Where needed, sampling data were

collected from various Armed Forces vessels to supplement existing data. The methods that

were used to collect discharge information are discussed in the following sections.

3.2 Surveys

Survey questionnaires were issued in 1996 by the Navy to obtain information about

vessel discharges and to provide a broad basis for subsequent technical efforts. As part of these

surveys, a memorandum was distributed to the Navy’s technical community, including Navy fleet

commands, subcommands, shore installations, and shipboard operators; other branches of the

Armed Forces; and to all other organizations that are represented on the TWG.1 The

memorandum provided background on the UNDS development effort, an explanation of the

UNDS scope and approach, and two enclosures. The first enclosure was a report entitled U.S.

Navy Ship Wastewater Discharges,

2

 which provided those surveyed with findings from previous

Navy-sponsored efforts on vessel wastewater identification, characterization, and quantification.

The second enclosure was a survey entitled Equipment/System Discharge Stream Questionnaire.

3

This questionnaire sought information about vessel discharges such as: system description, how
3-2

the discharge is generated and released (if applicable), time and location of the discharge,

discharge volume, discharge constituents and their concentrations, contributing vessel classes

and number of vessels, applicable regulations, currently employed control devices and/or

management practices, and any reports or documentation available that were pertinent to the

system or the discharge. Survey recipients were requested to review the report, provide

comments on its contents, and respond to the questionnaire.

In addition to information from the surveys, information was also obtained during presampling “ship checks” (i.e., vessel inspections) and during other scheduled visits to vessels.

During these checks and visits, additional information was often obtained by directly observing

discharges and by talking with the ship’s crew.

3.3 Consultations with Department of Defense Personnel Having Equipment Expertise

The survey responses helped identify incidental vessel discharges and their

characteristics. However, the survey responses did not, in all cases, provide sufficient

understanding of the discharges to make well-supported Phase I decisions. Therefore, the Navy

and EPA met with vessel discharge experts from the government and the private sector (as

consultants to the Navy), including engineers, field-activity representatives, and Navy laboratory

personnel. The objective of these consultations was to obtain information that was not obtained

from the survey responses, such as:

• system equipment design, operation, and maintenance practices;

• discharge volume and composition;

• the numbers and types of vessels producing the discharge; and

• existing engineering and environmental analysis reports for the discharge including

available sampling data.

In addition, these meetings provided information beyond the scope of the surveys, such

as:

• potential MPCD options for controlling the discharge;

• ongoing research and development efforts; and

• information useful for assessing the practicability of implementing various MPCD

options.

The information that was gathered during the numerous consultations on large-vessel

systems (i.e., ships and submarines) was supplemented with information on discharges from

small Navy watercraft during a meeting with the Navy’s small boat group in Norfolk, Virginia.

Meetings were also held with Army representatives from the U.S. Army Tank-Automotive and

Armaments Command (TACOM) in Warren, Michigan and from the 7th Transportation Group at

Fort Eustis, VA to review Army watercraft systems, operations, and discharges.
3-3

After the survey responses and information obtained during ship checks were analyzed,

DoD and EPA developed a list of 39 types of discharges incidental to the normal operation of

Armed Forces vessels. These discharges are listed in Table 3-1.

Table 3-1. Incidental Discharges from Vessels of the Armed Forces

• Aqueous Film-Forming Foam

• Boiler Blowdown

• Catapult Water Brake Tank and PostLaunch Retraction Exhaust

• Catapult Wet Accumulator Discharge

• Cathodic Protection

• Chain Locker Effluent

• Clean Ballast

• Compensated Fuel Ballast

• Controllable Pitch Propeller Hydraulic

Fluid

• Deck Runoff

• Dirty Ballast

• Distillation and Reverse Osmosis Brine

• Elevator Pit Effluent

• Gas Turbine Water Wash

• Graywater

• Hull Coating Leachate

• Firemain Systems

• Freshwater Lay-Up

• Mine Countermeasures Equipment

Lubrication

• Motor Gasoline Compensating

Discharge

• Non-Oily Machinery Wastewater

• Photographic Laboratory Drains

• Portable Damage Control Drain Pump

Discharge

• Portable Damage Control Drain Pump

Wet Exhaust

• Refrigeration/Air Conditioning

Condensate

• Rudder Bearing Lubrication

• Seawater Cooling Overboard Discharge

• Seawater Piping Biofouling Prevention

• Small Boat Engine Wet Exhaust

• Sonar Dome Discharge

• Steam Condensate

• Stern Tube Seals and Underwater

Bearing Lubrication

• Submarine Acoustic Countermeasures

Launcher Discharge

• Submarine Bilgewater

• Submarine Emergency Diesel Engine

Wet Exhaust

• Submarine Outboard Equipment Grease

and External Hydraulics

• Surface Vessel Bilgewater/Oil-Water

Separator Discharge

• Underwater Ship Husbandry

• Welldeck Discharges

3.4 Consultation and Outreach Outside the Department of Defense

During Phase I of UNDS, DoD and EPA consulted with other interested Federal agencies,

States, and environmental organizations. Other Federal agencies that have been involved in

UNDS development include the Coast Guard for DOT; the Department of State; and the National

Oceanic and Atmospheric Administration for the Department of Commerce. The Coast Guard

has been involved in all aspects of UNDS development. The other agencies have participated

with DoD, EPA, and the Coast Guard as members of the UNDS Executive Steering Committee
3-4

(ESC), which is responsible for UNDS policy development and is composed of senior-level

managers. Separately, DoD and EPA provided an overview of the Phase I process and results to

the U.S. Fish and Wildlife Service and the National Marine Fisheries Service.

Two mechanisms were used to consult with States. First, a representative from the

Environmental Council of the States (ECOS) participates in UNDS ESC meetings. ECOS is the

national association of State and territorial environmental commissioners and was established, in

part, to provide State positions on environmental issues to EPA. Second, representatives from

the Navy (as the lead for DoD), EPA, and the Coast Guard met at least once, and in most cases

twice, with each State interested in UNDS development. The states agreeing to these meetings

were predominantly those with significant numbers of Navy or Coast Guard vessels.

3.4.1 Initial State Consultation Meetings

In early 1996, the Navy and EPA invited States with a DoD or Coast Guard vessel

presence to participate in an initial round of consultation meetings. Of the approximately 40

States invited, 21 requested a meeting. These initial State consultation meetings were held

between August and December 1996. State environmental regulatory authorities hosted each

meeting, which consisted of a Navy/EPA briefing on UNDS activities and an opportunity to

discuss State-specific issues. A Coast Guard representative was present at each meeting to

address discharges from Coast Guard vessels. The Navy/EPA briefing summarized the UNDS

legislative history and requirements, considerations for evaluating discharges, the technical

approach for determining which discharges require control, an overview of the vessels to which

UNDS is applicable, and the roles of DoD and EPA in the rulemaking process. The States that

participated in the first round of State meetings are listed in Table 3-2. The minutes from these

meetings are compiled in the Uniform National Discharge Standards State Consultation

Meetings (Round #1) Compendium of Minutes.

4

Table 3-2. States Involved in Initial Consultation Meetings

• Alaska • Illinois • Nevada

• California • Indiana • New York

• Connecticut • Kentucky • North Carolina

• Delaware • Louisiana • Rhode Island

• Florida • Maryland • South Carolina

• Georgia • Michigan • Virginia

• Hawaii • Mississippi • Washington

3.4.2 Second Round of State Consultation Meetings

The Navy and EPA held a second round of State consultation meetings from October

1997 through January 1998. Of the 22 States consulted during the second round of meetings,

five had not been briefed initially. The second round of consultation meetings provided Navy
3-5

and EPA an opportunity to summarize the activities that had taken place since the initial round of

consultation meetings. This included discussing the 39 types of vessel discharges that were

identified and the preliminary decisions regarding which of the discharges would be proposed to

require control. States were given information on the equipment or process generating the

discharges, the locations where the discharges occur, vessels producing the discharges, the

preliminary results of environmental effects screenings, and the preliminary conclusions of

whether MPCDs would be required. States were generally supportive of the UNDS effort.

States most commonly expressed interest in matters related to the implementation of UNDS

regulations, including enforcement and procedures for establishing no-discharge zones; the

relationship between UNDS and other State programs; which vessels are subject to UNDS; and

potential MPCD options. States that participated in the second round of consultation meetings

are identified in Table 3-3. The minutes from these meetings are compiled in the Uniform

National Discharge Standards State Consultation Meetings (Round #2) Compendium of

Minutes.

5

Table 3-3. States Involved in the Second Round of Consultation Meetings

• Alaska • Louisiana • North Carolina

• California • Maryland • Oregon

• Connecticut • Massachusetts • Rhode Island

• Florida • Michigan • Texas

• Georgia • Mississippi • Virginia

• Hawaii • New Hampshire • Washington

• Indiana • New Jersey

• Kentucky • New York

Separately, city representatives from Portland, OR requested a briefing on UNDS

activities. In February 1998, the Navy, EPA, and Coast Guard provided an overview of UNDS to

city representatives. This meeting is summarized in the Uniform National Discharge Standards

State Consultation Meetings (Round #2) Compendium of Minutes.

5

3.4.3 Consultation with Environmental Organizations

In addition to State meetings, the Navy, EPA, and Coast Guard met with environmental

organizations to provide an overview of UNDS and the preliminary results of the first phase of

the UNDS regulatory development process. These meetings were held in December 1997 and

May 1998 and are summarized in the Uniform National Discharge Standards State Consultation

Meetings (Round #2) Compendium of Minutes.

5

3.4.4 UNDS Newsletter and Homepage

To provide a continuous source of information on UNDS and as a way to receive

information relative to UNDS, the Navy and EPA publish a newsletter and an Internet web site.
3-6

The newsletter contains feature articles on UNDS-related subjects (e.g., nonindigenous species,

Navy research and development programs, etc.), provides answers to frequently asked questions,

and provides an update on recent progress and upcoming events. The newsletter is mailed to

State and environmental group representatives, Armed Forces and EPA contacts, and interested

members of the general public. Approximately 360 newsletters are distributed, approximately

200 of which are distributed outside the EPA, DoD, and their contractor’s organizations.

Electronic copies of the newsletter are available for downloading from the UNDS Internet site

(http://206.5.146.100/n45/doc/unds/unds.html). In addition to providing an electronic version of

the newsletter, the Internet site provides UNDS legislative information, a summary of the

technical and management approach to used to develop the rule, and a description of the benefits

expected to result from UNDS. Both the newsletter and the Internet site provide points of

contact for obtaining information on UNDS.

3.5 Sampling and Analysis

3.5.1 Approach to Identifying Discharges Requiring Sampling

The available information for each discharge was evaluated to determine if additional

data were necessary to adequately evaluate potential environmental effects. Sampling was not

required for discharges where existing information was sufficient to characterize the nature of the

discharge and to assess potential environmental impacts, if any. Nine of the 39 types of

discharges required additional information and were sampled.6,7 Table 3-4 lists these discharges.

Table 3-4. Discharges Sampled During Phase 1 of UNDS

• Boiler Blowdown

• Compensating Fuel Ballast

• Distillation and Reverse Osmosis Brine

• Firemain Systems

• Freshwater Lay-Up

• Non-Oily Machinery Wastewater

• Seawater Cooling Overboard Discharge

• Steam Condensate

• Surface Vessel Bilgewater/Oil-Water

Separator Discharge

3.5.2 Approach to Determining Analytes

To determine which constituents to analyze for in the nine sampled discharges, a

comprehensive list of approximately 450 candidate analytes was considered, including the

“priority pollutants” referenced in § 307(a) of the CWA. Analyses for constituents or analytical

groups were not performed if it was evident that these constituents or groups could not be present

based on process knowledge. A sampling rationale document was prepared to describe the

reasons for excluding analytes from analysis on a discharge-by-discharge basis.6,7 Table 3-5

shows the categories of analytes that were analyzed in each of the nine sampled discharges.
3-7

Table 3-5. Type of Analysis According to Discharge

Discharge Classicals VOCs SVOCs Metals Pesticides PCBs Mercury Hydrazine

Boiler Blowdown x x x x x

Compensated Fuel

Ballast

x x x x x x

Distillation and Reverse

Osmosis Brine

x x x

Firemain Systems x x x x

Freshwater Lay-Up x x x x

Non-Oily Machinery

Wastewater

x x x x x x

Seawater Cooling

Overboard Discharge

x x x x

Steam Condensate x x x

Surface Vessel

Bilgewater/ Oil Water

Separator Discharge

x x x x x x x x

Notes:

x = constituents analyzed for, but not necessarily detected.

Classicals: Includes analytes such as total dissolved solids (TDS) and total suspended solids (TSS), as well as other

classical analytes listed in Table 3-8.

PCBs: polychlorinated biphenyls

VOCs: volatile organic compounds

SVOCs: semi-volatile organic compounds

3.5.3 Shipboard Sampling

For the purpose of UNDS Phase I, samples were collected from ten vessels representing a

total of six Navy, Coast Guard, and MSC vessel types. The Navy vessels that were sampled

included an aircraft carrier, three surface combatants, two amphibious ships, and a submarine. A

Coast Guard cutter and two MSC oilers, which are Naval Fleet Auxiliary Support Force vessels

used for fuel transport, were also sampled. The discharges that were sampled on each vessel are

presented in Table 3-6. The reasoning for sampling specific discharges on certain vessel classes

is contained in the sampling rationale document.6,7 In addition, the sampling procedures for eight

of the ten vessels are presented in sampling and analysis plans (SSAP) prepared for each

vessel.8-15 SSAPs were not prepared for the USS Mitscher or the USNS Big Horne because they
3-8

are the same class of vessel as the USS Arleigh Burke and the USNS Laramie, respectively.

Therefore, the SSAPs for the USS Arleigh Burke and the USNS Laramie were used when

sampling the USS Mitscher and the USNS Big Horne, respectively. The details of each sampling

event are documented in a separate volume of the UNDS Phase I Sampling Episode Report,

which contains the sampling analytical results and discusses any deviations from the SSAPs.16

The laboratory methods used to analyze the samples are listed in Tables 3-7 and 3-8.

3.5.4 Quality Assurance/Quality Control and Data Validation Procedures

EPA-approved quality assurance/quality control (QA/QC) and data validation procedures

were used throughout the sample collection and sample analysis activities during Phase I of

UNDS. The field and analytical QA/QC procedures are described in detail in SSAPs8-15 and the

UNDS Phase I Sampling Episode Report.

16 During sample collection in the field, trip and

equipment blanks were collected as well as field duplicate samples. Analytical QA/QC included

analysis of blanks, matrix spikes, and samples. The analyses followed the QA/QC requirements

specified in the analytical methods listed in Tables 3-7 and 3-8.

In addition, the analytical results were validated according to standard EPA procedures.

The purpose of the data validation was to detect and then verify any data values that may not

reflect actual sample constituents and concentrations. The data validation step was conducted to

identify data errors, biases, and outlying data so that such values would not be used when making

Phase I decisions.
3-9

Table 3-6. Discharges Sampled by Ship

Discharge

USS John C.

Amphibious

Assault Ship

(LHD)

USS Wasp

Cruiser

(CG)

USS Anzio

Cutter

(WHEC)

USCG

Dallas

Dock Landing

Ship (LSD)

USS Oak Hill

Attack

Submarine

(SSN)

USS Scranton

Oilers (T-AO)

USNS Laramie

USNS Big

Horne

Boiler Blowdown x x x x x

Compensated Fuel Ballast x

Distillation and Reverse

Osmosis Brine

x x x

Firemain Discharge x x x

Freshwater Lay-Up x

Non-Oily Machinery

Wastewater

x x x x

Seawater Cooling Overboard

Discharge

x x x x x x

Steam Condensate x x x x

Surface Vessel Bilgewater /

Oil-Water Separator Discharge

x
3-10

Table 3-7. Analytes and Analytical Methods

Target Analytes Analytical Method

Classicals see Table 3-8

Volatile Organic Compounds (VOC) EPA Method 1624

Semi-Volatile Organic Compounds (SVOC) EPA Method 1625

Metals EPA Method 1620

Pesticides, Polychlorinated Biphenyls (PCBs) EPA Method 1656, 1657, 1658, 1660

Mercury EPA Method 1631

Hydrazine American Society for Testing and Materials (ASTM)

D1385-88

Table 3-8. Classical Analytes and Methods

Target Chemical/Analyte Analytical Method

Ammonia as Nitrogen (NH3 - N) EPA 350

Total Kjeldahl Nitrogen (TKN) EPA 351

Nitrate/Nitrite (NO2/NO3) EPA 353

Total Phosphorus EPA 365

Total Suspended Solids (TSS) EPA 160.2

Biochemical Oxygen Demand (BOD5) EPA 405.1

Total Organic Carbon (TOC) EPA 415.1

Chemical Oxygen Demand (COD) EPA 410.4

Total Dissolved Solids (TDS) EPA 160.1

Total Volatile Solids (TVS) EPA 160.4

Total Petroleum Hydrocarbons (TPH) EPA 1664

Oil and Grease EPA 1664/

modified EPA 418.2

Cyanide EPA 335

Chlorine DPD* 17

Alkalinity EPA 310

Sulfate EPA 375

Sulfide EPA 376

Chloride EPA 325.1

Notes:

* DPD: N,N-diethyl-p-phenylene diamine

3.6 References

1. NAVSEA letter 5090, Ser 00T/136. 1 July 1996.

2. Ships Environmental Support Office (SESO) Naval Surface Warfare Center Carderock

Division. “U.S. Navy Ship Wastewater Discharges,” TM-63-95/08. 3 July 1995.
3-11

3. NAVSEA. Equipment/System Discharge Stream Questionnaire.

4. U.S. Navy/U.S. EPA. “Uniform National Discharge Standards (UNDS) State Consultation

Meetings (Round #1) Compendium of Minutes.”

5. U.S. Navy/U.S. EPA. “Uniform National Discharge Standards (UNDS) State Consultation

Meetings (Round #2) Compendium of Minutes.”

6. NAVSEA. “Uniform National Discharge Standards Rationale for Initial Discharge

Sampling.” December 1997.

7. NAVSEA. Memorandum to File. Subject: Explanation of Deviations from the Phase I

“Rationale for Discharge Sampling” Document. 21 July 1998.

8. NAVSEA. “Specific Sampling and Analysis Plan,” USS Stennis (CVN). July 1997.

9. NAVSEA. “Specific Sampling and Analysis Plan,” USS Arleigh Burke (DDG). July 1997.

10. NAVSEA. “Specific Sampling and Analysis Plan,” USS Anzio (CGN). July 1997.

11. NAVSEA. “Specific Sampling and Analysis Plan,” USCG Dallas (WHEC). July 1997.

12. NAVSEA. “Specific Sampling and Analysis Plan,” USS Oak Hill (LSD). July 1997.

13. NAVSEA. “Specific Sampling and Analysis Plan,” USS Scranton (SSN). July 1997.

14. NAVSEA. “Specific Sampling and Analysis Plan,” USNS Laramie (T-AO). July 1997.

15. NAVSEA. “Specific Sampling and Analysis Plan,” USS Wasp (LHD). July 1997.

16. NAVSEA. “UNDS Phase 1 Sampling Episode Report,” Volumes 1-13. February 1998.

17. American Public Health Association, American Water Works Association, and the Water

Pollution Control Federation. Standard Methods for the Examination of Water and

Wastewater. Method 4500-Cl G. DPD Colorimetric Method. 17th Edition. Washington,

DC: American Public Health Association. 1989.

4-1

4. DISCHARGE EVALUATION METHODOLOGY

4.1 Introduction

The information collected during Phase I from surveys, consultations, and from discharge

sampling and analysis was used collectively to evaluate the discharges and to make Phase I

decisions according to the seven factors listed in section 1.3. This chapter explains how Phase I

decisions were made for the 39 discharge types listed in Table 3-1 (i.e., which discharges need to

be controlled by MPCDs and which do not). Section 4.2 describes how the environmental effects

screening of the discharges was conducted. Section 4.3 describes the Nature of Discharge

(NOD) analysis and the contents of the NOD reports contained in Appendix A. Section 4.4

describes the MPCD practicability, operational feasibility, and cost analysis and the contents of

the MPCD reports - also contained in Appendix A. Section 4.5 lists the chapter 4 references.

4.2 Environmental Effects Determination

EPA and DoD assessed the potential environmental effects of the discharges using a

screening approach characterized by the following questions concerning their chemical, physical,

and biological characteristics:

• Chemical Constituents. Does the discharge contain constituents in concentrations

that exceed State aquatic water quality criteria or Federal aquatic water quality criteria

(as promulgated by EPA in the National Toxics Rule (NTR)1) and have the potential to

be released into the environment in significant amounts, resulting in a potential

adverse impact on the environment?

• Thermal Pollution. Does the discharge pose the potential to exceed State thermal

water quality criteria in the receiving waters beyond a mixing zone, and to a degree

sufficient to have an adverse impact on the environment?

• Bioaccumulative Chemicals of Concern. Does the discharge have the potential to

contain bioaccumulative chemicals of concern in amounts sufficient to have an adverse

impact on the environment?

• Nonindigenous Species. Does the discharge have the potential to introduce viable

nonindigenous aquatic species to new locations?

If the answer to any of the above questions was “yes,” EPA and DoD determined that the

discharge had a potential for adverse environmental effect. Each of these factors is discussed

below.

4.2.1 Chemical Constituents

EPA and DoD used sampling results or process knowledge to identify the potential

presence and concentrations of constituents in the discharge. Constituent concentrations in the

discharge were compared to Federal aquatic water quality criteria promulgated by EPA in the

National Toxic Rule (NTR)1 and State aquatic water quality numeric criteria for the ten States
4-2

with the most significant presence of Armed Forces vessels.2-11 These ten States are California,

Connecticut, Florida, Georgia, Hawaii, Mississippi, New Jersey, Texas, Virginia, and

Washington. Constituent concentrations in the discharge were compared against the most

stringent of the Federal and ten States’ criteria for that constituent. For almost all constituents,

the State aquatic water quality criteria are more stringent than the Federal NTR aquatic water

quality criteria. EPA and DoD used aquatic water quality criteria in this assessment because they

are a measure of the level of water quality that provides for the protection and propagation of

aquatic life.

EPA and DoD used saltwater aquatic life criteria for screening the discharges because

most Armed Forces vessels operate in the brackish water of estuaries or bays, or in the marine

environment off the coast or in open ocean, where the biology of the waterbody is dominated by

saltwater aquatic life. In addition, aquatic life criteria were used instead of human health criteria,

which are related to consumption of fish and shellfish, because recreational activities such as

fishing and swimming generally do not occur in the immediate vicinity of Armed Forces vessels.

Depending on the nature of the discharge, EPA and DoD compared discharge

concentrations to either the acute or chronic aquatic water quality criteria values. Where

discharges are intermittent or occasional in nature, of relatively short duration (a few seconds to a

few hours), and dissipate rapidly in the environment, constituent concentrations were compared

to acute aquatic water quality criteria. Where discharges are of a longer duration or continuous

and likely to result in concentrations in the environment that approach a steady-state condition,

the constituent concentrations were compared to chronic aquatic water quality criteria. Table 4-1

is a list of the most stringent saltwater-based aquatic water quality criteria for the constituents

that were either detected in UNDS discharge samples or thought to be present based on

engineering knowledge. It contains aquatic water quality criteria for both short-term (acute) and

long-term (chronic) exposure published in Federal and State regulations.

Because metals may be present in the discharges in both dissolved and solid forms, the

Federal criteria and many States’ criteria distinguish between dissolved and “total recoverable”

forms. As issued by EPA or a particular State, an aquatic water quality criterion for the dissolved

form of a metal is always less than or equal to the criterion for the “total recoverable” form.

However, not all States issue criteria for both forms of metal. For metal constituents, the

following method was used to compare concentrations in the discharge to aquatic water quality

criteria:

• When the form of the metal was known (i.e., either “total recoverable” or

“dissolved”) as in the nine discharges that were sampled, as well as some of the nonsampled discharges, the measurement of “total recoverable” metal in the discharge

was compared to “total recoverable” criteria, and the measurement of “dissolved”

metal in the discharge was compared to “dissolved” criteria.

• When the form of the metal was unknown, the metal concentration was compared to

the most stringent criteria, whether for “total recoverable” or “dissolved.”
4-3

Table 4-1. Aquatic Life Water Quality Criteria

Constituent Name Most Stringent Acute

Aquatic Life Water

Quality Criterion

Source of

 Most Stringent

 Acute Criterion

Most Stringent

Chronic Aquatic

Life Water Quality

Criterion

Source of

 Most Stringent

Chronic Criterion

PRIORITY POLLUTANTS* (μg/L) (μg/L)

Acenaphthene 320 HI --------

Acenaphthylene 0.031 a FL 0.031 a FL

Acrolein, 2-Propenal 18 HI 780 GA

Anthracene 110,000 GA 110,000 GA

Antimony 4,300 FL 4,300 FL

Arsenic (Dissolved) 69 EPA, CA, HI, CT 36 EPA, CA, HI, CT

Arsenic (Total) 36 GA, FL 36 GA, FL, WA, MS

Benzene 71.28 FL, GA 71.28 FL, GA

Benzidine 0.000535 GA 0.000535 GA

Benzo(a)anthracene 0.031 a FL 0.031 a FL

Benzo(a)pyrene 0.031 a FL 0.031 a FL

Benzo(b)fluoranthene 0.031 a FL 0.031 a FL

Benzo(g,h,i)perylene 0.031 a FL 0.031 a FL

Benzo(k)fluoranthene 0.031 a FL 0.031 a FL

Beryllium 0.13 FL 0.13 FL

BHC, alpha- ** 0.0131 GA 0.0131 GA

BHC, beta- ** 0.046 GA, FL 0.046 GA, FL

BHC, gamma- \ Lindane ** 0.0625 GA 0.01 VA

Bis(2-ethylhexyl) phthalate 5.92 GA 5.92 GA

Cadmium (Dissolved) 42 EPA, CA, CT 9.3 EPA, CA, HI, VA, CT,

MS

Cadmium (Total) 9.3 GA, FL 8 WA

Chromium (Dissolved) 1,100 EPA & 6 STATES 50 EPA & 6 STATES

Chromium (Total) 50 GA, FL 50 WA, GA, FL

Chrysene 0.031 a FL 0.031 a FL

Copper (Dissolved) 2.4 EPA, CT, MS 2.4 EPA, CT, MS

Copper (Total) 2.9 WA 2.9 GA. FL

Cyanide 1 EPA & 9 STATES 1 EPA & 9 STATES

Dibenzo(a,h)anthracene 0.031 FL 0.031 FL

Diethyl phthalate 120,000 GA 120,000 GA

Dimethyl phthalate 2,900,000 GA 2,900,000 GA

Ethylbenzene 140 HI 28,718 GA

Fluoranthene 13 HI 370 GA

Fluorene 14,000 GA 14,000 GA

Heptachlor 0.00021 FL 0.00021 FL

Heptachlor epoxide 0.00011 GA 0.00011 GA

Indeno(1,2,3-cd)pyrene 0.031 a FL 0.031 a FL

Lead (Dissolved) 140 HI, TX 5.6 TX

Lead (Total) 5.6 GA, FL 5.6 GA, FL

Mercury ** (Dissolved) 1.8 EPA, CA, CT, MS 0.025 VA

Mercury ** (Total) 0.025 GA, FL 0.025 EPA, WA, GA, CT, MS,

FL
4-4

Table 4-1. Aquatic Water Quality Criteria (contd.)

Constituent Name Most Stringent Acute

Aquatic Life Water

Quality Criterion

Source of

 Most Stringent

 Acute Criterion

Most Stringent

Chronic Aquatic

Life Water Quality

Criterion

Source of

 Most Stringent

Chronic Criterion

Naphthalene 780 HI --------

Nickel (Dissolved) 74 EPA, CA, CT 8.2 EPA, CA, CT

Nickel (Total) 8.3 GA, FL 7.9 WA

Nitrophenol, 4- 1,600 HI --------

Phenanthrene 0.031 a FL 0.031 a FL

Phenol 170 HI 58 MS

Pyrene 11,000 GA 11,000 GA

Selenium (Dissolved) 290 EPA, CA, CT 71 EPA, CA, HI, VA, CT,

MS

Selenium (Total) 71 GA, FL 71 WA, GA, FL

Silver (Dissolved) 1.9 EPA, CA, MS --------

Silver (Total) 1.2 WA 1.2 WA

Thallium 6.3 FL 6.3 FL

Toluene 2,100 HI 200,000 GA

Trichloroethane, 1,1,1- 10,400 HI --------

Zinc (Dissolved) 90 EPA, CA, CT, MS 81 EPA, CA, MS

Zinc (Total) 84.6 WA 76.6 WA

NON-PRIORITY

POLLUTANTS

Chlorine (Chlorine Produced

Oxidants)

10 FL 7.5 HI, WA, VA, CT, MS,

NJ

Oil & Grease 5,000 FL 5,000 FL

Aluminum 1,500 FL 1,500 FL

Ammonia as NH3*** 6 HI 6 HI

Bromine 100 FL 100 FL

Chloride 10% >

ambient

FL 10% >

ambient

FL

Iron 300 FL 300 FL

Nitrate/Nitrite*** 8 HI 8 HI

Phosphorus*** 25 HI 25 HI

Total Nitrogen*** 200 HI 200 HI,

Tributyltin 0.001 VA 0.001 VA

Notes:

* from 40 CFR 136.36

** Denotes bioaccumulative chemicals of concern (40 FR 15366, Table 6A)

*** Nutrient criteria are not specified as either acute or chronic and are, therefore, listed in both columns.

a: Total of acenaphthylene benzo(a)anthrancene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene,

benzo(k)fluoranthene chrysene, dibenz(a,h)anthracene, indeno(1,2,3-c,d)pyrene, and phenanthrene.
4-5

The initial screening process involved comparing the constituent concentrations in the

undiluted discharge to the aquatic water quality criteria. For those discharges, such as cathodic

protection, where the constituents diffuse from the exterior of a vessel or vessel component, EPA

and DoD generally computed a concentration within a small mixing zone (a few inches to a few

feet).

EPA and DoD further assessed those discharges that had constituents exceeding aquatic

water quality criteria. EPA and DoD considered mass loadings, flow rates, the geographic

location of the discharge, the manner in which the discharge occurs (e.g., continuous or

intermittent), and in some cases, the effect of the dilution within a small mixing zone. The

purpose of this further assessment was to determine whether the constituents are discharged with

such a low frequency or in such small amounts that the resulting constituent mass loading has the

potential to produce only minor or undetectable environmental effects, or whether the

constituents are released in such a manner that dilution in a small mixing zone quickly results in

concentrations below aquatic water quality criteria. If so, EPA and DoD considered the chemical

constituents of the discharge not to have the potential to adversely affect the environment.

4.2.2 Thermal Pollution

In addition to chemical constituents, EPA and DoD assessed whether the discharges

exceeded State thermal water quality criteria for the five States with the most significant presence

of Armed Forces vessels (California, Florida, Hawaii, Virginia, and Washington). A screening

study was performed on these discharges to quantify these potential effects.12 Many discharges

did not need a detailed assessment because they are discharged at ambient or only slightly

elevated temperatures, or the volume or discharge rate is very low. EPA and DoD determined

that six discharges are released at sufficiently high temperatures and volumes that further

assessment was warranted to determine whether the discharge had the potential to cause an

adverse thermal effect. These discharges are:

• Boiler Blowdown;

• Catapult Water Brake Tank and Post-Launch Retraction Exhaust;

• Catapult Wet Accumulator Discharge;

• Distillation And Reverse Osmosis Brine;

• Seawater Cooling Overboard Discharge; and

• Steam Condensate.

EPA and DoD modeled these discharges to determine the size of the mixing zone that

would be needed for receiving waters to meet State thermal water quality criteria and compared

this zone to State thermal mixing zone allowances. Small boat engine wet exhaust, firemain

systems, portable damage control drain pump wet exhaust, and submarine emergency diesel

engine wet exhaust discharges also have elevated temperatures above ambient when released.

These discharges generally have minimal temperature differences between the influent and

effluent streams, are released in small volumes, and generally occur only while the vessel is

moving, which distributes the heat load over a wide area. Submarine emergency diesel engine

wet exhaust is released into the air as a mist and cools before contacting the water. The overall
4-6

thermal impact from these discharges is minimal; thus, they were not included in the thermal

effects study.

Two screening protocols were used to evaluate thermal discharges. For discharges that

can be continuous such as steam condensate, seawater cooling overboard discharge, and

distillation and reverse osmosis brine, the Cornell Mixing Zone Expert System (CORMIX,

Version 3.2) was used to estimate the plume size and temperature gradients in the receiving

waterbody for comparison to mixing zone requirements for States with major naval ports.

CORMIX is a software model used to analyze and predict aqueous pollutant discharges into

water bodies. The output from CORMIX provides the shape and size of the thermal plume along

with temperature contours that can then be compared to various thermal criteria. However,

CORMIX has several limitations when modeling this discharge, including modeling the effect of

tidal action and turbulent mixing beyond the plunge zone (i.e., area of initial mixing from a

discharge above the waterline) on the discharge plume. Therefore, additional modeling was

performed using a hydrodynamic transport model, CH3D, to evaluate steam condensate because

CH3D simulates the mixing of the buoyant plume with ambient and tidal flows by advection and

turbulent mixing both horizontally and vertically in the water column.13

For discharges that can be intermittent, short-duration, or batch (boiler blowdown,

catapult water brake tank and post-launch retraction exhaust, and catapult wet accumulator

blowdown), thermodynamic equations were used to estimate the temperature effects because

CORMIX and CH3D were designed primarily for continuous, steady-state discharges. Batch

discharges of high-temperature water require a different screening approach than continuous

discharges because these discharges are not steady-state and are generally small. The steps used

to estimate the maximum size of the impact zone for a given acceptable plume temperature

included:

• calculating the total heat and water mass released;

• calculating the volume of water needed to dilute this mass of water such that the

acceptable mixed temperature is obtained; and

• determining the region around the release point assuming complete vertical mixing

that will provide the required volume.

4.2.3 Bioaccumulative Chemicals of Concern

EPA and DoD reviewed each discharge to determine whether it contained

bioaccumulative chemicals of concern, as identified in the Final Water Quality Guidance for the

Great Lakes System.14 This guidance contains a list of bioaccumulative chemicals of concern

identified after scientific study, in a process subjected to public notice and comment, designed to

support a regionally uniform set of standards applicable to the waters of the Great Lakes. Table

4-2 lists these bioaccumulative chemicals of concern. In every case where the presence of a

bioaccumulative chemical of concern was confirmed in a discharge, EPA and DoD had already
4-7

determined based on other information that it was reasonable and practicable to require control of

that discharge.

4.2.4 Nonindigenous Species

EPA and DoD also assessed each discharge for its potential to transport viable living

aquatic organisms between naturally isolated water bodies. Preventing the introduction of

invasive nonindigenous aquatic species has been recognized as important in maintaining

Table 4-2. List of Bioaccumulative Chemicals of Concern14

• BHC, alpha-

• BHC, beta-

• BHC, delta-

• BHC, gamma- \Lindane

• Chlordane

• DDD

• DDE

• DDT

• Dieldrin

• Hexachlorobenzene

• Hexachlorobutadiene

• Mercury

• Mirex/Dechlorane

• PCB-1016

• PCB-1221

• PCB-1232

• PCB-1242

• PCB-1248

• PCB-1254

• PCB-1260

• Pentachlorobenzene

• 1,2,4,5-Tetrachlorobenzene

• 2,3,7,8-Tetrachlorodibenzo-

 p-dioxin

• Toxaphene

Notes:

BHCs are chlorinated cyclohexanes DDD and DDE are metabolites of DDT

DDT is dichlorodiphenyl trichloroethane PCBs are polychlorinated biphenyls

biodiversity, water quality, and the designated uses of water bodies. If the available data indicate

that a discharge has a potential for transporting and then subsequently discharging viable aquatic

organisms into waters of the U.S., then EPA and DoD considered the discharge to present a

potential for causing adverse environmental effects from nonindigenous species.

4.2.5 Discharge Evaluation

In some cases, EPA and DoD determined it was reasonable and practicable to require

MPCDs to control a discharge even though available information indicates that the discharge has

a low potential for adversely affecting the environment. For the Chain Locker Effluent and

Sonar Dome discharges, at least one class of Armed Forces vessel has a management practice or

control technology already in place to control the environmental effects of the discharge. EPA

and DoD considered the existence of a currently applied management practice or control

technology to be sufficient indication that it was reasonable and practicable to require a MPCD.

In other cases (Non-Oily Machinery Wastewater and Photographic Laboratory Drains), analysis
4-8

of whether the discharge had a potential to adversely affect the environment was inconclusive.

However, EPA and DoD determined that it was reasonable and practicable to require a MPCD to

mitigate possible adverse environmental effects from the discharge.

For each discharge that was determined to have the potential to adversely affect the

environment, EPA and DoD conducted an initial evaluation of the practicability, operational

impact, and economic cost of using a MPCD to control each discharge. EPA and DoD first

determined whether a control technology or management practice is currently in place to control

the discharge for environmental protection on any vessel type. The use of existing controls on a

vessel was considered sufficient demonstration that at least one reasonable and practicable

control is available for at least one vessel type. The Phase I UNDS rule does not address whether

existing control technologies or management practices are adequate to mitigate potential adverse

impacts. In Phase II of UNDS, EPA and DoD will promulgate MPCD performance standards for

the discharges requiring control. For discharges without any existing pollution controls, EPA

and DoD analyzed potential pollution control options to determine whether it is reasonable and

practicable to require the use of MPCDs. For every discharge that was found to have a potential

to cause adverse environmental effects, EPA and DoD determined that it is reasonable and

practicable to require a MPCD for at least one vessel type. The results of the MPCD assessments

are presented in Appendix A.

4.3 Nature of Discharge Analysis

The nature of the discharge was analyzed for each of the 39 discharges incidental to the

operations of Armed Forces vessels (Table 3-1), and based on this analysis, a NOD report was

prepared that describes the discharge in detail, including the system that produces the discharge,

the equipment involved, the constituents released to the environment, and the current practice, if

any, to prevent or minimize environmental effects. The NOD report summarizes the results of

additional sampling or other data gathered on the discharge. Based on this information, the NOD

report describes how the estimated constituent concentrations and mass loadings in the

environment were determined. The constituent concentrations are compared to applicable

Federal and State water quality criteria. In addition to comparing discharge concentrations to

Federal and State water quality criteria, other U.S. laws and international standards were also

evaluated, including the standards for oil established by the International Convention for the

Prevention of Pollution from Ships (MARPOL) (73/78) as implemented by the Act to Prevent

Pollution from Ships, and the oil spill regulations at 40 CFR Part 110. Where Federal law and

international standards were relevant to a discharge, the law and standards are discussed in the

NOD reports contained in Appendix A.

In addition, known bioaccumulative chemicals of concern are identified, possible thermal

effects are discussed (if applicable) and the potential for introducing nonindigenous aquatic

species is assessed. The NOD report also discusses the potential for the discharge to cause

adverse environmental effects.
4-9

4.3.1 Nature of Discharge Report Contents

NOD reports are divided into six sections, the outline of which is presented below:

Section 1.0 -- Introduction

Provides a brief description of the basic objectives of the NOD analysis. This section is identical for each of

the reports.

Section 2.0 – Discharge Description

2.1 Equipment Description and Operation – this section describes the equipment and ship operations that

generate the discharge. It includes any pertinent figures and schematics that assist in explaining the origin

of the discharge.

2.2 Releases to the Environment – this section describes the actual discharge released to the environment.

The section also describes how the discharge is released, such as whether the flow is a stream, a mist, or

results from direct contact with surrounding waters.

2.3 Vessels Producing the Discharge – this section describes which Armed Forces vessels produce the

discharge.

Section 3.0 -- Discharge Characteristics

3.1 Locality – this section describes whether the discharge occurs within 12 n.m. from shore.

3.2 Rate – this section presents the estimated flow rate of the discharge. This rate can be a distinct flow in

the case of liquid discharges, or a release rate in the case of constituents that corrode, erode, or dissolve into

the environment.

3.3 Constituents – this section identifies the constituents in the discharge, including thermal pollution, when

applicable. Included in this section is an identification of those pollutants known to be particularly

detrimental to environmental quality. Section 3.3 includes the following:

• a list of all constituents identified in the discharge;

• identification of priority pollutants; and

• identification of bioaccumulative chemicals of concern.

3.4 Concentrations – this section presents the concentrations of the constituents in the discharge. When

possible, this is estimated from an analysis of the existing data or alternatively, from process knowledge of

the system that produces the discharge. When sampling was conducted, results of the sample analyses are

presented.

Section 4.0 - Nature of Discharge Analysis

4.1 Mass Loadings -- in this section, the flow rate and the concentrations presented in section 3.0 are used

to calculate an estimated annual mass loading on a fleet-wide basis.

4.2 Environmental Concentrations – this section varies with each analysis, but includes a comparison of

the concentrations (from section 3.4) with the Federal aquatic water quality criteria and aquatic water

quality criteria for selected States. Where appropriate, this section presents estimates of the concentrations

after dilution in the environment. Any mixing zone calculations are clearly explained and assumptions are
4-10

listed. Pertinent figures from any analysis are included to support statements regarding the results of the

analysis.

4.3 Potential for Introducing Nonindigenous Species – this section describes an evaluation of the potential

for the discharge to transport and introduce nonindigenous aquatic species.

Section 5.0 -- Conclusion

Provides a summary of the assessment of the potential for the discharge to cause an adverse environmental

effect based on information presented in the report.

Section 6.0 -- Data Sources and References

This section contains a table that indicates the type and source of information presented in each section of

the analysis. The section also lists the references cited in the report.

4.3.2 Peer Review

Peer review is a documented critical review of a scientific and technical work product. It

is an in-depth assessment that is used to ensure that the final work product is technically sound.

Peer reviews are conducted by qualified individuals who are independent of those who prepared

the work product. For the Phase I rule, reviewers were selected because of their technical

expertise in assessing pollutant behavior in coastal and estuarine ecosystems, modeling pollutant

concentrations, and predicting the effects of pollutant loadings on ambient water quality,

sediments, and biota.

NOD reports for five discharges were selected for peer review. For each of these

discharges, EPA and DoD determined that it is not reasonable and practicable to require the use

of MPCDs because they exhibit a low potential for causing adverse impacts on the marine

environment. Peer reviewers were asked whether the data and process information presented in

the NOD reports are sufficient to characterize the discharges; whether the analyses are

appropriate for the discharges; and whether the conclusions regarding the discharges’ potential

for causing adverse environmental impacts are supported by the information presented in the

NOD reports. Peer review comments are compiled in a separate report.15

EPA and DoD reviewed the peer review comments and determined that the comments did not

indicate any fundamental flaws in the methodology used to assess a discharge's potential to cause

adverse impacts on the marine environment. EPA and DoD resolution of peer review comments

are compiled in Uniform National Discharge Standards For Vessels Of The Armed Forces Peer

Review Comment Response. 16
4-11

4.4 MPCD Practicability, Operational Feasibility, and Cost Analysis

If a discharge was determined to have a potential to cause an adverse environmental

impact in the absence of pollution controls, EPA and DoD evaluated the practicability,

operational impact, and economic cost of using a MPCD to control the discharge. First, EPA and

DoD determined whether a control technology or management practice is currently in place to

control the discharge for environmental protection on any vessel type. The use of existing

controls was considered sufficient demonstration that at least one practicable control is available.

The Phase I UNDS rule does not address whether existing control technologies or management

practices are adequate to mitigate potential adverse impacts. In Phase II of UNDS, EPA and

DoD will promulgate MPCD performance standards for the discharges requiring control. For

discharges without any existing pollution controls but having the potential to cause an adverse

environmental impact, EPA and DoD analyzed potential pollution control options to determine

whether it is reasonable and practicable to require the use of MPCDs. Practicability analyses

were prepared for the following four discharges (these analyses are contained in Appendix A):

• Distillation and Reverse Osmosis Brine;

• Hull Coating Leachate;

• Small Boat Engine Wet Exhaust; and

• Underwater Ship Husbandry.

For every discharge that showed a potential to cause adverse environmental effects, EPA

and DoD determined that it is reasonable and practicable to require a MPCD.

4.4.1 MPCD Practicability, Operational Feasibility, and Cost Report Contents

Each MPCD report gives a brief description of the discharge, lists and describes the

MPCD options, and reports the results of analyzing each MPCD option according to

practicability, operational impact, cost, and environmental effectiveness. The contents of the

MPCD reports are briefly described below:

Analysis of Practicability, Operational Impact, and Cost of Selected MPCD Options

This section describes the purpose of the MPCD analysis and discusses the factors that are considered when

determining which discharges should be controlled by MPCDs.

1.0 MPCD Options

This section describes the discharge and how it is generated and lists each of the MPCD options considered.

2.0 MPCD Analysis Results

This section presents the results of the MPCD analysis including discussions on practicability, effect on

operational and warfighting capabilities, cost, environmental effectiveness, and a determination for each

MPCD option. It recommends one or more MPCD options for further consideration under Phase II of

UNDS.
4-12

4.5 References

1. USEPA. “Water Quality Standards.” 40 CFR Part 131.36. The following Federal Register

notices addressed the National Toxic Rule that is promulgated at 40 CFR Part 131.36:

“Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic Pollutants,”

57 FR 60848, 22 December 1992, and “Water Quality Standards; Establishment of Numeric

Criteria for Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria,” 60

FR 22230, 4 May 1995.

2. State of Florida. “Florida Department of Environmental Protection. Surface Water Quality

Standards,” Chapter 62-302. Effective 26 December 1996.

3. State of Georgia. Georgia Final Regulations. “Water Quality Control,” Chapter 391-3-6 as

provided by The Bureau of National Affairs, Inc. 1996.

4. State of Connecticut. Connecticut Department of Environmental Protection. “Surface Water

Quality Standards,” Effective 8 April 1997.

5. State of Mississippi. Mississippi Department of Environmental Quality, Office of Pollution

Control. “Water Quality Criteria for Intrastate, Interstate and Coastal Waters.” Adopted 16

November 1995.

6. State of Texas. Texas Natural Resource Conservation Commission. “Texas Surface Water

Quality Standards.” 307.2 - 307.10. Effective 13 July 1995.

7. State of New Jersey. New Jersey Final Regulations. “Surface Water Quality Standards.”

Section 7:9B-1, as provided by The Bureau of National Affairs, Inc. 1996.

8. USEPA. “Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California,” Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. .62, Number 150. 5 August 1997.

9. State of Hawaii. “Water Quality Standards.” Chapter 54, Section 11-54.

10. State of Washington. “Water Quality Standards for Surface Waters of the State of

Washington.” Chapter 173-201A. Washington Administrative Code.

11. State of Virginia. “Water Quality Standards.” Chapter 260. Virginia Administrative Code

VA 9; VAC 25-260.

12. NAVSEA. “Thermal Effects Screening of Discharges From Vessels of the Armed Forces.”

July 1997.

13. USNavy/USEPA. “Supplement to Thermal Effects Screening of Discharges from Vessels of

the Armed Forces.”

14. USEPA. Table 6A of the “Water Quality Guidance for the Great Lakes System.” 60 FR

15365. 23 March 1995.

15. USEPA. “Peer Review Comments Document, Nature of Discharge Reports for Uniform

National Discharge Standards.” Contract No. 68-C7-0002, Work Assignment No. 1-50. 1

July 1998.

16. USNavy/USEPA. “Uniform National Discharge Standards For Vessels Of The Armed Forces

Peer Review Comment Response.” 1 March 1999.
5-1

5. PHASE I DISCHARGE DETERMINATIONS

This chapter summarizes the 39 discharge types listed in Table 3-1 and the UNDS Phase I

decisions made regarding whether MPCDs are required. Section 5.1 provides this information

for the discharges that EPA and DoD determined to require MPCDs; section 5.2 provides

information for the discharges determined not to require MPCDs; and section 5.3 lists the chapter

5 references.

5.1 Discharges Determined To Require MPCDs

For the reasons discussed below, EPA and DoD have determined that it is reasonable and

practicable to require the use of a MPCD to control 25 types of discharges from vessels of the

Armed Forces. Except where noted, the pollutant characteristics of these discharges indicate a

potential to cause adverse environmental impacts. Table 5-1 lists those discharges for which EPA

and DoD determined it was reasonable and practicable to require the use of an MCPD, and

identifies the characteristics of each discharge that formed the basis of the determination.

For the Phase I rule, EPA and DoD identified at least one potential MPCD control option

for each discharge that could mitigate the environmental impacts of the discharge from at least

one class of Armed Forces vessel. In Phase II of the UNDS rulemaking, EPA and DoD will

perform a more detailed assessment of MPCD control options. EPA and DoD will consider

options that are being evaluated as part of research and development programs in addition to

those that are currently available. EPA and DoD will evaluate MPCDs for all classes of vessels

and promulgate the specific performance standards for each MPCD that are reasonable and

practicable for that class of vessel. In developing specific MPCD performance standards, EPA

and DoD will consider the same factors considered in Phase I. The Phase II rule may distinguish

among vessel types and sizes, between new and existing vessels, and may waive the applicability

of Phase II standards as necessary or appropriate to a particular type or age of vessel (see CWA

section 312(n)(3)(B)).

A MPCD is a control technology or a management practice that can reasonably and

practicably be installed or otherwise used on a vessel of the Armed Forces to receive, retain,

treat, control or discharge a discharge incidental to the normal operation of the vessel.

The discussions below provide a brief description of the discharges and the systems that

produce the discharges EPA and DoD propose to control. The discussions highlight the most

significant constituents released to the environment, and describes the current practice, if any, to

prevent or minimize environmental effects. Because of the diversity of vessel types and designs,

these control practices are usually not uniformly applied to all vessels generating the discharge.

In addition, these controls do not necessarily represent the only control options available. A

more detailed discussion of the discharges is presented in the NOD reports in Appendix A.
5- 2

Table 5-1. Discharges Requiring the Use of a MPCD and the Basis for the Determinationa

Chemical Constituents

Discharge Oil Metals Organic

Chemicals

Thermal

Pollution

Bioaccumulative

Chemicals

of Concern

Nonindigenous

Species

Other

Aqueous Film-Forming Foam (b)

Catapult Water Brake Tank

Discharge and Post-Launch

Retraction Exhaust

X

Chain Locker Effluent (c)

Clean Ballast X

Compensated Fuel Ballast X

Controllable Pitch Propeller

Hydraulic Fluid

X

Deck Runoff X

Dirty Ballast X

Distillation and Reverse

Osmosis Brine

X

Elevator Pit Overboard

Discharge

X

Firemain Systems X

Gas Turbine Washdown

Discharge

X X

Graywater X

Hull Coating Leachate X

Motor Gasoline

Compensating Overboard

Discharge

X

X

Non-Oily Machinery

Wastewater

(d)

Photographic Laboratory

Drains

(d)

Seawater Cooling Overboard

Discharge

X X

Seawater Piping Biofouling

Prevention

(e)

Small Boat Engine Wet

Exhaust

X

Sonar Dome Discharge (c)

Submarine Bilge Water X

Surface Vessel Bilge

Water/Oil-Water Separator

Discharge

X

Underwater Ship Husbandry X X

Welldeck Discharges X
5- 3

Notes:

(a) This table provides a simplified overview of the basis for requiring the use of MPCDs for particular

discharges. It is not intended to fully characterize the discharges or describe the analyses leading to the

decision. More complete characterizations of the discharges and the analyses leading to the decisions are

presented in this section and in Appendix A.

(b) Discharge may produce floating foam in violation of some State water quality standards.

(c) Discharge was determined to have a low potential to adversely affect the environment, but an existing

MPCD is in place on at least one type of vessel to reduce this low potential even further.

(d) No conclusion was drawn on the potential of the discharge to adversely affect the environment, but EPA

and DoD determined a MPCD is reasonable and practicable to mitigate any possible adverse effects.

(e) Chlorine and chlorination byproducts.

5.1.1 Aqueous Film-Forming Foam (AFFF)

This discharge consists of a mixture of seawater and firefighting foam discharged during

training, testing, and maintenance operations. Aqueous film forming foam (AFFF) is the primary

firefighting agent used to extinguish flammable liquid fires on surface ships of the Armed Forces.

AFFF is stored on vessels as a concentrated liquid that is mixed with seawater to create the

diluted solution (3-6% AFFF) that is sprayed as a foam on the fire. The solution is applied with

both fire hoses and fixed sprinkler devices. During planned maintenance of firefighting systems,

system testing and inspections, and flight deck certifications, the seawater/foam solution is

discharged either directly overboard from hoses, or onto flight decks and then subsequently

washed overboard. These discharges are considered incidental to the normal operation of Armed

Forces vessels. Discharges of AFFF that occur during firefighting or other shipboard emergency

situations are not incidental to normal operations and are not subject to the requirements of the

rule.

AFFF is discharged from all Navy ships, those MSC ships capable of supporting

helicopter operations, and Coast Guard cutters, icebreakers, and tugs. AFFF discharges generally

occur at distances greater than 12 n.m. from shore, and in all cases more than 3 n.m. from shore

due to existing Armed Forces operating instructions. The constituents of AFFF include water, 2-

(2-butoxyethoxy)-ethanol, urea, alkyl sulfate salts, amphoteric fluoroalkylamide derivative,

perfluoroalkyl sulfonate salts, triethanolamine, and methyl-1H-benzotriazole. Because the water

used to mix with the AFFF concentrate comes from the vessel’s firemain, the discharge will also

include bis(2-ethylhexyl)phthalate, nitrogen (measured as total Kjeldahl nitrogen), copper, nickel,

and iron from the firemain piping.

The AFFF discharge produces an aqueous foam intended to cool and smother fires. Water

quality criteria for some States include narrative requirements for waters to be free of floating

materials attributable to domestic, industrial, or other controllable sources, or include narrative

criteria prohibiting discharges of foam. AFFF discharges in State waters would be expected to

result in violating such narrative criteria for foam or floating materials. At present, the Navy uses

certain management practices to control these discharges, including a self-imposed prohibition

on AFFF discharges in coastal waters by most Armed Forces vessels. These management

practices to control discharges of AFFF demonstrate the availability of a MPCD to mitigate the
5- 4

potential adverse impacts that could result from the discharge of AFFF. Therefore, EPA and

DoD have determined that it is reasonable and practicable to require use of a MPCD for this

discharge.

AFFF discharges occur beyond 3 n.m. but within 12 n.m. from shore infrequently and in

relatively small volumes, and preliminary investigation indicates that the diluted (3-6%) AFFF

solution does not exhibit significant toxic effects. Further, any discharges that do occur take

place while the vessel is underway and will be dispersed in the turbulence of the vessel wake.

5.1.2 Catapult Water Brake Tank and Post-Launch Retraction Exhaust

This intermittent discharge is the oily water skimmed from the catapult water brake tank,

and the condensed steam discharged when the catapult is retracted. Catapult water brakes are

used to stop the forward movement of the steam-propelled catapults used to launch aircraft from

Navy aircraft carriers. The catapult water brake system includes water brake cylinders and a

water brake tank that contains freshwater. During flight operations, water from the catapult

water brake tank is continuously injected into the catapult water brake cylinders. At the end of a

launch stroke, spears located on the front of the catapult pistons enter the water brake cylinders.

The water in the cylinders builds pressure ahead of the spears, cushioning the catapult pistons to

a stop. The catapult brake water is continuously circulated between the catapult water brake tank

and the catapult water brake cylinders.

Prior to the launch stroke, lubricating oil is applied to the catapult cylinder through which

the catapult piston and piston spear are driven. As the catapult piston is driven forward during

the launch stroke, the catapult piston and spear carries lubricating oil from the catapult cylinder

into the water brake cylinder at the end of the stroke. Over the course of multiple launchings, the

oil and water circulating through the water brake cylinder and tank leads to the formation of an

oil layer in the water brake tank. The oil layer can adversely affect water brake operation by

interfering with the cooling of water in the water brake tank. To prevent excessive heat buildup

in the tank, the oil is periodically skimmed off and discharged overboard. Additionally, as the

catapult piston is retracted following the launch, expended steam from the catapult launch stroke

and some residual lubricating oil from the catapult cylinder walls are discharged below the

waterline through a separate exhaust pipe.

Only aircraft carriers generate this discharge. Catapult operations during normal flight

operations generate both the water brake tank discharge and the post-launch retraction exhaust;

however, flight operations take place beyond 12 n.m. from shore. Catapult testing which occurs

within 12 n.m. always discharges the post-launch retraction exhaust, but usually does not add

sufficient quantities of oil to the water brake tank to require skimming.

The water brake tank is used within 12 n.m. for dead-load catapult shots when testing

catapults on new aircraft carriers, and following major drydock overhauls or major catapult

modifications. This testing requires a minimum of 60 dead-load shots each and may occur over a

period of several days within 12 n.m. from shore. New carrier testing occurs only once, and

major overhauls generally occur on 5- to 7-year cycles in conjunction with drydocking. Major
5- 5

modifications to catapults may occur during an overhaul or pierside and are also infrequent

events. Carriers also routinely perform no-load shots when leaving port. The number of no-load

shots conducted when leaving port, however, usually do not add enough lubricating oil to the

water brake tank to require skimming the oil while the ship is within 12 n.m. from shore.

The Water Brake Tank and Post-Launch Retraction exhaust discharge includes

lubricating oil, a limited thermal load associated with the heated oil and water (or condensed

steam, in the case of the post-launch retraction exhaust), nitrogen (in the form of ammonia,

nitrates and nitrites, and total Kjeldahl nitrogen), and metals such as copper and nickel from the

piping systems. EPA and DoD analyzed the thermal effects of this discharge and concluded they

were unlikely to exceed thermal mixing zone criteria in the States where aircraft carriers most

frequently operate. The post-launch retraction exhaust discharge can contain oil, copper, nickel,

ammonia, bis(2-ethylhexyl)phthalate, phosphorus, and benzidine in concentrations exceeding

State acute water quality criteria. The post-launch retraction exhaust discharge can also contain

nitrogen in concentrations exceeding the most stringent State water quality criteria.

The Navy has imposed operational controls limiting the amount of oil applied to the

catapult cylinder during the launch stroke, which directly affects the amount of oil that is

subsequently discharged from the water brake tank or during the post-launch retraction exhaust.

The Navy has also established requirements prescribing when catapult testing is required within

12 n.m. from shore. These operational constraints minimize discharges of oil from the water

brake tank and post-launch retraction exhaust in coastal waters. These existing management

practices demonstrate the availability of controls for this discharge. Therefore, EPA and DoD

have determined that it is reasonable and practicable to require use of a MPCD to mitigate

potential adverse environmental impacts from this discharge.

5.1.3 Chain Locker Effluent

This discharge consists of accumulated precipitation and seawater that is occasionally

emptied from the compartment used to store the vessel’s anchor chain.

The chain locker is a compartment used to store anchor chain aboard vessels. Navy

policy requires that the anchor chain, appendages, and anchor on Navy surface vessels be washed

down with seawater during retrieval to prevent onboard accumulation of sediment. During

washdown, some water adheres to the chain and is brought into the chain locker as the chain is

stored. The chain locker sump accumulates the residual water and debris that drains from the

chain following anchor chain washdown and retrieval, or washes into the chain locker during

heavy weather. Water accumulating in the chain locker sump is removed by a drainage eductor

powered by the shipboard firemain system.

All Armed Forces vessels housing their anchor chains in lockers, except submarines, can

generate this discharge. Since submarine chain lockers are always open to the sea, water is

always present in the chain locker and there is no “collected” water to be discharged as effluent.

Navy policy prohibits discharging chain locker effluent within 12 n.m. Other vessels of the

Armed Forces are currently authorized to discharge chain locker effluent within 12 n.m.;
5- 6

however, most Armed Forces vessels also observe the 12 n.m. discharge prohibition. A recent

review of practices on several Navy ships found no water accumulation in the chain locker sump,

and the ships’ crew confirmed that discharges of chain locker effluent occur outside 12 n.m.

In addition to water, materials collecting in the chain locker sump can include paint chips,

rust, grease, and other debris. Chain locker effluent may contain organic and inorganic

compounds associated with this debris, as well as metals from the sump and from sacrificial

anodes installed in the chain locker to provide cathodic protection. If the anchor chain

washdown is not performed and the chain locker effluent is subsequently discharged in a

different port, the discharge could potentially transport nonindigenous species. Discharge

volume will vary depending upon the frequency of anchoring operations, the number of anchors

used, and the depth of water (which determines the amount of chain that will be lowered into the

water).

Given the manner in which water collects in the chain locker sump and remains there for

extended periods of time, it is possible that the discharge could contain elevated levels of metals

at concentrations exceeding State water quality criteria. However, given the small volume of the

discharge and the infrequency of anchoring operations, it is unlikely that discharges of chain

locker effluent would adversely impact the environment. Nevertheless, the Navy and other

Armed Forces already have management practices in place for most vessels requiring anchors

and anchor chains to be washed down with seawater during retrieval, and prohibiting the

discharge of chain locker effluent until beyond 12 n.m. from shore. DoD has chosen as a matter

of policy to continue prohibiting the discharge of chain locker effluent within 12 n.m. from

shore. This prohibition, while not considered necessary to mitigate an existing or potential

adverse impact, will eliminate the possibility of discharging into coastal waters any metals, other

contaminants, or nonindigenous aquatic species that may have accumulated in the chain locker

sump. EPA and DoD have determined that the existing management practices demonstrate that

it is reasonable and practicable to require use of a MPCD for chain locker effluent.

5.1.4 Clean Ballast

This discharge is composed of the seawater taken into, and discharged from, dedicated

ballast tanks used to maintain the stability of the vessel and to adjust the buoyancy of

submarines.

Many types of Armed Forces vessels store clean ballast in dedicated tanks in order to

adjust a vessel’s draft, buoyancy, trim, and list. Clean ballast may consist of seawater taken

directly onboard into the ballast tanks or seawater received from the vessel’s firemain system.

Clean ballast differs from “dirty ballast” and “compensated ballast” discharges (described below)

in that clean ballast is not stored in tanks that are also used to hold fuel. Many surface vessels

introduce clean ballast into tanks to replace the weight of off-loaded cargo or expended fuel to

improve vessel stability while navigating on the high seas. Amphibious ships also flood clean

ballast tanks during landing craft operations to lower the ship’s stern, allowing the well deck to

be accessed. Submarines introduce clean ballast into their main ballast tanks when submerging,

and introduce clean ballast into their variable ballast tanks to make minor adjustments to
5- 7

buoyancy, trim, and list while operating submerged or surfaced. The discharge occurs when fuel

or cargo is taken on and the ballast is no longer needed, when amphibious operations are

concluded and the vessel is returned to its normal operating draft, when submarines surface, or

when submarines make some operational adjustments in trim or list while submerged or

surfaced.

Clean ballast discharges are intermittent and can occur at any distance from shore,

including within 12 n.m. Constituents of clean ballast can include materials from tank coatings

(e.g., epoxy), chemical additives (e.g., flocculant chemicals or rust inhibitors), and metals from

piping systems and sacrificial anodes used to control corrosion. Based on analytical data for

firemain system discharges, metals expected to be present in the discharge include copper, nickel,

and zinc. These data indicate that the pollutant concentrations in the discharge may exceed State

water quality criteria.

Previous studies have documented the potential of ballasting operations to transfer

nonindigenous aquatic species into receiving waters. Ballast water potentially contains living

microorganisms, plants, and animals that are native to the location where the water was pumped

aboard. When the ballast water is transported to another port or coastal area and discharged, the

surviving organisms are released and have the potential to invade and impact the local

ecosystem.

The Navy, MSC, and Coast Guard either currently implement or are in the process of

approving a ballast water management policy requiring open-ocean ballast water exchange, based

on guidelines established by the International Maritime Organization.1 These management

practices demonstrate the availability of controls to mitigate the potential adverse environmental

impacts from this discharge. Therefore, EPA and DoD have determined that it is reasonable and

practicable to require a MPCD for discharges of clean ballast.

5.1.5 Compensated Fuel Ballast

This intermittent discharge is composed of the seawater taken into, and discharged from,

tanks designed to hold both fuel and ballast water to maintain the stability of the vessel.

Compensated fuel ballast systems are configured as a series of fuel tanks that

automatically draw in seawater to replace fuel as it is consumed. Keeping the fuel tanks full in

this manner enhances the stability of a vessel by using the weight of the seawater to compensate

for the mass of ballast lost through fuel consumption. During refueling, fuel displaces the

seawater, and the displaced seawater is discharged overboard.

Compensated fuel ballast is discharged by approximately 165 Navy surface vessels and

submarines. In most cases, surface ships with compensated fuel ballast systems discharge

directly to surface waters each time they refuel. However, in some situations that discharge is

collected for processing on shore. Surface vessels are refueled both in port and at sea. All at-sea

refueling is accomplished beyond 12 n.m. from shore. For submarines, refueling occurs only in

port and the compensated ballast is transferred to shore facilities for processing.
5- 8

The compensated fuel ballast discharge can contain 2-propenal, phosphorus, thallium, oil

(and its constituents, such as benzene, phenol, and toluene), copper, mercury (a bioaccumulative

chemical of concern), nickel, silver, and zinc. Concentrations of 2-propenal, benzene, copper,

nickel, phosphorus, silver, thallium, and zinc can exceed acute Federal criteria or State acute

water quality criteria. The compensated fuel ballast discharge can also contain nitrogen (in the

form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen) in concentrations exceeding

the most stringent State water quality criteria.

To reduce the discharge of fuel in compensated fuel ballast discharge, the Navy has

instituted operational guidelines intended to reduce the potential for overfilling tanks or

discharging excessive amounts of fuel entrained in the displaced compensating water while

refueling surface vessels. These guidelines limit the amount of fuel that can be taken on in port

(i.e., to prevent “topping off” the fuel tanks) and establish maximum allowable rates for in port

refueling. Additionally, submarines transfer all compensated fuel ballast water to shore facilities

when refueling diesel fuel oil tanks. These operational controls for surface vessel refueling and

the practice of transferring the discharge to shore for submarines demonstrates the availability of

MPCDs to mitigate potential adverse environmental impacts; therefore, EPA and DoD have

determined it is reasonable and practicable to require the use of a MPCD for compensated fuel

ballast.

5.1.6 Controllable Pitch Propeller Hydraulic Fluid

This discharge is the hydraulic fluid that is discharged into the surrounding seawater from

propeller seals as part of normal operation, and the hydraulic fluid released during routine

maintenance of the propellers.

Controllable pitch propellers (CPP) are used to control a vessel’s speed or direction while

maintaining constant propulsion plant output (i.e., varying the pitch, or “bite,” of the propeller

blades allows the propulsion shaft to remain turning at a constant speed). CPP blade pitch is

controlled hydraulically through a system of pumps, pistons, and gears. Hydraulic oil may be

released from CPP assemblies under three conditions: leakage through CPP seals, releases

during underwater CPP repair and maintenance activities, or releases from equipment used for

CPP blade replacement.

Over 200 Armed Forces vessels have CPP systems. Leakage through CPP seals can

occur within 12 n.m., but seal leakage is more likely to occur while the vessel is underway than

while pierside or at anchor because the CPP system operates under higher pressure when a vessel

is underway. Blade replacement occurs in port on an as-needed basis when dry-docking is

unavailable or impractical, resulting in some discharge of hydraulic oil. Approximately 30 blade

replacements and blade port cover removals (for maintenance) are conducted annually, fleetwide.

CPP assemblies are designed to operate at 400 psi without leaking. Typical pressures

while pierside range from 6 to 8 psi. CPP seals are designed to last five to seven years, which is

the longest period between dry-dock cycles, and are inspected quarterly to check for damage or
5- 9

excessive wear. Because of the hub design and the frequent CPP seal inspections, leaks of

hydraulic oil from CPP hubs are found to be negligible. During the procedure for CPP blade

replacement, however, hydraulic oil is released to the environment from tools and other

equipment. In addition, hydraulic oil could also leak from the CPP hub during a CPP blade port

cover removal.

The Navy’s repair procedures impose certain requirements during blade replacement and

blade port cover removal to minimize the amount of hydraulic oil released to the extent possible.

In addition, booms are placed around the aft end of the vessel to contain possible oil release

during these procedures. Nevertheless, EPA and DoD have determined that the amount of

hydraulic oil released during underwater CPP maintenance could create an oil sheen and exceed

State water quality criteria. Constituents of the discharge could include paraffins, olefins, and

metals such as copper, aluminum, tin, nickel, and lead. Metal concentrations are expected to be

low because hydraulic oil is not corrosive, and the hydraulic oil is continually filtered to protect

against system failures.

EPA and DoD have determined that pollution controls are necessary to mitigate the

potential adverse environmental impacts that could result from releases of hydraulic oil during

underwater maintenance on controllable pitch propellers. The existing repair procedures and the

staging of containment booms and oil skimming equipment to capture released oil demonstrate

the availability of MPCDs (i.e., best management practices) for this discharge. Therefore, EPA

and DoD have determined that it is reasonable and practicable to require MPCDs to control

discharges of CPP hydraulic fluid.

5.1.7 Deck Runoff

Deck runoff is an intermittent discharge generated when water from precipitation,

freshwater washdowns, wave action, or spray falls on the exposed portion of a vessel such as a

weather deck or flight deck. This water is discharged overboard through deck openings and

washes overboard any residues that may be present on the deck surface. The runoff drains

overboard to receiving waters through numerous deck openings. All vessels of the Armed Forces

produce deck runoff, and this discharge occurs whenever the deck surface is exposed to water,

both within and beyond 12 n.m.

Contaminants present on the deck originate from topside equipment components and the

many varied activities that take place on the deck. This discharge can include residues of

gasoline, diesel fuel, Naval distillate fuel, grease, hydraulic fluid, soot, dirt, paint, glycol,

cleaners such as sodium metasilicates, and solvents. A number of metal and organic pollutants

may be present in the discharge, including silver, cadmium, chromium, copper, nickel, lead,

benzene, ethylbenzene, toluene, xylene, polycyclic aromatic hydrocarbons, and phenol. Mass

loadings and concentrations of these constituents will vary with a number of factors including

ship operations, deck washdown frequency, and the frequency, duration, and intensity of

precipitation events.
5-10

Based on the results from limited sampling from catapult troughs (a component of runoff

from aircraft carrier flight decks), oil and grease, phenols, chromium, cadmium, nickel, and lead

could be present in this discharge at levels exceeding acute Federal criteria and State acute water

quality criteria. If not properly controlled, oil collecting in catapult troughs can cause deck

runoff from aircraft carrier flight decks to create an oil sheen on the surface of the receiving

water, which would violate State water quality criteria. Armed Forces vessels already institute

certain management practices intended to reduce the amount of pollutants discharged in deck

runoff, including keeping weather decks cleared of debris, immediately mopping up and cleaning

spills and residues, and engaging in spill and pollution prevention practices. These practices

demonstrate the availability of controls to mitigate adverse impacts from deck runoff. Therefore,

EPA and DoD have determined it is reasonable and practicable to require a MPCD for deck

runoff.

5.1.8 Dirty Ballast

This intermittent discharge is composed of the seawater taken into, and discharged from,

empty fuel tanks to maintain the stability of the vessel. The seawater is brought into these tanks

for the purpose of improving the stability of a vessel during rough sea conditions. Prior to taking

on the seawater as ballast, fuel in the tank to be ballasted is transferred to another fuel tank or

holding tank to prevent contaminating the fuel with seawater. Some residual fuel remains in the

tank and mixes with the seawater to form dirty ballast. Dirty ballast systems are configured

differently from compensated ballast and clean ballast systems. Compensated ballast systems

continuously replace fuel with seawater in a system of tanks as the fuel is consumed. Clean

ballast systems have tanks that carry only ballast water and are never in contact with fuel. In a

dirty ballast system, water is added to a fuel tank after most of the fuel is removed.

Thirty Coast Guard vessels generate dirty ballast as a discharge incidental to normal

vessel operations. These Coast Guard vessels do so because their size and design do not allow

for a sufficient volume of clean ballast tanks. The larger of these vessels discharge the dirty

ballast at distances beyond 12 n.m. from shore, while the smaller vessels discharge the dirty

ballast between 3 and 12 n.m. from shore. Coast Guard vessels monitor the dirty ballast

discharge with an oil content monitor. If the dirty ballast exceeds 15 parts per million (ppm) oil,

it is treated in an oil-water separator prior to discharge.

Expected constituents of dirty ballast are Naval distillate fuel or aviation fuel. Based on

sampling results for compensated fuel ballast, which is expected to have similar constituents to

dirty ballast, this discharge can contain oil (and its constituents such as benzene and toluene);

biocidal fuel additives; metals such as copper, mercury (a bioaccumulative chemical of concern),

nickel, silver, thallium, and zinc; and the constituents 2-propenal, nitrogen (in the form of

ammonia and total Kjeldahl nitrogen), and phosphorus.

Uncontrolled discharges of dirty ballast would be expected to exceed acute Federal

criteria or State acute water quality criteria for oil, benzene, , copper, nickel, phosphorus, 2-

propenal, silver, thallium, and zinc. Concentrations of nitrogen would be expected to exceed the

most stringent State water quality criteria. The use of oil content monitors and oil-water
5-11

separators to reduce the concentration of oil (and associated constituents) demonstrates the

availability of MPCDs to control this discharge. Therefore, EPA and DoD have determined that

it is reasonable and practicable to require the use of MPCDs to control discharges of dirty ballast.

5.1.9 Distillation and Reverse Osmosis Brine

This intermittent discharge is the concentrated seawater (brine) produced as a byproduct

of the processes used to generate freshwater from seawater.

Distillation and reverse osmosis plants are two types of water purification systems that

generate freshwater from seawater for a variety of shipboard applications, including potable

water for drinking and hotel services, and high-purity feedwater for boilers. Distillation plants

boil seawater, and the resulting steam is condensed into high-purity distilled water. The

remaining seawater concentrate, or “brine,” that is not evaporated is discharged overboard.

Reverse osmosis systems separate freshwater from seawater using semi-permeable membranes as

a physical barrier, allowing a portion of the seawater to pass through the membrane as freshwater

and concentrating the suspended and dissolved constituents in a saltwater brine that is

subsequently discharged overboard.

Distillation or reverse osmosis systems are installed on approximately 540 Armed Forces

vessels. This discharge can occur in port, while transiting to or from port, or while operating

anywhere at sea (including within 12 n.m.). Distillation plants on steam-powered vessels may be

operated to produce boiler feedwater any time a vessel’s boilers are operating; however,

operational policy limits its use in port for producing potable water because of the increased risk

of biofouling from the water in harbors and the reduced demand for potable water. MSC steampowered vessels typically operate one evaporator while in port to produce boiler feedwater; most

diesel and gas-turbine powered MSC vessels do not operate water purification systems within 12

n.m.

Pollutants detected in distillation and reverse osmosis brine include copper, iron, lead,

nickel, , and zinc. The sampling data indicate that copper, lead, nickel, iron, and zinc can exceed

acute Federal criteria or State acute water quality criteria. The distillation and reverse osmosis

brine discharge can also contain nitrogen (in the form of ammonia, nitrates and nitrites, and total

Kjeldahl nitrogen) and phosphorus in concentrations exceeding the most stringent State water

quality criteria. The mass loadings of copper and iron are estimated to be significant. Thermal

effects modeling of distillation plant discharges indicates that the thermal plume does not exceed

State water quality criteria.

Review of existing practices indicate that certain operational controls limiting the use of

distillation plants and reverse osmosis units can reduce the potential for this discharge to cause

adverse environmental impacts in some instances. Additionally, it appears that, for some vessels,

reverse osmosis units may present an acceptable alternative to the use of distillation plants.

Reverse osmosis units discharge brines are expected to contain lower concentrations of metals

because these systems have non-metallic membranes and ambient operating temperatures,

resulting in less system corrosion. Further analysis is necessary before determining whether
5-12

distillation plants should be replaced by reverse osmosis units. Nevertheless, existing operational

practices for distillation and reverse osmosis plants and the availability of reverse osmosis units

to replace distillation units on some vessels demonstrates the availability of MPCDs to reduce the

effects of this discharge. Therefore, EPA and DoD have determined that it is reasonable and

practicable to require the use of MPCDs to control discharges from distillation and reverse

osmosis plants.

5.1.10 Elevator Pit Effluent

This discharge is the liquid that accumulates in, and is occasionally discharged from, the

sumps of elevator wells on vessels. Most large surface ships have at least one type of elevator

used to transport supplies, equipment, and personnel between different decks of the vessel.

These elevators generally can be classified as either a closed design in which the elevator

operates in a shaft, or an open design used to move aircraft between decks. Elevators operating

in a shaft are similar to the conventional design seen in many buildings. For these elevators, a

sump is located in the elevator pit to collect liquids entering the elevator and shaft areas. Deck

runoff and elevator equipment maintenance activities are the primary sources of liquids entering

the sump. On some vessels, the elevator sump is equipped with a drain to direct liquid wastes

overboard. On others, piping is installed that allows an eductor to pump the pit effluent

overboard. However, most vessels collect and containerize the pit effluent for disposal onshore

or process it along with their bilgewater.

The elevators used on aircraft carriers to move aircraft and helicopters from one deck to

another are an open design (i.e., there is no elevator shaft). The elevator platform is supported by

cables and pulleys, and it operates on either the port or starboard side of the ship away from the

hull. Unlike elevators with pits, the aircraft elevators are exposed to the water below and there

are no systems in place for collecting liquid wastes.

Coast Guard, Army and Air Force vessels do not have elevators and therefore do not

produce this discharge. The discharge of elevator pit effluent may occur at any location, within

or beyond 12 n.m. from shore. Constituents in elevator pit effluent are likely to include grease,

lubricating oil, fuel, hydraulic fluid, cleaning solvents, dirt, paint chips, aqueous film-forming

foam, glycol, and sodium metasilicate. The discharge can also contain nitrogen (measured as

total Kjeldahl nitrogen) and metals from firemain water used to operate eductors draining the

elevator pit.

The concentrations of copper, iron, nickel, and bis(2-ethylhexyl)phthalate in firemain

water (discussed in section 5.1.11) may exceed acute Federal criteria or State acute water quality

criteria. The elevator pit effluent discharge can also contain nitrogen in concentrations

exceeding the most stringent State water quality criteria. Constituent concentrations and mass

loadings vary among ship classes depending on the frequency of elevator use, the size of the

elevator openings, the amount and concentration of deck runoff, and the frequency of elevator

equipment maintenance activities. Material accumulated in elevator pits is either collected for

disposal onshore or directed to the bilgewater system for treatment through an oil-water separator

prior to discharge. These existing practices demonstrate the availability of controls to reduce the
5-13

potential for this discharge to cause adverse impacts on the environment. Therefore, EPA and

DoD have determined that it is reasonable and practicable to require MPCDs for elevator pit

effluent.

5.1.11 Firemain Systems

This discharge is the seawater pumped through the firemain system for firemain testing,

maintenance, and training, and to supply water for the operation of certain vessel systems.

Firemain systems distribute seawater for firefighting and other services aboard ship.

Firemain water is provided for firefighting through fire hose stations, sprinkler systems, and

foam proportioners, which inject aqueous film-forming foam (AFFF) into firemain water for

distribution over flammable liquid spills or fire. Firemain water is also directed to other services

including ballast systems, machinery cooling, lubrication, and anchor chain washdown.

Discharges of firemain water incidental to normal vessel operations include anchor chain

washdown, firemain testing, various maintenance and training activities, bypass flow from the

firemain pumps to prevent overheating, and cooling of auxiliary machinery equipment (e.g.,

refrigeration plants). UNDS does not apply to discharges of firemain water that occur during

firefighting or other shipboard emergency situations, because they are not incidental to the

normal operation of a vessel.

Firemain systems aboard Armed Forces vessels are classified as either wet or dry. Wet

firemain systems are continuously charged with water and pressurized so that the system is

available to provide water upon demand. Dry firemains are not continuously charged with water,

and consequently do not supply water upon demand. Dry firemain systems are periodically

tested and are pressurized during maintenance or training exercises, or during emergencies.

With the exception of small boats and craft, all Armed Forces vessels use firemain

systems. All Navy surface ships and some MSC vessels use wet firemain systems. Submarines

and all Army and Coast Guard vessels use dry firemains. Firemain system discharges occur both

within and beyond 12 n.m. from shore. Flow rates depend upon the type, number, and operating

time of the equipment and systems using water from the firemain system.

Samples were collected from three vessels with wet firemain systems and analyzed to

determine the constituents present. Because of longer contact times between seawater and the

piping in wet firemains, and the use of zinc anodes in some seachests and heat exchangers to

control corrosion, pollutant concentrations in wet firemains are expected to be higher than those

in dry firemain systems. Pollutants detected in the firemain discharge include nitrogen

(measured as total Kjeldahl nitrogen), copper, nickel, iron, and bis(2-ethylhexyl)phthalate. The

concentrations of iron exceeded the most stringent State chronic water quality criteria. The

concentrations of nitrogen exceeded the most stringent State water quality criteria. Copper,

nickel, and bis(2-ethylhexyl)phthalate concentrations exceeded the relevant chronic Federal

criteria and State chronic water quality criteria. These concentrations contribute to a significant

total mass loading in the discharge due to the large volume of water discharged from wet

firemain systems. Circulation through heat exchangers to cool auxiliary machinery increases the
5-14

temperature of the firemain water, but the resulting thermal effects do not exceed State mixing

zone criteria.

Firemain systems have a low potential for transporting nonindigenous aquatic species,

primarily because the systems do not transport large volumes of water over great distances. In

addition, stagnant portions of the firemain tend to develop anaerobic conditions that are

inhospitable to most marine organisms.

EPA and DoD believe that dry firemain systems may offer one means for reducing the

total mass of pollutants discharged from firemain systems. The use of dry firemains for Coast

Guard vessels demonstrates that, for at least some types of vessels, this option may be an

available control mechanism. Another possible MPCD option for achieving pollutant reductions

is the use of alternative piping systems (i.e., different metallurgy) that provide lower rates of pipe

wall corrosion and erosion. The use of dry firemains and the potential offered by alternative

piping systems demonstrates the availability of controls to mitigate potential adverse impacts on

the environment. Therefore, EPA and DoD have determined that it is reasonable and practicable

to require the use of a MPCD for firemain systems.

5.1.12 Gas Turbine Water Wash

Gas turbine water wash consists of water periodically discharged while cleaning internal

and external components of propulsion and auxiliary gas turbines. Approximately 155 Armed

Forces vessels use gas turbines for either propulsion or auxiliary power generation. Gas turbine

water wash is generated within 12 n.m. and varies by the type of gas turbine and the amount of

time it is operated. Because the drain collecting system is limited in size, discharges may occur

within 12 n.m. On most Navy and MSC gas turbine ships, gas turbine water wash is collected in

a dedicated collection tank and is not discharged overboard within 12 n.m. On ships without a

dedicated collection tank, this discharge is released as a component of deck runoff, welldeck

discharges, or bilgewater.

Expected constituents of gas turbine water wash are synthetic lubricating oil, grease,

solvent-based cleaning products, hydrocarbon combustion by-products, salts from the marine

environment, and metals leached from metallic turbine surfaces. The concentration of

naphthalene (from solvents) in the discharge is expected to exceed State acute water quality

criteria. To limit the impacts of gas turbine water wash discharge while operating in coastal

areas, most vessels direct the discharge to a dedicated holding tank for shore disposal. This

containment procedure demonstrates the availability of controls for this discharge. Therefore,

EPA and DoD have determined that it is reasonable and practicable to require the use of a MPCD

for gas turbine water wash.

5.1.13 Graywater

Section 312(a)(11) of the CWA defines graywater as “galley, bath, and shower water.”

Recognizing the physical constraints of Armed Forces vessels and the manner in which

wastewater is handled on these vessels, graywater is more broadly defined for the purposes of
5-15

UNDS. For the purposes of this regulation, the graywater discharge consists of graywater as

defined in CWA section 312(a)(11), as well as drainage from laundries, interior deck drains,

water fountains and miscellaneous shop sinks. All ships, and some small boats, of the Armed

Forces generate graywater on an intermittent basis. Graywater discharges occur both within and

beyond 12 n.m. from shore. Most Armed Forces vessels collect graywater and transfer it to shore

treatment facilities while pierside. Some vessel types, however, have minimal or no graywater

collection or holding capability and discharge the graywater directly overboard while in transit.

Graywater is discharged pierside when collection facilities are not available.

Less than half of all graywater discharged within 12 n.m. occurs pierside from vessels

lacking graywater collection holding capability. The remainder of the discharge in coastal waters

occurs during transit within 12 n.m. from shore. Copper, lead, mercury (a bioaccumulative

chemical of concern), nickel, silver, and zinc were detected in concentrations that exceed acute

Federal criteria and State acute water quality criteria. Graywater also contains conventional and

nonconventional pollutants, such as total suspended solids, biochemical oxygen demand,

chemical oxygen demand, oil, grease, ammonia, nitrogen, and phosphates. Due to the large

volume of graywater generated each year, the mass loadings of these constituents may be

significant. The use of containment systems to transfer graywater to shore treatment facilities

demonstrates the availability of controls to mitigate adverse impacts on the environment.

Therefore, EPA and DoD have determined that it is reasonable and practicable to require a

MPCD to control graywater discharges.

5.1.14 Hull Coating Leachate

This discharge consists of constituents that leach, dissolve, ablate, or erode from hull

paints into the surrounding seawater.

Vessel hulls that are continuously exposed to seawater are typically coated with a base

anti-corrosive coating covered by an anti-fouling coating. This coating system prevents

corrosion of the underwater hull structure and, through leaching action releases antifouling

compounds. Ablative coatings allow the paint surface to erode or dissolve to release antifouling

compounds. These compounds inhibit the adhesion of biological growth to the hull surface.

The coatings on most vessels of the Armed Forces are either copper- or tributyl tin

(TBT)-based, with copper-based ablative paints being the most predominant coating system. The

Armed Forces have been phasing out the use of TBT paints, and currently it is found only on

approximately 10-20 percent of small boats and craft with aluminum hulls. Small boats and craft

that spend most of their time out of water typically do not receive an anti-corrosive or antifouling coating.

Hull coating leachate is generated continuously whenever a vessel hull is exposed to

water, within and beyond 12 n.m. from shore. Priority pollutants expected to be present in this

discharge include copper and zinc. TBT is also expected to be present in this discharge for those

vessels with TBT paint. The release rate of the constituents in hull coating leachate varies with

the type of paint used, water temperature, vessel speed, and the age of the coating. Using average
5-16

release rates derived from laboratory tests, the wetted surface area of each vessel, and the number

of days the vessel is located within 12 n.m., EPA and DoD estimated the mass of copper, zinc,

and TBT released in the leachate and concluded that the discharge has the potential to cause an

adverse environmental effect.

Annual releases of TBT are expected to decrease since TBT coatings are being phased out

by DoD and the Coast Guard. Both DoD and the commercial industry have conducted research

on the use of advanced antifouling coatings such as easy release coatings (e.g., silicone) that

resist biofouling when the vessel is in motion and a critical speed is reached. The combination of

phasing out TBT paints, the potential to establish limits on copper release rates for copper-based

coating systems, and the potential for alternative coating systems to reduce copper discharges

demonstrates the availability of controls to mitigate potential environmental impacts from hull

coating leachate. Thus, EPA and DoD determined that it is reasonable and practicable to require

use of a MPCD for hull coating leachate.

5.1.15 Motor Gasoline Compensating Discharge

This intermittent discharge consists of seawater taken into, and discharged from, motor

gasoline tanks. Motor gasoline (MOGAS) is used to operate vehicles and equipment stored or

transported on some Navy amphibious vessels. MOGAS is stored in a compensating fuel tank

system in which seawater is automatically added to fuel tanks as the gasoline is consumed in

order to eliminate free space where vapors could accumulate. The compensating system is used

for MOGAS to provide supply pressure for the gasoline and to keep the tank full to prevent

potentially explosive gasoline vapors from forming. During refueling, gasoline displaces

seawater from the tanks, and the displaced seawater is discharged directly overboard.

The Navy has two classes of vessels with MOGAS storage tanks. Eleven of these vessels

are homeported in the U.S. Based on operational practices, vessels with MOGAS storage tanks

typically refuel once per year, and the refuelings are always conducted in port. Therefore, all

discharges from the MOGAS compensating system occur in port.

Seawater in the MOGAS compensating system is in contact with the gasoline for long

periods of time. MOGAS discharges are expected to contain components of gasoline, including

benzene, ethylbenzene, toluene, phenols, and naphthalenes at concentrations that exceed acute

water quality criteria.

Specific operating procedures are followed when refueling MOGAS tanks to reduce the

potential for discharging gasoline. These procedures require MOGAS tanks to be filled slowly

and prohibit filling the tanks beyond 80 percent of the total tank capacity. Containment is placed

around hose connections to contain any releases of gasoline, and containment booms are placed

in the water around the vessel being refueled. Diffusers are used within the tanks to prevent

entraining fuel into the discharged compensating water. These management practices

demonstrate the availability of controls to mitigate potential adverse impacts to the environment.

Therefore, EPA and DoD have determined that it is reasonable and practicable to require MPCDs

for the MOGAS compensating discharge.
5-17

5.1.16 Non-Oily Machinery Wastewater

This intermittent discharge is composed of water leakage from the operation of

equipment such as distillation plants, water chillers, valve packings, water piping, low- and highpressure air compressors, and propulsion engine jacket coolers. Only wastewater that is not

expected to contain oil is collected in this system. The discharge is captured in a dedicated

system of drip pans, funnels, and deck drains to prevent mixing with oily bilgewater. Non-oily

machinery wastewater from systems and equipment located above the waterline is drained

directly overboard. Non-oily machinery wastewater from systems and equipment below the

waterline is directed to collection tanks prior to overboard discharge. In limited cases, steam

condensate generated when a vessel is in port is directed to the non-oily machinery wastewater

collection tank. See section 5.2.10 for additional information on steam condensate discharges.

Nuclear-powered Navy surface vessels and some conventionally powered vessels have

dedicated non-oily machinery wastewater systems. Most other Armed Forces vessels have no

dedicated non-oily machinery wastewater system, so this type of wastewater drains directly to the

bilge and is part of the bilgewater discharge.

Non-oily machinery wastewater is discharged in port, during transit, and at sea. This

discharge is generated whenever systems or equipment are in use, and varies in volume according

to ship size and the level of machinery use.

Pollutants, including copper, nickel, silver, bis(2-ethylhexyl)phthalate, and zinc were

present in concentrations that exceed acute Federal criteria or State acute water quality criteria.

Nitrogen (in the form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen) and total

phosphorus were present in concentrations exceeding the most stringent State water quality

criteria. Mercury (a bioaccumulative chemical of concern) was also detected, but at

concentrations that did not exceed Federal or State water quality criteria. There was significant

variability in sampling data, and flow rate data were insufficient for reliably estimating mass

loadings for this discharge. System design changes to control the types and numbers of

contributing systems and equipment, and implementation of management practices to reduce the

generation of non-oily machinery wastewater are potential options for reducing the potential

impact of this discharge on the environment. For this rule, EPA and DoD have determined that

it is reasonable and practicable to require MPCDs for non-oily machinery wastewater.

5.1.17 Photographic Laboratory Drains

This intermittent discharge is laboratory wastewater resulting from processing

photographic film. Typical liquid wastes from these activities include spent film processing

chemical developers, fixer-bath solutions and film rinse water.

Navy ship classes such as aircraft carriers, amphibious assault ships, and submarine

tenders have photographic laboratory facilities, including color, black-and-white and x-ray

photographic processors. The Coast Guard has two icebreakers with photographic and x-ray
5-18

processing capabilities. The MSC has two vessels that have photographic processing equipment

onboard, but the equipment normally is not operated in U.S. waters. Army, Air Force, and

Marine Corps vessels do not use photographic equipment aboard their vessels and therefore do

not produce this discharge.

Photographic laboratory wastes may be generated within and beyond 12 n.m. from shore,

although current practice is to collect and hold the waste onboard within 12 n.m. The volume

and frequency of the waste generation varies with a vessel’s photographic processing capabilities,

equipment, and operational objectives.

Expected constituents in photographic laboratory wastes include acetic acid, aluminum

sulfate, ammonia, boric acid, ethylene glycol, sulfuric acid, sodium acetate, sodium chloride,

ammonium bromide, aluminum sulfate, and silver. Concentrations of silver can exceed acute

Federal criteria and State acute water quality criteria; however, the existing data are insufficient

to determine whether drainage from shipboard photographic laboratories has the potential to

cause adverse environmental effects.

The Navy has adopted guidance to control photographic laboratory drains, including

containerizing for onshore disposal all photographic processing wastes generated within 12 n.m.,

and is transitioning to digital photographic systems. The current handling practices and the

availability of digital photographic systems demonstrates that MPCDs are available to mitigate

potential adverse effects, if any, from photographic laboratory drains. Therefore, EPA and DoD

have determined that it is reasonable and practicable to require use of a MPCD for this discharge.

5.1.18 Seawater Cooling Overboard Discharge

This discharge consists of seawater from a dedicated system that provides noncontact

cooling water for other vessel systems. The seawater cooling system continuously provides

cooling water to heat exchangers, removing heat from main propulsion machinery, electrical

generating plants, and other auxiliary equipment. The heated seawater is discharged directly

overboard. With the exception of some small, non-self-propelled vessels and service craft, all

Armed Forces vessels discharge seawater from cooling systems. Typically, the demand for

seawater cooling is continuous and occurs both within and beyond 12 n.m. from shore.

Seawater cooling overboard discharge contains trace materials from seawater cooling

system pipes, valves, seachests, pumps, and heat exchangers. Pollutants detected in seawater

cooling overboard discharge include copper, zinc, nickel, arsenic, chromium, lead, and nitrogen

(in the form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen). Copper, nickel, and

silver were detected in concentrations exceeding both the chronic Federal criteria and State

chronic water quality criteria. Nitrogen was detected in concentrations exceeding State chronic

water quality criteria. These concentrations contribute to a significant total mass released by this

discharge due to the large volume of cooling water. In addition, thermal effects modeling

indicates that some vessels may exceed State thermal mixing zone requirements. The seawater

cooling water system has a low potential for transporting nonindigenous species, because the

residence time for most portions of the system are short. However, a strainer plate is used to
5-19

minimize the inflow of larger biota during system operation. The strainer plate is periodically

cleaned using low pressure air or steam to dislodge any accumulated material. This procedure

may result in releasing biota that have attached to the plate.

A potential MPCD option for achieving pollutant reductions is the use of alternative

piping systems (i.e., different metallurgy) that provide lower rates of pipe wall corrosion and

erosion. The potential substitution of materials demonstrates the availability of controls to

mitigate potential adverse impacts on the environment. Based on this information, EPA and

DoD have determined that it is reasonable and practicable to require use of a MPCD for this

discharge.

5.1.19 Seawater Piping Biofouling Prevention

This discharge consists of the additives used to prevent the growth and attachment of

biofouling organisms in seawater cooling systems on selected vessels, as well as the reaction

byproducts resulting from the use of these additives. Fouling reduces seawater flow and heat

transfer efficiency. Aboard some vessels, active biofouling control systems are used to control

biological fouling of surfaces within the seawater cooling systems. Generally, these active

biofouling control systems are used when the cooling system piping does not have inherent

antifouling properties (e.g., titanium piping). The most common seawater piping biofouling

prevention systems include chlorination, chemical dosing, and anodic biofouling control systems.

All three systems act to prevent fouling organisms from adhering to and growing on interior

piping and components. Chlorinators use electric current to generate chlorine and chlorineproduced oxidants from seawater. Anodic biofouling control systems use electric current to

accelerate the dissolving of an anode to release metal ions into the piping system. Chemical

dosing uses an alcohol-based chemical dispersant that is intermittently injected into the seawater

system.

Twenty-nine Armed Forces vessels use active seawater piping biofouling control systems.

Nine vessels use onboard chlorinators, 19 vessels use anodic biofouling control systems, and one

vessel employs chemical dosing. Chlorinators operate on a preset schedule of intermittent

operation, a few hours daily. Chemical dispersant dosing is performed for one hour every three

days. Anodic systems normally operate continuously.

Seawater discharged from systems with active biofouling control systems is likely to

contain residuals from the fouling control agent (chlorine, alcohol-based chemical additives, or

copper), in addition to constituents normally found in cooling water. Based on modeling of the

discharge plume, EPA and DoD estimate that receiving water concentrations of residual chlorine

could exceed chronic Federal criteria and State chronic water quality criteria. Because of the

large volume of seawater discharged from these systems, the resulting mass loading of chlorine

released to the environment is considered significant.

Existing operational controls that limit the residual chlorine discharged to the

environment demonstrate the availability of a MPCD to mitigate the potential for adverse
5-20

impacts from this discharge. EPA and DoD have determined that it is reasonable and practicable

to require a MPCD for seawater piping biofouling prevention systems.

5.1.20 Small Boat Engine Wet Exhaust

This discharge is the seawater that is mixed and discharged with small boat propulsion

engine exhaust gases to cool the exhaust and quiet the engine. Small boats are powered by either

inboard or outboard engines. Seawater is injected into the exhaust of these engines for cooling

and to quiet engine operation. Constituents from the engine exhaust are transferred to the

injected seawater and discharged overboard as wet exhaust.

Most small boats with engines generate this discharge. The majority of inboard engines

used on small boats are two-stroke engines that use diesel fuel. The majority of outboard engines

are two-stroke engines that use a gasoline-oil mixture for fuel. This discharge is generated when

operating small boats. Due to their limited range and mission, small boats spend the majority of

their operating time within 12 n.m. from shore.

Wet exhaust from outboard engines contains several constituents that can exceed acute

Federal criteria or State acute water quality criteria including benzene, toluene, ethylbenzene, and

naphthalene. Wet exhaust from inboard engines can contain benzene, ethylbenzene, and total

polycyclic aromatic hydrocarbons (PAHs) that can exceed State water quality criteria. Mass

loadings of these wet exhaust constituents are considered large. Potential MPCD options include

replacing existing outboard engines with new reduced-emission outboard engines, and ensuring

all new boats and craft have inboard engines with dry exhaust systems. Therefore, EPA and DoD

have determined that it is reasonable and practicable to require use of a MPCD for small boat

engine wet exhaust.

5.1.21 Sonar Dome Discharge

This discharge is generated by the leaching of antifoulant materials from the sonar dome

material into the surrounding seawater and the discharge of seawater or freshwater from within

the sonar dome during maintenance activities. Hull-mounted sonar domes house the electronic

equipment used to navigate, detect, and determine the range to objects. Sonar domes are

composed of either rubber impregnated with tributyltin (TBT) anti-foulant, rubber without TBT,

steel, or glass-reinforced plastic, and are filled with freshwater and/or seawater to maintain their

shape and internal pressure. The discharge is generated when materials leach from the exterior

surface of the dome, or when water containing leach materials from inside the dome is pumped

overboard to allow for periodic maintenance or repairs on the sonar dome or equipment housed

inside the dome.

Only Navy and MSC operate vessels with sonar domes. Sonar domes are currently

installed on approximately 225 vessels, including eight classes of Navy vessels and one class of

MSC vessels. Sonar domes on MSC vessels are fiberglass and do not contain TBT.
5-21

The leaching of materials from the exterior surface of the dome is a continuous discharge

and occurs both within and beyond 12 n.m. from shore. Discharges from the interior of the dome

are intermittent and occur while the vessel is pierside as water inside the dome is removed to

allow for periodic maintenance or repairs (approximately twice per year per dome).

Expected constituents of sonar dome water discharge are TBT, dibutyl tin, monobutyl tin,

and metals such as copper, nickel, zinc, and tin. Based on sampling data in the record,

concentrations of TBT, copper, nickel, and zinc can exceed acute Federal criteria or State acute

water quality criteria, although fleetwide mass loadings of these constituents are not considered

large (15 pounds/year of TBT, 23 pounds/year of copper, 11 pounds/year of nickel, and 122

pounds/year of zinc). Nevertheless, the Navy has instituted a program to install new sonar domes

that do not have TBT-impregnated internal surfaces as existing domes require replacement. This

practice demonstrates the availability of a control to mitigate potential adverse environmental

impacts, if any, from sonar dome discharges. Therefore EPA and DoD have determined that it is

reasonable and practicable to require a MPCD for sonar dome discharges.

5.1.22 Submarine Bilgewater

The submarine bilgewater discharge contains a mixture of wastewater and leakage from a

variety of sources that are allowed to drain to the lowest inner part of the hull, known as the

bilge. These sources can include condensed steam from steam systems, spillage from drinking

fountains, valve and piping leaks, and evaporator dumps (i.e., evaporator water that fails to meet

specifications for use). From the various collection points in the bilge, this bilgewater is

transferred via an auxiliary drain system to a series of holding tanks. Most submarines have the

capability to segregate oily wastewater from non-oily wastewater. The non-oily waste is

discharged directly overboard and the oily wastewater is collected in a tank that allows gravity

separation of the oil and water. The separated water phase is then discharged overboard, as

needed, and the oil phase held onboard until it can be transferred to shore facilities for disposal.

This discharge is generated by all submarines, all of which are operated by the Navy.

Approximately 60 of the submarines (the SSN 688 class) discharge the separated water phase

from the bilgewater collection tanks within and beyond 12 n.m. from shore. The remaining

submarines generally hold all bilgewater onboard until they are beyond 50 n.m. from shore. The

frequency and volume of the discharge is highly variable, depending upon crew size, operating

depth, and equipment conditions.

Sampling conducted onboard submarines showed concentrations of cadmium, chlorine,

copper, cyanide, heptachlor, heptachlor epoxide, mercury (a bioaccumulative chemical of

concern), nickel, oil, phenol, silver, and zinc that exceeded acute Federal criteria or State acute

water quality criteria. Submarines use gravity separation to reduce the concentration of oil in

bilgewater prior to discharge; however, this method apparently does not consistently produce a

discharge that meets water quality criteria. The adequacy of existing gravity separation treatment

to provide effective environmental protection will be addressed by the Phase II rulemaking. The

nature of this discharge is such that submarine bilgewater, if untreated, could potentially impact

the environment. Because of this potential to cause adverse environmental impacts, coupled with
5-22

the demonstration that pollution controls are available to reduce the oil content of the discharge,

EPA and DoD have determined that it is reasonable and practicable to require the use of a MPCD

for submarine bilgewater.

5.1.23 Surface Vessel Bilgewater/OWS Discharge

The Surface Vessel Bilgewater/OWS Discharge consists of a mixture of wastewater and

leakage from a variety of sources that are allowed to drain to the lowest inner part of the hull,

known as the bilge. The sources of surface vessel bilgewater are generally similar to those

discussed above for submarines. An additional source of bilgewater for surface vessels is water

from the continual blowdown of boilers (i.e., boiler blowdown). On surface vessels, bilgewater

is usually transferred to an oily waste holding tank, where it is stored for shore disposal or treated

in an oil-water separator (OWS) to remove oil before being discharged overboard. Some vessels

also have an oil content monitor (OCM) installed downstream from the OWS to monitor

bilgewater oil content prior to discharge. Vessels with OCMs have the capability to return

bilgewater not meeting a preset oil concentration limit to the OWS for reprocessing until the

limit is met. Oil collected from the OWS separation process is held in a waste oil tank until

transferred to shore facilities for disposal.

All vessels of the Armed Forces produce bilgewater and most of the larger vessels have

OWS systems. Small craft bilgewater is collected and transferred to shore facilities while

pierside.

Bilgewater accumulates continuously; however, vessels of the Armed Forces do not

discharge untreated bilgewater. Under current policy, bilgewater treated by an OWS can be

discharged as needed within 12 n.m., while untreated bilgewater is held for transfer to a shore

facility for treatment. For vessels with an OWS and OCM, oil concentrations in the treated

bilgewater must be less than 15 ppm prior to overboard discharge.

Sampling data for OWS effluent show oil, copper, iron, mercury (a bioaccumulative

chemical of concern), nickel, and zinc exceed acute Federal criteria or State acute water quality

criteria. Sampling data also show concentrations of nitrogen (in the form of ammonia, nitrates

and nitrites, and total Kjeldahl nitrogen) and phosphorus exceed the most stringent State water

quality criteria. The estimated mass loading for oil is considered to be large.

The existing policies prohibiting the discharge of untreated bilgewater, and the extensive

use of oil-water separators and oil content monitors demonstrate the availability of pollution

controls for bilgewater. The data in the record indicate that untreated bilgewater would likely

cause adverse environmental impacts. Therefore, EPA and DoD have determined that it is

reasonable and practicable to require the use of a MPCD for this discharge.

5.1.24 Underwater Ship Husbandry

The underwater ship husbandry discharge is composed of materials discharged during the

inspection, maintenance, cleaning, and repair of hulls and hull appendages performed while the
5-23

vessel is waterborne. Underwater ship husbandry includes activities such as hull cleaning,

fiberglass repair, welding, sonar dome repair, propulsor lay-up, non-destructive testing, masker

belt repairs, and painting operations.

Underwater ship husbandry discharge is created occasionally by all Navy surface ships

and submarines, and some Coast Guard vessels. These ship husbandry operations are normally

conducted pierside. With the exception of underwater hull cleaning and propulsor (i.e.,

propeller) lay-up, other ship husbandry discharges have a low potential for causing an adverse

environmental effect. Underwater hull cleaning is conducted by divers using a mechanical brush

system. Copper and zinc are released during cleaning in concentrations that exceed acute Federal

criteria and State acute water quality criteria and produce a significant mass loading of

constituents. The copper and zinc in this discharge originate from the anti-fouling and

anticorrosive hull coatings applied to vessels. Data from commercial vessels indicate that

underwater hull cleaning also has the potential to transfer nonindigenous aquatic species.

Propulsor lay-up requires the placement of a vinyl cover over the propulsor to reduce fouling of

the propulsor when the vessel is in port for extended periods. Chlorine-produced oxidants are

generated from impressed current cathodic protection systems and can build up within the cover

to levels exceeding State water quality criteria. However, discharges from this operation, as well

as other ship husbandry operations (excluding hull cleaning) are infrequent and small in terms of

volume or mass loading.

The Navy has established policies to minimize the number of hull cleanings, based on the

degree to which biological fouling has occurred. In addition, the Navy has established

procedures to use the least abrasive cleaning equipment necessary as a means for reducing the

mass of copper and zinc in the discharge. These practices represent available controls to mitigate

adverse impacts from underwater ship husbandry operations, and EPA and DoD have determined

that it is reasonable and practicable to require the use of a MPCD to control this discharge.

5.1.25 Welldeck Discharges

This discharge is the water that accumulates from the seawater flooding of the docking

well (welldeck) of a vessel used to transport, load, and unload amphibious vessels, and from the

maintenance and freshwater washings of the welldeck and equipment and vessels stored in the

welldeck.

Amphibious operations by the Armed Forces require transport of vehicles, equipment,

and personnel between ship and shore on landing craft. The landing craft are stored in a docking

well, or welldeck, of some classes of amphibious warfare ships. To load or unload landing craft,

amphibious warfare ships may need to flood the welldeck by taking on ballast water and sinking

the aft (rear) end of the ship. Water that washes out of the welldeck contains residual materials

that were on the welldeck prior to flooding. Other welldeck discharges are created by routine

operations such as washing equipment and vehicles with potable water, washing the gas turbine

engines of air-cushion landing craft (LCACs) in the welldeck with mild detergents, and

graywater from stored utility landing craft (LCUs). Additionally, the U.S. Department of

Agriculture (USDA) requires washing welldecks, vehicle storage areas, and equipment upon
5-24

return from overseas locations. The washing is required to ensure that there is no inadvertent

transport of nonindigenous species to land. USDA-required washes of welldecks and vehicle

storage areas occur pierside, while vehicles and equipment are washed onshore in a USDAdesignated area. Effluent from such shipboard activities drain to unflooded welldecks and are

discharged directly overboard.

The Navy is the only branch of the Armed Forces with ships having welldecks. Thirtythree amphibious warfare ships produce this discharge, which is released both within and beyond

12 n.m. from shore.

Depending upon the specific activities conducted, welldeck discharges contain a variety

of residual constituents, including oil and grease, ethylene glycol (antifreeze), chlorine,

detergents/cleaners, metals, solvents, and sea-salt residues. The volume of welldeck washout

varies depending upon the type of landing craft to be loaded or unloaded. The greatest volume of

welldeck discharge occurs when LCUs are being loaded into, or unloaded from the welldeck.

Loading and unloading of LCACs does not require the welldeck to be flooded. Instead, a small

“surge” of water enters the ship during these operations. Constituent concentrations in welldeck

washout are expected to be low due to dilution in the large volume of water discharged, and

because of general housekeeping procedures that require containment and cleanup of materials

spilled on the welldeck.

Other discharges from the welldeck include vehicle and craft washwater, gas turbine

engine washes, and USDA washes. Constituents of these discharges are expected to be identical

to those in welldeck washout. Of the various welldeck discharges, gas turbine water washes and

USDA washes may result in hydrocarbon, or metal concentrations that exceed acute water quality

criteria. In addition, there is a potential for nonindigenous species to be introduced from USDArequired welldeck washes, although it should be noted that the viability of any species introduced

is questionable since they generally would have been exposed to air for extended periods of time

prior to their introduction into U.S. coastal waters (i.e., for the most part, these species would

have been removed from vehicles and deck surfaces and thus it would not be a water-to-water

transfer, in contrast to species transfers from ballast water systems).

Existing practices for containment and cleanup of welldeck spills demonstrate the

availability of controls to reduce contamination of welldeck discharges and the potential for

causing adverse environmental impacts (e.g., oil sheens). EPA and DoD have determined that it

is reasonable and practicable to require a MPCD for welldeck discharges.
5-25

5.2 Discharges Determined To Not Require MPCDs

For the reasons discussed below, EPA and DoD have determined that it is not reasonable

and practicable to require the use of a MPCD to control 14 discharges incidental to the normal

operation of Armed Forces vessels. These discharges have a low potential to adversely affect the

environment by introduction of chemical constituents, thermal pollution, bioaccumulative

chemicals of concern, or nonindigenous species.

As discussed below, in some cases, the concentration of one or more constituents in the

undiluted discharge exceed water quality criteria at the point of discharge. However, such

discharges occur in low volumes or infrequently. In all of these instances, either the pollutant

concentration in the discharge plume quickly falls below water quality criteria once the dilution

effect of mixing zones is taken into account, or the low mass loading of the discharge is unlikely

to adversely affect the environment.

These 14 discharge types do not require control, and no control standards will be set for

them, in Phase II of UNDS development. Upon promulgation of this Phase I rule, States and

their political subdivisions are prohibited from adopting or enforcing any statute or regulation to

control these discharges, except by establishing no-discharge zones. States can petition EPA and

DoD to review the determination not to require MPCDs for these discharges.

The discussion below provides a brief description of the discharges and the systems that

produce the discharge and highlights the most significant constituents released to the

environment and other characteristics of the discharge. A more detailed discussion of these

discharges is presented in Appendix A.

5.2.1 Boiler Blowdown

This discharge is the water and steam discharged during the blowdown of a boiler or

steam generator, or when a safety valve is tested. Boilers are used to produce steam for

propulsion and a variety of auxiliary and hotel services. Water supplied to the boiler system

(feedwater) is treated with chemicals to inhibit corrosion and the formation of scale in the boiler

and boiler system piping. Periodically, water must be removed from the boiler to control the

buildup of particulates, sludge, and treatment chemical concentrations. The term “blowdown”

refers to the minimum discharge of boiler water required to prevent the buildup of these materials

in the boiler to levels that would adversely affect boiler operation and maintenance. There are

four types of boiler blowdown procedures employed on Armed Forces vessels: 1) surface

blowdowns for removing materials dissolved in the boiler water and for controlling boiler water

chemistry; 2) scum blowdowns for removing surface scum; 3) bottom blowdowns for removing

sludge that settles at the bottom of boilers; and 4) continuous blowdowns for removing dissolved

metal chelates and other suspended matter. The type of blowdown used is a function of the

boiler water chemistry and thus varies among vessel classes. With the exception of continuous

blowdowns, boiler blowdowns are discharged below the vessel waterline. Continuous

blowdowns are discharged inside the vessel and are directed to the bilge. These are addressed as

part of the surface vessel bilgewater/OWS discharge (see section 5.1.23). Another discharge
5-26

occurs during periodic testing of steam generator safety valves on nuclear-powered vessels. The

safety valve discharge is a short-duration release of steam below the vessel waterline.

Approximately 360 surface vessels and submarines discharge boiler blowdowns directly

to receiving waters. These blowdowns occur both within and beyond 12 n.m. from shore.

Nuclear-powered ships perform steam generator safety valve testing only in port once every five

years.

Boiler blowdown is discharged intermittently in small volumes (approximately 300

gallons per discharge), at high velocities (over 400 feet/second), and at elevated temperatures

(over 325 degrees Fahrenheit). Boiler water treatment chemicals used by Armed Forces vessels

include ethylenediamine-tetraacetic acid (EDTA), hydrazine, sodium hydroxide, and disodium

phosphate. Sampling data for boiler blowdowns indicate the presence of nitrogen (in the form of

ammonia, nitrates and nitrites, and total Kjeldahl nitrogen), phosphorus, hydrazine, iron, bis(2-

ethylhexyl)phthalate, copper, lead, nickel, and zinc. Boiler blowdown discharges from

conventionally powered boilers can exceed Federal criteria or State water quality criteria for

copper, iron, lead, nickel, zinc, bis(2-ethylhexyl)phthalate, nitrogen (in the form of ammonia,

nitrates and nitrites, and total Kjeldahl nitrogen) and phosphorus. Blowdown discharges from

nuclear-powered steam generators exceed acute Federal criteria and State acute water quality

criteria for copper, and the most stringent State acute water quality criteria for lead and nickel.

For nitrogen (in the form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen) and

phosphorus, the most stringent State water quality criteria was exceeded. However, the turbulent

mixing resulting from the high velocity discharge, and the relatively small volume of the boiler

blowdown causes pollutant concentrations to rapidly dissipate to background levels or below

acute Federal criteria and State acute water quality criteria within a short distance from the point

of discharge.

Based on thermal modeling of the discharge plume, boiler blowdowns are not expected to

exceed State standards for thermal effects. Thermal effects from safety valve testing are

substantially less than those from blowdowns, thus safety valve testing also will not exceed State

standards for thermal effects.

While the pollutant concentrations in the boiler blowdown discharges exceed acute

Federal criteria and State acute water quality criteria, they are discharged intermittently and in

small volumes. Further, these discharges are distributed throughout the U.S. at Armed Forces

ports, and each individual port receives only a fraction of the total fleetwide mass loading. Based

on the information in the record regarding the low mass of pollutants discharged during boiler

blowdowns and safety valve discharges, and the manner in which the discharges take place, there

is a low potential for causing adverse environmental impacts. Therefore, EPA and DoD have

concluded that it is not reasonable and practicable to require the use of a MPCD to mitigate

adverse impacts on the marine environment for this discharge.
5-27

5.2.2 Catapult Wet Accumulator Discharge

This discharge is the water discharged from a catapult wet accumulator, which stores a

steam/water mixture for launching aircraft from an aircraft carrier.

The steam used as the motive force for operating the catapults for launching aircraft is

provided to the catapult from a steam reservoir, referred to as the catapult wet accumulator. The

catapult wet accumulator is a pressure vessel containing a steam/water mixture at a high

temperature and pressure. The accumulator is fed an initial charge of boiler feedwater and

provided steam from boilers. As steam is released from the accumulator for the catapult launch,

the pressure reduction in the accumulator allows some of the water to flash to steam, providing

additional steam to operate the catapult. During operation of the system, steam condenses in the

accumulator and causes the water level in the accumulator to gradually rise. Periodic blowdowns

of the accumulator are required to maintain the water level within operating limits. This

steam/water mixture released during the blowdown is discharged below the vessel waterline. In

addition to blowdowns required during catapult operation and testing, wet accumulators are

emptied prior to major maintenance of the accumulator or when a carrier will be in port for more

than 72 hours. When emptying the accumulator, multiple blowdowns are performed over an

extended period (up to 12 hours) to reduce pressure prior to draining the tank.

The Navy is the only branch of the Armed Forces with vessels generating this discharge.

Eleven of the aircraft carriers are homeported in the United States.

Wet accumulator blowdowns are performed during flight operations, which occur beyond

12 n.m., and during catapult testing, which occurs within 12 n.m. from shore. Wet accumulators

are emptied outside 12 n.m. when returning to port for accumulator maintenance or when the

carrier will be in port for more than 72 hours. If catapult testing is conducted in port, and the

carrier will remain in port for more than 72 hours following the testing, the accumulator will be

emptied in port.

Catapult wet accumulator blowdowns have little potential for causing adverse

environmental impacts because of the low pollutant loadings and thermal effects of this

discharge. Because boiler feedwater is used for the initial charge of water to an empty

accumulator, the constituents of the discharge include water treatment chemicals present in boiler

feedwater. These chemicals include EDTA, disodium phosphate, and hydrazine. During normal

operation, the boiler feedwater chemicals are diluted by the supplied steam. Additional

constituents present in the blowdowns originate from the steam provided to the accumulator.

Based on sampling data for steam condensate (a similar discharge discussed below in section

5.2.10) and the volume of wet accumulator blowdowns performed within 12 n.m., the combined

mass loading for all metals is estimated at less than 0.01 pounds/year. Constituents found in

steam condensate include benzidine, bis(2-ethylhexyl)phthalate, copper, nickel, nitrogen (in the

form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen), and phosphorus. The

concentrations of benzidine, copper, and nickel in steam condensate were found to exceed acute

Federal criteria and State acute water quality criteria. The concentration of bis(2-

ethylhexyl)phthalate was found to exceed State acute water quality criteria. The concentrations
5-28

of nitrogen and phosphorus were found to exceed the most stringent State water quality criteria.

However, using steam condensate data may overestimate wet accumulator pollutant

concentrations because of the shorter contact time between catapult steam and its associated

piping system (resulting in less opportunity to entrain corrosion products from the piping).

Based on thermal modeling of the discharge plume, catapult wet accumulator blowdowns are not

expected to exceed State standards for thermal effects.

Catapult wet accumulator blowdowns have little potential for causing adverse

environmental impacts because of the very low pollutant mass loadings in this discharge and

because of the low thermal effects from this discharge. Therefore, EPA and DoD determined

that it is not reasonable and practicable to require the use of a MPCD to mitigate adverse impacts

on the marine environment for this discharge.

5.2.3 Cathodic Protection

This discharge consists of the constituents released into the surrounding water from

sacrificial anodes or impressed current cathodic protection systems used to prevent hull

corrosion.

Steel-hulled vessels require corrosion protection. In addition to anti-corrosion hull paints,

these vessels employ cathodic protection which is provided by either sacrificial anodes or

Impressed Current Cathodic Protection (ICCP) systems. The most common cathodic protection

system for vessels of the Armed Forces is the zinc sacrificial anode, although a few submarines

use aluminum anodes. With the sacrificial anode system, zinc or aluminum anodes attached to

the hull will preferentially corrode from exposure to the seawater and thereby minimize corrosion

of the vessel’s hull.

In ICCP systems, the vessel’s electrical system passes a current through inert platinumcoated anodes. This current protects the hull in a manner similar to sacrificial anodes by

generating current as the anodes corrode. Depending on the type of cathodic protection used, the

discharge will include either zinc or aluminum from sacrificial anodes, or chlorine-produced

oxidants (CPO) from ICCP systems. Zinc anodes are approximately 99.3% zinc and contain

small amounts of zinc, silicon, and indium (for activation). Aluminum anodes can contain

0.001% mercury as an impurity; mercury is a known bioaccumulator.

Approximately 2,170 large Armed Forces vessels use cathodic protection. Of these,

nearly 270 have ICCP systems, fewer than five use aluminum sacrificial anodes, and the

remaining use zinc sacrificial anodes. The discharge is continuous while the vessel is waterborne

and occurs both within and beyond 12 n.m. from shore.

EPA and DoD modeled the discharge from cathodic protection systems to determine the

range of constituent concentrations that could be expected in the water surrounding a vessel.

This discharge is best described as a mass flux of reaction byproducts emanating from the

electro-chemical reaction that occurs at the anodes. Two separate modeling techniques were

used for both sacrificial anodes and ICCP systems. The first technique was a dilution model for
5-29

harbors that takes into account the number of homeported vessels and harbor-specific volume

and tidal flow information. Three Navy ports were modeled, representing a range of port sizes.

The resulting constituent concentrations calculated for the three ports in this dilution model were

below chronic Federal criteria and State chronic water quality criteria.

The second technique modeled mixing zones around a vessel using calculations for a hull

size typical of vessels using cathodic protection systems. The mixing model results indicate that

a mixing zone of five feet for CPO and 0.5 feet for zinc results in concentrations below the

chronic Federal criteria or State chronic water quality criteria. For vessels with aluminum

anodes, a mixing zone of less than 0.1 feet achieves concentrations below chronic Federal criteria

and State chronic water quality criteria. Concentrations of mercury will be 1,000 times lower

than the acute State water quality criteria and 35 times lower than the chronic criteria. The total

amount of mercury discharged from aluminum anodes on all Armed Forces vessels is estimated

to be less than 0.001 pounds annually.

For ICCP calculations, the modeling is based on an assumption that 100 percent of the

supplied electrical current results in CPO generation. Less CPO is actually expected to be

generated because the efficiency of the chlorine generation process is known to be less than 100

percent. In addition, using the generation rate alone does not account for the rapid decay of CPO

in water through chemical reactions involving CPO, which occur within minutes.

The dilution and mixing zone modeling performed for this discharge indicates that

cathodic protection has a low potential for causing adverse impacts on the marine environment.

Therefore, EPA and DoD determined that it is not reasonable and practicable to require the use of

a MPCD to mitigate adverse impacts on the marine environment for this discharge.

5.2.4 Freshwater Lay-Up

This discharge is the potable water that is periodically discharged from the seawater

cooling system while the vessel is in port, and the cooling system is in a lay-up mode.

Seawater cooling systems are used onboard some Armed Forces vessels to remove heat

from main propulsion machinery, electrical generating plants and other auxiliary equipment.

These are single-pass, non-contact cooling systems whereby the seawater enters the hull, is

pumped through a piping network and circulated through one or more heat exchangers, then exits

the vessel. On certain vessels, the seawater cooling systems are placed in a stand-by mode, or

lay-up, when the machinery is not in use. The lay-up is accomplished by blowing the seawater

from the condenser with low-pressure air. The condenser is then filled with potable water and

drained again to remove residual seawater as protection against corrosion. Then, the condenser is

refilled with potable water for the actual lay-up. After 21 days, the lay-up water is discharged

overboard and the condenser refilled. The condenser is discharged and refilled on a 30-day cycle

thereafter. The volume of each condenser batch discharge is approximately 6,000 gallons.

The Navy is the only branch of the Armed Forces with vessels discharging freshwater layup. All submarines generate this discharge, which only occurs while in port. Eight aircraft
5-30

carriers also lay-up their condensers; however, these condensers are drained to the bilge and the

water is handled as bilgewater. Generally, the cooling system is only placed in a lay-up condition

if the vessel remains in port for more than three days and the main steam plant is shut down.

Sampling data for submarine freshwater lay-up indicate the presence of chlorine, nitrogen

(in the form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen), and the priority

pollutants chromium, copper, lead, nickel, and zinc. The concentrations of chlorine, copper,

nickel, and zinc can exceed acute Federal criteria or State acute water quality criteria. For

nitrogen and phosphorus, the most stringent State water quality criteria was exceeded. Chlorine

was detected in the initial flush discharge, but was not found in the extended lay-up discharge.

Mass loadings for the priority pollutants (copper, nickel, and zinc) were estimated using total

annual discharge volumes and average pollutant concentrations. The total mass loading from all

discharges of freshwater lay-up from submarines is estimated at 7 pounds/year of copper, 36

pounds/year of nickel, 29 pounds/year of zinc, 55 pounds/year of nitrogen, 0.58 pounds of total

chlorine, 8.3 pounds/year total phosphorus. The mass discharge from any individual freshwater

lay-up discharge event would be a fraction of that total. Because of the low total annual mass

loading, the low frequency at which the discharge occurs, and the volume of an individual

discharge event, discharges of freshwater lay-up have a low potential for causing adverse

environmental impacts. Therefore, EPA and DoD determined that it is not reasonable and

practicable to require the use of a MPCD to mitigate adverse impacts on the marine environment

for this discharge.

5.2.5 Mine Countermeasures Equipment Lubrication

This discharge consists of the constituents released into the surrounding seawater by

erosion or dissolution from lubricated mine countermeasures equipment when the equipment is

deployed or towed. Various types of mine countermeasures equipment are deployed and towed

behind vessels to locate and destroy mines. Lubricating grease and oil applied to this equipment

can be released into surrounding seawater during its deployment and use, including during

training exercises.

The Navy is the only branch of the Armed Forces with a mine countermeasures mission.

The Navy uses two classes of vessels, totaling 23 ships, to locate, classify, and destroy mines.

The discharge is generated during training exercises, which are normally conducted between 5

and 12 n.m. from shore. Depending on the class of vessel and the type of mine countermeasures

equipment being used, the number of training exercises conducted by each vessel ranges from 6

to 240 per year.

Using estimates of the amount of lubricant released during each training exercise, EPA

and DoD calculated the annual mass loading of lubricant discharges to be approximately 770

pounds of grease and oil. Using the estimates of the pollutant mass loading released during an

exercise, and the volume of water through which the countermeasures equipment is towed or

operated during an exercise, EPA and DoD estimated the oil and grease concentrations resulting

from mine countermeasures training exercises. These estimated concentrations of oil and grease

in the receiving water range from 0.688 to 7.3 μg/l and do not exceed acute water quality criteria.
5-31

An additional calculation was performed for the lift cable for the SLQ-48 mine

neutralization vehicle (MNV). This lift cable is lubricated with grease; however, the cable is not

towed through the water and is only used to deploy or recover the MNV while a vessel is

stationary. Using the maximum predicted release of 0.15 ounces of grease per deployment,

modeling results indicate that the grease released from the lift cable would disperse in the

surrounding receiving waters and be at concentrations below the most stringent State acute water

quality criteria within 3 to 5 feet from the cable.

Most discharges from mine countermeasures equipment occur while vessels are underway

and the pollutants are quickly dispersed in the environment due to the turbulent mixing

conditions caused by the wake of the vessel and towed equipment. Further, these discharges take

place beyond 5 n.m. from shore in waters with significant wave energy, allowing for rapid and

wide dispersion of the releases. The manner in which these releases occur, coupled with the

relatively small amounts of lubricants released, results in this discharge having a low potential

for causing adverse impacts on the marine environment. Therefore, EPA and DoD determined

that it is not reasonable and practicable to require the use of a MPCD to mitigate adverse impacts

on the marine environment for the mine countermeasures equipment lubrication discharge.

5.2.6 Portable Damage Control Drain Pump Discharge

This discharge consists of seawater pumped through the portable damage control drain

pump and discharged overboard during periodic testing, maintenance, and training activities.

Portable damage control (DC) drain pumps are used to remove water from vessel

compartments during emergencies or to provide seawater for shipboard firefighting in the event

water is unavailable from the firemain system. The types of pumps used are described in section

5.2.7, Portable Damage Control Drain Pump Wet Exhaust. Discharges from drain pumps being

used during onboard emergencies are not incidental to normal vessel operations, and therefore

are not within the scope of this rule. These pumps are, however, periodically operated during

maintenance, testing, and training, and pump discharges during these activities are within the

scope of this rule. To demonstrate that the pumps are functioning properly, the suction hose is

hung over the side of the vessel and the pump operated to verify that the pump effectively

transfers the seawater or harbor water. This pump effluent is discharged directly overboard

during this testing.

All large ships and selected boats and craft of the Armed Forces generate this discharge.

As part of equipment maintenance, testing, and training, the pumps are operated both within and

beyond 12 n.m. from shore. Navy, Army, and MSC vessels operate portable DC drain pumps for

approximately 10 minutes per month and an additional 15 minutes/year to demonstrate working

order and condition. Coast Guard vessels operate their portable DC drain pumps for

approximately 30 minutes/month for maintenance and testing.

This discharge consists of seawater/harbor water that only briefly passes through a

pumping process. The drain pump discharge is unlikely to cause adverse impacts because the
5-32

water has a residence time of less than five seconds in the pump and associated suction and

discharge hoses, and no measurable constituents are expected to be added to the seawater/harbor

water. Therefore, EPA and DoD determined it is not reasonable and practicable to require the

use of a MPCD to mitigate adverse impacts on the marine environment for this discharge.

5.2.7 Portable Damage Control Drain Pump Wet Exhaust

This periodic discharge is seawater that has mixed and been discharged with portable

damage control drain pump exhaust gases to cool the exhaust and quiet the engine.

Portable, engine-driven pumps provide seawater for shipboard firefighting in the event

water is unavailable from the firemain. Two models of these portable damage control (DC) drain

pumps are used: P-250 and P-100. The P-250 pumps operate on gasoline, injected with oil-based

lubricants. Part of the seawater output from these pumps is used to cool the engine and quiet the

exhaust. This discharge, termed wet exhaust, is typically routed overboard through a separate

exhaust hose and does not include the main discharge of the pump which is classified separately

as Portable Damage Control Drain Pump Discharge and discussed in section 5.2.6.

Fuel residuals, lubricants, or their combustion byproducts are present in P-250 engine

exhaust gases, condense in the cooling water stream, and are discharged as wet exhaust. The P100 model operates on diesel fuel. Although the engine that drives the P-100 pump is air-cooled

and no water is injected into the exhaust of the pump, a small amount of water contacts the

engine during pump priming. Up to one-seventh of a gallon of water may be discharged during

each priming event. This water discharged during P-100 priming is considered part of the

portable DC drain pump wet exhaust.

The Navy operates approximately 910 drain pumps, the MSC approximately 140 drain

pumps, and the Coast Guard approximately 370 drain pumps.

Portable DC drain pump wet exhaust discharges occur during training and monthly

planned maintenance activities both within and beyond 12 n.m. from shore. During monthly

maintenance activities, the pumps are run for approximately 10 to 30 minutes. The use of

portable DC drain pumps during onboard emergencies is not incidental to normal operations, and

therefore not within the scope of this rule.

Based on data in the record, the wet exhaust discharge is likely to include metals, oil and

grease, and volatile and semi-volatile organic compounds. The concentrations of copper, lead,

nickel, silver, and zinc in portable DC drain pump wet exhaust can exceed acute Federal criteria

and State acute water quality criteria. Concentrations of oil and grease, benzene, toluene,

ethylbenzene, and naphthalene can exceed State acute water quality criteria. Concentrations of

these constituents in receiving waters are not expected to exceed water quality criteria because

they will dissipate quickly since the mass loadings per discharge event are small and the

discharge locations are dispersed fleetwide. The discharge from each of the 500 P-250 pumps

occurs separately at different discharge locations. On average, each P-250 pump discharges less

than 0.3 pounds of pollutants per discharge event. The duration of each discharge is short,
5-33

averaging less than 30 minutes. These factors allow the pollutants to dissipate rapidly. Based on

this information, the portable DC drain pump wet exhaust is expected to have a low potential for

exhibiting adverse environmental impacts on the marine environment. Therefore, EPA and DoD

determined it is not reasonable and practicable to require a MPCD to mitigate adverse impacts on

the marine environment for this discharge.

5.2.8 Refrigeration and Air Conditioning Condensate

This discharge is the drainage of condensed moisture from air conditioning units,

refrigerators, freezers, and refrigerated spaces. Refrigerators, refrigerated spaces, freezers, and

air conditioning units produce condensate when moist air contacts the cold evaporator coils.

This condensate drips from the coils and collects in drains. Condensate collected in drains above

the vessel waterline is continuously discharged directly overboard. Below the waterline,

condensate is directed to the bilge, non-oily machinery wastewater system, or is retained in

dedicated holding tanks prior to periodic overboard discharge.

Approximately 650 Navy, MSC, Coast Guard, Army, and Air Force vessels produce this

discharge. The condensate may be discharged at any time, both within and beyond 12 n.m. from

shore.

Condensate flow rates depend on air temperature, humidity, and the number and size of

cooling units per vessel. The discharge can contain cleaning detergent residuals, seawater from

cleaning refrigerated spaces, food residues, and trace metals leached from contact with cooling

coils and drain piping. Because evaporator coils are made from corrosion-resistant materials and

condensation is non-corrosive, condensate is not expected to contain metals in significant

concentrations. Discharges of refrigeration and air conditioning condensate are expected to have

a low potential for causing adverse environmental impacts, therefore EPA and DoD determined it

is not reasonable and practicable to require a MPCD to mitigate adverse impacts on the marine

environment for condensate discharges.

5.2.9 Rudder Bearing Lubrication

This discharge is the oil or grease released by the erosion or dissolution from lubricated

bearings that support the rudder and allow it to turn freely. Armed Forces vessels generally use

two types of rudder bearings, and two lubricating methods for each type of rudder bearing: 1)

grease-lubricated roller bearings; 2) oil-lubricated roller bearings; 3) grease-lubricated stave

bearings; and 4) water-lubricated stave bearings. Only oil-lubricated roller bearings and greaselubricated stave bearings generate a discharge.

Approximately 220 Navy vessels, 50 Coast Guard vessels, and eight MSC vessels use a

type of rudder bearing that generates this discharge. The discharge occurs intermittently,

primarily when a vessel is underway or its rudder is in use, although some discharges from oillubricated roller bearings could potentially occur pierside even when the rudder is not being used

because the oil lubricant is slightly pressurized.
5-34

This discharge consists of oil leakage and the washout of grease from rudder bearings.

EPA and DoD developed an upper bound estimate of the fleetwide release of oil and grease

based on allowable leakage/washout rates and the amount of time each vessel spends within 12

n.m. from shore. The maximum allowable oil leak rate for oil-lubricated roller bearings is one

gallon/day when the vessel is underway and one pint/day while in port. In practice, these leakage

rates are not reached under normal conditions. The grease washout rate for grease-lubricated

stave bearings is based on Navy specifications limiting grease washout to 5 percent. Grease

washout estimates for this rule are based on releasing 5 percent of the grease over a two-week

period, which corresponds to the time between grease applications.

EPA and DoD calculated the expected receiving water concentrations of oil and grease

from this discharge to evaluate the potential for the discharge to cause adverse impacts. The

underway receiving water volume was determined using an average size vessel and estimating

the volume of water displaced by the vessel while transiting from port to a distance of 12 n.m.

from shore. In port, discharges are not expected since the lower bearing seals are designed to

prevent leakage and, as noted above, the oil to the bearings is kept at a low pressure while in

port. The resulting estimated pollutant concentrations do not exceed acute Federal criteria or

State acute water quality criteria. The rudder bearing lubrication discharge has a low potential

for causing adverse environmental impacts. EPA and DoD determined that it is not reasonable

and practicable to require a MPCD to mitigate adverse impacts on the marine environment for

this discharge.

5.2.10 Steam Condensate

This discharge is the condensed steam discharged from a vessel in port, where the steam

originates from shore-based port facilities. Navy and MSC surface ships often use steam from

shore facilities during extended port visits to operate auxiliary systems such as laundry facilities,

heating systems, and other shipboard systems. In the process of providing heat to ship systems,

the steam cools and condenses. This condensate collects in drain collection tanks and is

periodically discharged by pumping it overboard. The steam condensate is discharged above the

vessel waterline and a portion of the condensate can vaporize as it contacts ambient air.

This discharge is generated only in port because vessels only discharge the condensed

steam if it was generated by a shore facility. Ships producing their own steam will recycle their

condensate back to the boiler. Vessels take on shore steam when their own boilers are shut

down, and thus they have no means for reusing the condensate. There are no systems in place

that would allow vessels to return steam condensate to shore for reuse.

Depending on the steam needs of individual vessels, the discharge can be intermittent or

continuous whenever shore steam is supplied. Approximately 180 Navy and MSC vessels

discharge steam condensate. Coast Guard vessels do not generate this discharge because they

operate their auxiliary boilers to produce their own steam even while in port. Army and Air

Force vessels do not have steam systems and therefore do not discharge steam condensate.
5-35

The constituents of steam condensate include metals from onshore steam piping, ship

piping, and heat exchangers, and may have some residual water treatment chemicals.

Constituents found in the discharge include nitrogen (in the form of ammonia, nitrates and

nitrites, and total Kjeldahl nitrogen), phosphorus, bis(2-ethylhexyl)phthalate, benzidine, copper,

and nickel. Sampling of steam condensate from four vessels found copper concentrations that

exceed both chronic Federal criteria and State chronic water quality criteria. Nickel

concentrations exceeded the most stringent State chronic water quality criteria, but not the

chronic Federal criteria. Benzidine, bis(2-ethylhexyl)phthalate, nitrogen (in the form of

ammonia, nitrates and nitrites, and total Kjeldahl nitrogen), and phosphorus concentrations

exceeded the most stringent State water quality criteria.

The potential for steam condensate to cause thermal environmental effects was evaluated

by modeling the thermal plume generated by the discharge and then comparing the model results

to State thermal discharge water quality criteria. Results of the modeling indicate that only the

largest generator of steam condensate (an aircraft carrier) may exceed state thermal mixing zone

criteria, and then, only in the State of Washington. The models predict that the thermal plume

from an aircraft carrier moored at the pier in Bremerton, Washington would extend a distance of

80 m from the discharge port along the vessel hull, not extending past the end of the hull. The

plume would also extend outward no more than a distance of 30 m from the vessel hull at any

point along the hull. Results of the modeling indicate that the aircraft carrier may exceed

Washington criteria in an area that only covers 5% of the width, 2% of the length, and 0.07% of

the total surface area of Sinclair Inlet.

The EPA and DoD do not consider that the plume results in a significant environmental

impact. Such a localized plume would have a low potential for interfering with the passage of

aquatic organisms in the water body and would have a limited impact on the organisms that

reside in the upper water layer (sea surface boundary layer). In addition, because the discharge is

freshwater (no salinity) and warmer than the receiving water, the plume floats in the surficial

layer of the water body and has no impact on bottom-dwelling organisms.

The low mass loadings in the discharge and the thermal effects modeling results indicate

that steam condensate has a low potential for causing adverse environmental impacts. Therefore,

EPA and DoD determined that it is not reasonable and practicable to require a MPCD to mitigate

adverse impacts on the marine environment for this discharge.

5.2.11 Stern Tube Seals and Underwater Bearing Lubrication

This discharge is the seawater pumped through stern tube seals and underwater bearings

to lubricate and cool them during normal operation.

Propeller shafts are supported by stern tube bearings at the point where the shaft exits the

hull (for surface ships and submarines), and by strut bearings outboard of the ship (for surface

ships only). A stern tube seal is used to prevent seawater from entering the vessel where the

shaft penetrates the hull. The stern tube seals and bearings are cooled and lubricated by forcing

seawater from the firemain or auxiliary cooling water system through the seals and over the
5-36

bearings. On submarines, potable water (freshwater) may be supplied from pierside connections

for stern tube seal lubrication during extended periods in port.

Strut bearings are not provided with forced cooling or lubrication. Instead, strut bearings

use the surrounding seawater flow for lubrication and cooling when the vessel is underway.

Submarines do not have strut bearings and instead use a self-aligning bearing aft of the stern tube

that supports the weight of the propeller and shafting outboard of the vessel.

Almost all classes of surface vessels and submarines have stern tube seals and bearings

that require lubrication, and these discharges are continuous. The discharge can contain synthetic

(Buna-N) rubber used in the construction of the bearings. Metals such as copper and nickel, the

materials of construction of the stern tube, can also be present in the discharge. When freshwater

is used for lubricating submarine seals, the freshwater may contain residual chlorine. Based on

estimates of chlorine concentrations in potable water, fleetwide approximately 0.8 pounds/year of

chlorine exit through the stern tube seals and bearings.

Total annual mass loadings for the metal constituents of seawater lubrication were

calculated based on materials of construction in the stern tube, corrosion rates for those materials,

and the surface area of the material exposed to seawater for a DDG 51 Class ship. While the

copper concentrations can exceed chronic Federal criteria and State chronic water quality criteria,

the rate at which the water is discharged through a vessel’s stern tube seal and bearings is

relatively small - 20 gal/min each shaft, 2 shafts per ship -- resulting in a low pollutant mass

loading exiting through the seals and bearings. Further, these discharges are distributed

throughout the U.S. at Armed Forces ports, and each individual port receives only a fraction of

the total fleetwide mass loading. Given the low rate of the discharge and the low mass loadings,

this discharge has a low potential for causing adverse environmental impacts. Therefore, EPA

and DoD determined it is not reasonable and practicable to require the use of a MPCD to

mitigate adverse impacts on the marine environment for this discharge.

5.2.12 Submarine Acoustic Countermeasures Launcher Discharge

This intermittent discharge is composed of seawater that mixes with acoustic

countermeasure device propulsion gas after launching an acoustic countermeasure device, and

subsequently discharged either through exchange with the surrounding seawater or while

draining from an expended device being removed from the submarine.

Navy submarines have the capability to launch acoustic countermeasures devices to

improve the survivability of a submarine by generating sufficient noise to be observed by hostile

torpedoes, sonars, or other monitoring devices. The only countermeasures systems that generate

a discharge within 12 n.m. are the countermeasures set acoustic (CSA) Mk 2 systems, which

launch the countermeasure devices by gas propulsion through a launch tube. Following the

launch, a metal plate closes the launch tube forming a watertight endcap. To equalize pressure, a

one-way check valve allows water to flow into the tube after launch, but does not allow any of

the water to be released through the opening. The launch tube cap contains three, 3/8 inch, bleed

hole plugs that dissolve approximately three days after the launch. This allows exchange
5-37

between the launch tube and the surrounding seawater while the submarine is moving. The bleed

holes also allow some launch tube water to drain into the surrounding water when the assembly

is removed from the submarine for replacement. The CSA Mk2 system is installed on 24 Navy

submarines.

Constituents found in the CSA Mk2 launch tubes after launching countermeasures

devices include copper, cadmium, lead, and silver. The discharge may also contain constituents

from the propulsion gas including hydrochloric acid, carbon dioxide, carbon monoxide, nitrogen,

alumina, iron (II) chloride, titanium dioxide, hydrogen, and iron (II) oxide. Sampling indicates

that copper, cadmium, and silver concentrations are above both Federal acute water criteria and

the most stringent State acute water quality criteria; lead concentrations are above the most

stringent State water quality criteria. The total annual mass loadings from all discharges from

submarine CSA Mk2 countermeasure launcher systems are estimated at 0.0005 pounds/year

cadmium, 0.0009 pounds/year lead, 0.0007 pounds/year copper, and 0.00009 pounds/year silver.

Because of the low annual mass loading, the low frequency at which the discharge occurs,

and the volume of the individual discharge event (17 gallons), discharges from submarine CSA

launcher systems have a low potential for causing adverse environmental impacts. Therefore

EPA and DoD determined it is not reasonable and practicable to require a MPCD to mitigate

adverse impacts on the marine environment for this discharge.

5.2.13 Submarine Emergency Diesel Engine Wet Exhaust

This discharge is seawater that is mixed and discharged with exhaust gases from the

submarine emergency diesel engine for the purpose of cooling the exhaust and quieting the

engine.

 Submarines are equipped with an emergency diesel engine that is also used in a variety

of non-emergency situations, including electrical power generation to supplement or replace

shore-supplied electricity, routine maintenance, and readiness checks. This wet exhaust

discharge is generated by injecting seawater (or harbor water) as a cooling stream into the diesel

engine exhaust system. The cooling water mixes with and cools the hot exhaust gases, and is

discharged primarily as a mist that disperses in the air before depositing on the surface of the

water body.

All submarines generate this discharge. Diesel engines must be operated for equipment

checks that occur prior to submarine deployment, monthly availability assurance, and periodic

trend analyses. On average, each submarine will operate the diesel engine for approximately 60

hours/year while within 12 n.m. from shore. Most of the operating time (54 hours/year) occurs

while the submarine is pierside.

Typical constituents of diesel engine exhaust include various hydrocarbon combustion

by-products, measured as volatile and semi-volatile organic compounds. The priority pollutants

expected to be present in the discharge include polycyclic aromatic hydrocarbons (PAHs),

toluene, and possibly metals. Although no individual pollutant exceeds water quality criteria, the
5-38

total concentration of PAHs in the discharge is predicted to exceed State acute water quality

criteria. Nevertheless, the discharge of PAHs is unlikely to cause adverse impacts on the marine

environment because the total fleetwide annual mass loading of PAHs is calculated to be less

than 0.06 pounds/year. Therefore, EPA and DoD determined that it is not reasonable and

practicable to require a MPCD to mitigate adverse impacts on the marine environment for

submarine diesel engine wet exhaust.

5.2.14 Submarine Outboard Equipment Grease and External Hydraulics

This discharge occurs when grease applied to a submarine’s outboard equipment is

released to the environment through the mechanical action of seawater eroding the grease layer

while the submarine is underway, and by the slow dissolution of the grease into the seawater.

This discharge also includes any hydraulic oil that may leak past the seals of hydraulically

operated external components of a submarine (e.g., bow planes).

Outboard equipment grease is discharged by all submarines, but the discharge of oil from

external hydraulic equipment is limited to 22 submarines. This discharge occurs continuously

both within and beyond 12 n.m. from shore, although the rate of discharge depends upon the

degree of contact between seawater and the greased outboard components, and how fast the

submarine is traveling. Most hydraulically-operated outboard equipment, for example, does not

contact seawater within 12 n.m. from shore because submarines generally operate on the surface

in this region, and the hydraulically-operated equipment producing this discharge is located

mostly above the waterline.

This discharge consists of grease (Termalene #2) and hydraulic oil. Termalene #2

consists of mineral oil, a calcium-based rust inhibitor, thickening agents, an antioxidant, and dye.

Using an assumption that 100 percent of all grease applied to outboard equipment is washed

away at a constant rate during submarine operations, the amount of grease released fleetwide

within 12 n.m. is approximately 520 pounds/year. This value is believed to overstate the actual

mass of grease discharged within 12 n.m. because submarines operate at lower rates of speed in

coastal waters (thus leading to less erosion of the grease) and a surfaced submarine exposes a

lesser amount of grease to the water than is exposed by a submerged submarine.

Hydraulic oil consists of paraffinic distillates and additives. Using a calculation that

assumes all hydraulic system seals leak oil at the maximum allowable leak rate, approximately

0.4 pounds/year of hydraulic oil is released fleetwide within 12 n.m. from shore. (Based on

discussions with Navy hydraulic system experts, such oil leakage rates are not common and thus

this calculation overestimates the amount of oil actually leaked.) The submarine will displace

approximately 120 million cubic feet of water as it travels within 12 n.m. from shore. Assuming

that hydraulic oil and outboard grease are leaked at a constant rate, this will result in

concentrations below the levels established in acute Federal criteria and State acute water quality

criteria.

In addition, the turbulence created by the vessel wake is expected to result in rapid

dispersion of the constituents released. As a result, the submarine outboard equipment grease
5-39

and external hydraulics discharge has low potential for causing adverse environmental effects.

EPA and DoD determined it is not reasonable and practicable to require a MPCD to mitigate

adverse impacts on the marine environment for this discharge.

5.3 References

1. International Maritime Organization. “Guidelines for Preventing the Introduction of

Unwanted Aquatic Organisms and Pathogens from Ships’ Ballast Water and Sediment

Discharge.” 10 May 1995.
GL-1

GLOSSARY AND ABBREVIATIONS

AAV amphibious assault vehicle

ABT aerostat balloon tender

AC area command cutter

AC anti-corrosive – as related to vessel hull coatings

ACE armored combat earthmover

Administrator the Administrator of the U.S. Environmental Protection Agency

AE ammunition ship

AF anti-fouling

AFB air force base

AFDB large auxiliary floating drydock

AFDL small auxiliary floating drydock

AFDM medium auxiliary floating drydock

AFFF aqueous film-forming foam

AFS combat store ship

AG miscellaneous auxiliary

AGER environmental research ship

AGF miscellaneous command ship

AGM missile range instrumentation ship

AGOR oceanographic research ship

AGOS ocean surveillance ship

AGS surveying ship

AGSS auxiliary research submarine

AH hospital ship

AKR vehicle cargo ship

Amps amperes

Anode the site at which oxidation occurs in an electrochemical cell

ANB aids to navigation boat

AO oiler

AOE fast combat support ship

AP area point system search craft

APF afloat pre-positioning force

APL barracks craft
GLOSSARY AND ABBREVIATIONS (contd.)

GL-2

APU auxiliary power unit

AR repair ship

ARC cable repairing ship

ARD auxiliary repair dock

ARDM medium auxiliary repair dock

ARS salvage ship

AS submarine tender

ASR annual sedimentation rate

ASTM American Society for Testing and Materials

ASW anti-submarine warfare

AT armored troop carrier

ATC mini-armored troop carrier

ATF fleet ocean tug

avg. average

AWR army war reserve

B barge

BC dry cargo barge

BCDK decked, enclosed conversion kit barge

BD floating crane

BDL below detection limit

BG liquid cargo barge

BH boom handling boat

BK deck cargo barge

BMP best management practice

BOD biochemical oxygen demand

BPL delong mobile piers

BRM refrigerated stores barge

BT bomb target

BU buoy utility boat

BUSL stern loading buoy utility boat

BW boston whaler

CA catamaran (also a gun cruiser, surface combatant)

Cathode the site at which reduction occurs in an electrochemical cell

CC cabin cruiser
GLOSSARY AND ABBREVIATIONS (contd.)

GL-3

CDNSWC (see NSWCCD)

CFR Code of Federal Regulations

CG guided missile cruiser

CGN guided missile cruiser (non-conventional propulsion)

CHT collection, holding and transfer (tank)

CID commercial item description

CM landing craft, mechanized

Cm centimeter

CNO Chief of Naval Operations

COD chemical oxygen demand

COE Corps of Engineers

COMNAVAIRLANT Commander Naval Air Force, Atlantic Fleet

COMNAVAIRPAC Commander Naval Air Force, Pacific Fleet

COMNAVSURFLANT Commander Naval Surface Force, Atlantic Fleet

COMNAVSURFPAC Commander Naval Surface Force, Pacific Fleet

COPHOS coordinated phosphate treatment

CORMIX Cornell mixing zone expert system

CPO chlorine produced oxidants

CPP controllable pitch propeller

CRRC combat rubber raiding craft

CT craft of opportunity coop trainer

CU landing craft, utility

CV multi-purpose aircraft carrier

CVN multi-purpose aircraft carrier, non-conventional

CWA Clean Water Act

DB distribution box boat

DBT dibutyltin

DC direct current

DC damage control

DD destroyer

DDG guided missile destroyer

DFT dry film thickness

DoD Department of Defense

DOT Department of Transportation
GLOSSARY AND ABBREVIATIONS (contd.)

GL-4

DSRV deep submergence rescue vehicle

DSV deep submergence vehicle

DT diving tender

DW dive workboat

EDTA ethylenediaminetetraacetic acid, a chelating agent

EE equipment expert

EGT emergency gas turbine

EOSS engineering operating sequencing systems

EPA the U.S. Environmental Protection Agency

ESC the UNDS Executive Steering Committee

FAS fueling at sea

FB catamaran ferry

FFG guided missile frigate

FLO/FLO float-on/float-off vessel

FMS floating machine shop

FR Federal Register

FR fouling rating

FSS fast sealift ship

G grams

Gal gallons

Gpm gallons per minute

GRP glass reinforced plastic

HC hydrocarbon

HEM hexane extractable materials

HOPM hydraulic oil pressure module

HP horsepower

I&S intelligence and security

ICCP impressed current cathodic protection

ILS integrated logistics services

IMO International Maritime Organization

INSURV board of inspection and survey

IX unclassified miscellaneous unit

J-Boat work and inspection boat

Kw kilowatt
GLOSSARY AND ABBREVIATIONS (contd.)

GL-5

L liter

LA landing craft, assault

LARC four-wheeled amphibious cargo vehicle

LASH lighter-aboard-ship

Lb pound

LC landing craft

LCAC landing craft, air cushion

LCC amphibious command ship

LCM landing craft, mechanized

LCPL landing craft, personnel, large

LCU landing craft, utility

LCVP landing craft, vehicle, personnel

LH line handling boat

LHA amphibious assault ship (general-purpose)

LHD amphibious assault ship (multi-purpose)

LPD amphibious transport dock

LPH amphibious assault ship (helicopter)

LSD dock landing ship

LST tank landing ship

LSV logistics support vessel

LT large harbor tug

MARAD Maritime Administration

MARPOL international convention for the prevention of pollution from

ships

MBT monobutyltin

MBT main ballast tank

MC mine countermeasures support craft

MCB motor cargo boat

MCM mine countermeasures ship

MDL minimum detection limit

MDZ maritime defense zone

MEB marine expeditionary brigade

MERR metal element repair and restoration machine

μg micrograms (one millionth of a gram)
GLOSSARY AND ABBREVIATIONS (contd.)

GL-6

Mg milligrams (one thousandth of a gram)

Mgal million gallons

Mgy million gallons per year

MHC minehunter, coastal

Min minute

ML motor launch

ML milliliter (one thousandth of a liter)

MLB motor life boat

MM marine mammal support craft

MNV mine neutralization vehicle

MOGAS motor gasoline

MPC maintenance procedure card

MPCD marine pollution control device

MPS maritime pre-positioning ship

MR missile retriever

MRC major regional conflict

MSB motor surf boat

MSC Military Sealift Command

MSD marine sanitation device

MSDS material safety data sheet

MV motor vessel

MW motor whaleboat

MWT magnetic water treatment

n.m. nautical miles

NAVSEA (or SEA) Naval Sea Systems Command

NAVSTA naval station

NDRF National Defense Reserve Fleet

NDZ no-discharge zone

NFAF Naval Fleet Auxiliary Force

NFESC Naval Facilities Engineering Services Command

NFME naval fleet marine expeditionary (see MEB)

NFO normal fuel oil

NL no limit

NM noise measuring boat
GLOSSARY AND ABBREVIATIONS (contd.)

GL-7

NOAA National Oceanic and Atmospheric Administration

NOD nature of discharge

NPDES national pollutant discharge elimination system

NraD Naval Research and Development Command

NRF Naval Reserve Fleet

NS non-standard (commercial) boat

NSTM naval ships’ technical manual

NSWCCD Naval Surface Warfare Center, Carderock Division

OCM oil content monitor

OPNAVINST naval operations instruction manual

OWHT oily waste holding tank

OWS oil-water separator

P personnel boats

PAH polynuclear aromatic hydrocarbon

PB patrol boat

PB-HS patrol boat, harbor security

PBR river patrol craft

PC patrol, coastal

PCB polychlorinated biphenyl

PE personnel boat

PF patrol craft, fast

PG patrol gunboat

PK picket boat

PL landing craft, personnel light

PMS preventative maintenance system

PMS planned maintenance system

Ppb parts per billion

Ppm parts per million

PR plane personnel and rescue

PREPO pre-positioning ships

Priority pollutants toxic pollutants designated in section 307(a) of the Clean

Water Act

PSB port security boat

Psi pounds per square inch
GLOSSARY AND ABBREVIATIONS (contd.)

GL-8

PT punt

PWB ports and waterways boat

RB or RIB rigid inflatable boat

RHIB rigid hull inflatable boat

RHIL large rigid hull inflatable boat

RHIM medium rigid hull inflatable boat

RIMSS redundant independent mechanical starting systems

RO reverse osmosis

RO/RO roll-on/roll-off type vessel

ROS reduced operating status

RRC rubber raiding craft

RRDF roll-on/roll-off discharge facilities

RRF Ready Reserve Fleet

RX rigid inflatable boat (non-standard)

SB sound/sail

SC support craft

SCAMP submerged cleaning and maintenance platform

SCC sample control center

Secretary the Secretary of the U.S. Department of Defense

SER sampling episode report

SERC Smithsonian Environmental Research Center

SES surface effects ship

SESO Ships Environmental Support Office

SGT silicone gel treated

SLO synthetic lubricating oil

SLWT side-loading warping tug

SMSF special mission support force

SRB surf rescue boat

SRFO standard refueling, fuel oil

SS steamship

SS submarine, (also swimmer support)

SSAP specific sampling and analysis plan

SSBN ballistic missile submarine, non-conventional

SSN submarine, non-conventional
GLOSSARY AND ABBREVIATIONS (contd.)

GL-9

ST sail training craft also small harbor tug

SVOC semi-volatile organic compound

T-Boat small freight and supply vessel

TACOM U.S. Army Tank-Automotive and Armaments Command

TANB trailerable aids to navigation boat

TBT tributyltin

TC training craft

TCLP toxicity characteristic leaching procedure

TD target drone

TDD technical development document

TDS total dissolved solids

TG tugboat

TOC total organic carbon

TPH total petroleum hydrocarbons

TR torpedo retriever

TRC total residual chlorine

TRO total residual oxidants

TS training ship, State Maritime Academies

TSS total suspended solids

TWG technical working group

U utility boat

UB utility boat

UMI underway material inspections

UNDS uniform national discharge standards

UNREP underway replenishment

UTB utility boat

UTL large utility boat

VOC volatile organic compound

VP landing craft, vehicle personnel

VSTOL vertical/short take-off and landing

WAGB icebreaker

WB work boat

Welldeck the docking well onboard amphibious warfare ships used to

store landing craft
GLOSSARY AND ABBREVIATIONS (contd.)

GL-10

WH wherry

WHEC high endurance cutter

WIX training cutter/sailing bark

WLB offshore buoy tender

WLI inshore buoy tender

WLIC inland construction tender

WLM coastal buoy tender

WLR river buoy tender

WMEC medium endurance cutter

WOCT waste oil collection tank

WOT waste oil tank

WPB patrol boat

WQC water quality criteria

WT warping tug

WTGB icebreaking tug

WYTL harbor tug, small

WYTM harbor tug, medium

YC open lighter

YCF car float

YCV aircraft transportation lighter

YD floating crane

YDT diving tender

YFB ferryboat or launch

YFN covered lighter

YFNB large covered lighter

YFND drydock companion craft

YFNX lighter - special purpose

YFP floating power barge

YFRN refrigerated/covered lighter

YFRT covered lighter, range tender

YFU harbor utility craft

YGN garbage lighter

YL yawl

YLC salvage lift craft
GLOSSARY AND ABBREVIATIONS (contd.)

GL-11

YM dredge

YMN dredge

YNG gate craft

YO fuel oil barge

YOG gasoline barge

YOGN gasoline barge

YON fuel oil barge

YOS oil storage barge

YP patrol craft, training

YPD floating pile driver

YR floating workshop

Yr year

YRB repair and berthing barge

YRBM repair, berthing and messing barge

YRDH floating drydock workshop, hull

YRR radiological repair barge

YRST salvage craft tender

YSD seaplane wrecking derrick

YSR sludge removal barge

YTB large harbor tug

YTL small harbor tug

YTM medium harbor tug

YTT torpedo trials craft

YWN water barge
A-1

Appendix A

Nature of Discharge (NOD) and Marine Pollution Control Device (MPCD) Reports
A-2

Appendix A

Appendix A contains each of the 39 NOD reports, the contents of which are described in

section 4.3 of the main document. Reports are arranged alphabetically, in order of appearance.

The title of each report may be found on the bottom center of each page. The following four

MPCD practicability analyses are also included in this appendix, after the respective NOD

reports:

• Distillation and Reverse Osmosis Brine;

• Hull Coating Leachate;

• Small Boat Engine Wet Exhaust; and

• Underwater Ship Husbandry

Refer to section 4.4 for a more detailed discussion of the process used to determine MPCD

practicability.
A-3

Appendix A

List of NOD and MPCD Reports (in order of appearance)

Aqueous Film-Forming Foam NOD Report

Boiler Blowdown NOD Report

Catapult Water Brake Tank and Post-Launch Retraction Exhaust NOD Report

Catapult Wet Accumulator Discharge NOD Report

Cathodic Protection NOD Report

Chain Locker Effluent NOD Report

Clean Ballast NOD Report

Compensated Fuel Ballast NOD Report

Controllable Pitch Propeller Hydraulic Fluid NOD Report

Deck Runoff NOD Report

Dirty Ballast NOD Report

Distillation and Reverse Osmosis Brine NOD Report

Distillation and Reverse Osmosis Brine MPCD Report

Elevator Pit Effluent NOD Report

Firemain Systems NOD Report

Freshwater Lay-Up NOD Report

Gas Turbine Water Wash NOD Report

Graywater NOD Report

Hull Coating Leachate NOD Report

Hull Coating Leachate MPCD Report

Mine Countermeasures Equipment Lubrication NOD Report

Motor Gasoline Compensating Discharge NOD Report

Non-Oily Machinery Wastewater NOD Report

Photographic Laboratory Drains NOD Report

Portable Damage Control Drain Pump Discharge NOD Report

Portable Damage Control Drain Pump Wet Exhaust NOD Report

Refrigeration /Air Conditioning Condensate NOD Report

Rudder Bearing Lubrication NOD Report

Seawater Cooling Overboard Discharge NOD Report

Seawater Piping Biofouling Prevention NOD Report

Small Boat Engine Wet Exhaust NOD Report

Small Boat Engine Wet Exhaust MPCD Report

Sonar Dome Discharge NOD Report

Steam Condensate NOD Report

Stern Tube Seals and Underwater Bearing Lubrication NOD Report

Submarine Acoustic Countermeasures Launcher Discharge NOD Report

Submarine Bilgewater NOD Report

Submarine Emergency Diesel Engine Wet Exhaust NOD Report

Submarine Outboard Equipment Grease and External Hydraulics NOD Report

Surface Vessel Bilgewater/Oil-Water Separator Discharge NOD Report

Underwater Ship Husbandry NOD Report

Underwater Ship Husbandry MPCD Report

Welldeck Discharges NOD Report

Aqueous Film Forming Foam (AFFF)

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“..discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Aqueous Film Forming Foam (AFFF)
Aqueous Film Forming Foam (AFFF)

2

2.0 DISCHARGE DESCRIPTION

This section describes the AFFF and includes information on: the equipment that is used

and its operation (Section 2.1), general description of the constituents of the discharge (Section

2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

AFFF is the primary firefighting agent used aboard U.S. Coast Guard (USCG) and Navy

vessels for flammable liquid fires. A different class of agents, Fluoroprotein foams, are used for

the same purpose on vessels in the Military Sealift Command (MSC). Aqueous Film Forming

Foam (AFFF) is a particular type of synthetic firefighting foam whose performance is governed

by military specification. Fluoroprotein foam is a protein-based material to which fluorinated

surfactants have been added to improve fluidity and surface tension properties, while reducing

the tendency of the protein base to absorb liquids.

These foams control and extinguish flammable liquid fires and help prevent such fires

after spills by spreading a vapor-sealing film over the flammable liquid. The foam layer

effectively excludes oxygen from the surface of the fuel, while the high water content cools the

surface. The foam layer also provides a reservoir that will reseal a disturbed fuel surface and

inhibit reignition. Both foams have excellent “wetting” or penetrating characteristics can be used

against fires involving densely packed wood, wood products, cloth, textile and fibrous materials,

paper, and paper products. Both types of foam concentrates can be stored for indefinite periods

in approved equipment and systems with no degradation in chemical properties or capabilities.

In use, foam concentrate is mixed with seawater to form a dilute seawater foam solution.

Seawater foam solution is generated in foam proportioning stations or by portable proportioners.1

Each type involves metering foam concentrate into pressurized, firefighting seawater. The

metering accuracy of the proportioning stations is verified by periodic tests.

Foam is applied both manually, with conventional foam or water/fog equipment such as

fire hoses equipped with foam nozzles, and from fixed sprinkler devices. Fixed systems provide

seawater foam solution to sprinklers on flight decks, and to overhead sprinklers in hangars, tank

decks, well decks, weapon elevator pits, fueled vehicle decks or holds, refueling stations, and

fuel pump rooms. If a protected area requires a greater flow rate than can be supplied by a single

proportioning station, the area is subdivided into zones or groups, each independently supplied

from a single proportioning station. Bilge sprinkler systems are installed in machinery spaces

and pump rooms. Firefighting hose reel stations are supplied through a system of proportioners,

pumps, and permanently installed piping.

Foam concentrate is stored in tanks, 55-gallon drums, and 5-gallon cans. Aircraft

carriers, large amphibious ships, and other large ships can carry more than 20,000 gallons of

AFFF or fluoroprotein foam concentrate.

Neither AFFF nor fluoroprotein foam is ever discharged from vessels in concentrated
Aqueous Film Forming Foam (AFFF)

3

form. Only the dilute seawater foam solution is discharged. Incidental discharge of seawater

foam solution occurs during maintenance that is part of the Planned Maintenance System (PMS),

Board of Inspection and Survey (INSURV) underway material inspections (UMI), flight deck

certifications, or biennial tests on MSC vessels by the USCG Office of Marine Inspection.

Regular preventive maintenance of firefighting systems and equipment requiring the

discharge of seawater foam solution aboard ship occurs annually during PMS activities, although

some maintenance is performed at 18 month intervals. Table 1 indicates the frequency of foam

solution discharges on Navy, MSC, and USCG vessels. For Navy vessels, an INSURV UMI

occurs every 3 years and involves the same system checks and resulting seawater foam

discharges as the annual PMS activities. An MSC damage control instruction requires that foam

solution be present at flight deck nozzles before every flight operation (approximately twice per

month per vessel), which is verified by operating the nozzles until foam is sighted.2 For aircraft

carriers, Navy requirements call for a flight deck certification during the first deployment to sea

after a shipyard or repair period (approximately every 1.5 years). Other than aircraft carriers,

ships with flight decks, whether Navy or MSC, receive flight deck certification inspections every

3 years that test for foam solution at all flight deck nozzles and hoses.

2.2 Releases to the Environment

The seawater foam solutions that are discharged onto flight and weather decks as a result

of maintenance, inspection, and certification activities are washed overboard with pressurized

seawater from fire hoses, or by activating the seawater washdown system. Foam that is

discharged into internal ship compartment bilges during system testing and flushing evolutions is

pumped overboard by eductors.

Seawater foam discharge will contain all the constituents from the firemain, in addition to

constituents unique to the foam concentrate. As discussed more fully in the Firemain Systems

NOD Report, the principal constituent of the firemain discharge that could have an adverse water

quality effect is copper, derived from the copper nickel firemain piping. Therefore, copper will

be an expected component of the AFFF solution discharge.

2.3 Vessels Producing the Discharge

All Navy surface ships, all classes of USCG cutters, icebreakers and icebreaking tugs, and

MSC ship classes with the ability to support helicopter operations produce the discharge.

Table 2 shows the vessel classes that produce the discharge.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
Aqueous Film Forming Foam (AFFF)

4

3.1 Locality

The Navy provides instruction on where seawater AFFF solutions can be discharged

during maintenance that tests the proportioning accuracy of AFFF proportioning stations. This

test is commonly conducted by discharging an AFFF hose over the side, when beyond the 12

nautical mile (n.m.) limit. The PMS instructions state:

“Accomplish maintenance requirements only when ship is beyond 12 nautical miles of

shore and preferably while underway. When within 3 nautical miles of shore or in port,

discharge to a tank, barge or to an authorized truck. In other cases, when between 3 and

12 nautical miles, overboard discharge is permitted with a minimum (ship) speed of 10

knots.”3-9

Discharges that are part of inspections and certifications are not governed by the

maintenance instruction, and can be discharged anywhere, except that seawater foam solution in

a machinery space bilge is governed by bilge pumping rules, and cannot be discharged within 12

n.m.10 In practice, the maintenance policy applies because a single discharge event will be

scheduled to satisfy simultaneously the requirements for maintenance, inspection, and

certification.

3.2 Rate

When testing the proportioning accuracy of proportioning stations, ships typically test one

station at a time by discharging a foam hose over the side. This discharge rate is 125 gallons per

minute (gpm) or 250 gpm, depending on the flow rate of the hose selected for the test. When

testing or demonstrating flight deck sprinkling, the most common practice is to operate one or

two zones at a time, continuing until all the zones have been tested. The nominal flow rate for

each zone on Navy ships is 1,000 gpm, so the typical discharge rate is 2,000 gpm.

AFFF concentrate is mixed with seawater from the firemain to form a 6% dilute solution,

that is, 100 gallons of solution contains 6 gallons of AFFF concentrate and 94 gallons of

seawater.1

 The WTGB 140 Class of icebreaking tugs operated by the USCG use more

concentrated base stock which is diluted to a 3% solution. Fluoroprotein foams are mixed on

MSC ships in both 3% and 6% solutions, depending on the design of the installed proportioning

equipment.11 These mixing ratios are used in Table 2 to derive discharge quantities of foam

concentrate and seawater.

After tests or demonstrations of flight deck sprinkling, the foam blanket is washed off

using fire hoses, or by operating the fixed seawater washdown system. Both techniques result in

a seawater discharge supplied from the firemain. The flow rate is variable, but a typical range is

250 gpm (two fire hoses on a ship with a helicopter landing platform) to 2,000 gpm (two flight

deck zones on an aircraft carrier).

Tests or demonstrations of bilge sprinkling do not result in environmental discharges
Aqueous Film Forming Foam (AFFF)

5

until bilges are pumped overboard. Bilges can be pumped within 12 n.m. of shore if the

discharge is passed through oil water separators. However, the surfactants in AFFF and

fluoroprotein foam render the oil water separators ineffective, so crews do not discharge seawater

foam solution through their oil water separators. Accordingly, bilges containing seawater foam

solution are pumped only beyond 12 n.m. from shore10. Therefore, this NOD report does not

account for foam discharges attributable to bilge sprinkling, discharge of machinery space bilge

hoses, nor the seawater used to wash and pump bilges.

By ship class, Table 2 shows the discharges of seawater foam solution, foam concentrate

in the solution, seawater in the solution, and seawater used to wash the solution off the ship. All

discharges are assumed to occur within 12 n.m. of shore. The fleetwide estimates are

summarized in Table 3.

3.3 Constituents

The ingredients in foam concentrate are listed on material safety data sheets (MSDSs)

prepared by the manufacturer. The AFFF concentrate produced by the principal Armed Forces

supplier contains water, 2-(2-butoxyethoxy)-ethanol, urea, alkyl sulfate salts (2 in number),

amphoteric fluoroalkylamide derivative, perfluoroalkyl sulfonate salts (5), triethanolamine, and

methyl-1H-benzotriazole, with fresh water accounting for approximately 80% of the ingredients

by weight (see Table 3).12 Freshwater is the principal ingredient of all the foam concentrates

used by the Armed Forces, comprising approximately 80% - 90% of the product by weight.12-16

The protein base in fluoroprotein foam is nontoxic and biodegradable. The chemical identities

and corresponding weight percents of the surfactants in AFFF and fluoroprotein concentrates are

proprietary, but are stated by the manufacturers to be nontoxic in the quantities present in the

manufactured product, and more benign when diluted with seawater to a 3% or 6% solution.

Fluoroprotein foam and 3% AFFF used on MSC and USCG vessels contribute only 4% of the

total volume of foam discharged annually from vessels.

No priority pollutants nor bioaccumulators are known to be present in the AFFF product

or fluoroprotein foam concentrates used aboard vessels of the Armed Forces.

The firemain provides the seawater in the seawater foam solution. Metals and other

materials from the firemain system can be dissolved by the seawater, and particles can be eroded

and physically entrained in the seawater flow. Any wetted material in the firemain system can

become a constituent of the firemain discharge. None of the potential constituents are known

bioaccumulators. The priority pollutants in the discharge are bis(2-ethylhexyl) phthalate, copper,

nickel, and iron, which are found in the piping of wet firemain systems.

The piping in Navy AFFF systems is made of copper nickel alloy, the same as used in the

firemain system. Total nitrogen, bis(2-ethylhexyl) phthalate, copper, nickel, and iron from this

source will be constituents of the discharge.

3.4 Concentrations
Aqueous Film Forming Foam (AFFF)

6

Table 3 shows the concentrations of the chemical constituents in AFFF concentrate. The

data are based on the type of concentrate that is most widely used. Table 3 also shows the

concentrations in the seawater foam solution.

Seawater foam discharges have not been part of the sampling program. The

concentrations of total nitrogen, bis(2-ethylhexyl) phthalate, copper, nickel, and iron contributed

from the AFFF system are not known. AFFF concentrate includes corrosion inhibitors.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of constituents in the

discharge are estimated and compared with the water quality criteria. In Section 4.3, the

potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Discharge quantities in Table 2 and constituent concentrations in Table 3 are combined to

estimate mass loadings.

Based on the approximate mass of 366,000 pounds of AFFF concentrate discharged

annually from Navy and USCG vessels, and the weight percentages of AFFF constituents, upper

bound estimates of the annual mass loadings for the constituents range from a maximum of

approximately 38,500 pounds for 2-(2-butoxyethoxy)-ethanol to a minimum of 370 pounds for

methyl-1H-benzotriazole. The mass loadings resulting from 3% AFFF and fluoroprotein foam

discharges aboard MSC vessels do not significantly change the calculated loadings because the

total volume of these concentrates represents 4.0% of the foam discharged annually.

The annual mass loadings of copper, nickel, and iron from the firemain system are shown

in Table 3, based on a total of 4,924,000 gallons of seawater used to produce foam and wash it

off the ship after the test.

4.2 Environmental Concentrations

As listed in Table 2, individual constituent concentrations in foam range from 6,400 mg/L

for 2-(2-butoxyethoxy)-ethanol down to about 61 mg/L for methyl-1H-benzotriazole. The

concentrations presented represent AFFF seawater foam constituent concentrations in the product

as discharged from hose nozzles and sprinkler heads aboard ship. These concentrations do not

take into account the additional diluting effect of any seawater used to wash the AFFF seawater

solution overboard. Thus, the concentration of the constituents in AFFF seawater solutions is

reduced when this additional dilution factor is considered. Further, the ship’s motion through the

sea causes the discharge to be distributed along the ship’s track, instead of being discharged in a

single spot. Upon discharge to the environment, AFFF concentrate has been diluted 94:6 (about
Aqueous Film Forming Foam (AFFF)

7

16:1) by the proportioning process, with further dilution during the wash-off procedure, followed

by rapid dispersion in the wake of a moving ship.

AFFF could potentially be discharged from vessels in amounts that cause visible foam

floating on the water surface. Floating foam detracts from the appearance of surface waters and

can violate aesthetic water quality criteria. Several states have standards to prevent “floating

The bis(2-ethylhexyl) phthalate, copper, nickel, and iron constituents are the only priority

pollutants sampled which exceed acute water quality criteria. Table 4 shows the concentration of

the constituents of firemain water, total nitrogen, bis(2-ethylhexyl) phthalate, copper, nickel, and

iron, that exceed acute water quality criteria. The copper concentration exceeds both the Federal

and most stringent state criteria while the total nitrogen, bis(2-ethylhexyl) phthalate, nickel, and

iron concentrations exceed only the most stringent state criterion.

4.3 Potential for Introducing Non-Indigenous Species

AFFF and fluoroprotein concentrates do not include biota. Seawater foam discharge can

include microbial and invertebrate marine organisms, since biofouling accumulates in firemain

systems, wet and dry types. See the Firemain Systems NOD Report for a discussion of the

potential for introducing non-indigenous species in the firemain discharge.

5.0 CONCLUSION

AFFF discharges from vessels of the Armed Forces have the potential to cause an adverse

environmental impact. There is currently an operational policy and procedure that prohibits any

overboard discharge of AFFF from Navy vessels within 3 n.m. of shore, and stipulates that

discharge could only occur at a minimum speed of 10 knots between 3 and 12 n.m. from shore.

If this policy were not in place, the discharge could deposit significant amounts of foam on

surface water. This foam would diminish the visual quality of the water.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information was used to estimate the volume of discharge. Based on this estimate and on the

reported constituent percentages by weight, the concentrations of the AFFF constituents in this

discharge were then estimated. Table 5 shows the sources of the data used to develop this NOD

report.

Specific References

1. Naval Ships’ Technical Manual (NSTM), Chapter 555, Vol. 1, Revision 4, pages 1-23, 2-
Aqueous Film Forming Foam (AFFF)

8

6, 2-7, 4-22, and 4-23, Surface Ship Firefighting. 8 December 1997.

2. Military Sealift Command (MSC), Damage Control Manual, COMSCINST 3541.5D,

21 February 1994, page 1-10-2.

3. Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)

5551/026-C5, Fire Extinguishing System, Fog, Foam, and AFFF, December 1995.

4. Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)

5551/027-C6, Fire Extinguishing System, Fog, Foam, and AFFF, December 1996.

5. Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)

5551/029-86, Fire Extinguishing System, Fog, Foam, and AFFF, August 1996.

6. Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)

5551/031-C5, Fire Extinguishing System, Fog, Foam, and AFFF, December 1995.

7. Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)

5551/034-A4, Fire Extinguishing System, Fog, Foam, and AFFF, October 1994.

8. Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)

5551/036-A4, Fire Extinguishing System, Fog, Foam, and AFFF, October 1994.

9. Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)

5551/037-37, Fire Extinguishing System, Fog, Foam, and AFFF, March 1997.

10. Office of Chief of Naval Operations (OPNAV), Environmental and Natural Resource

Program Manual, OPNAVINST 5090.1B, 1 November 1994.

11. Weersing, Penny, Military Sealift Command Central Technical Activity. Design of Fire

Protection Systems on MSC Ships, 26 March 1997, David Eaton, M. Rosenblatt & Son, Inc.

12. 3M Material Safety Data Sheet, FC-206CF LIGHT WATERTM Brand Aqueous Film

Forming Foam, November 13, 1995.

13. Ansul Inc. Material Safety Data Sheet, Ansulite 6% AFFF (AFC-5), May 19, 1995.

14. Chubb National Foam Inc. Material Safety Data Sheet, Aer-0-Water 6EM, March 27, 1991.

15. National Foam Inc. Material Safety Data Sheet, Aer-0-Foam XL-3 3%, October 2, 1996.

16. Ansul Inc. Material Safety Data Sheet, Ansul 3% Fluoroprotein Foam Concentrate, June

2, 1997.

17. Poidinger, Joe, 3-M Corp. MSDS 6% AFFF Concentrate Density, 18 September 1997,
Aqueous Film Forming Foam (AFFF)

9

Anil Giri, M. Rosenblatt & Son, Inc.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).
Aqueous Film Forming Foam (AFFF)

10

Coast Guard Uniform Maintenance Card R-A-012, Damage Control, Auxiliary, Fire

Extinguishing System, AFFF system.

Darwin, Robert, NAVSEA 03G2. “AFFF Overboard Discharge.” M. Rosenblatt & Son, Inc.

Crystal City, VA. 17 September 1996.

UNDS Ship Database, August 1, 1997.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Table 1. Frequency of AFFF Discharge Events

Months 12 18 24 30 36 42 48 54 60 66 72

USCG Ships

PMS - annual X X X X X X

FD Cert - triennial X X

 Hose: 3 times in 3 years

 Flt dk: 1 time in 3 years

MSC Ships

PMS - annual X X X X X X

USCG - biennial X X X

FD Cert - triennial X X

INSURV - triennial X X

 Hose: 9 times in 6 years

 Flt dk: 7 times in 6 years

T-AKR Class

 Foam maker: 7 times in 6 years

 Hose: 9 times in 6 years

 Flt Dk: 7 times in 6 years

LPH Class

PMS - 18 months X X X X

FD Cert - triennial X X

INSURV - triennial X X

 Hose: 3 times in 3 years

 Flt Dk: 2 times in 3 years

CV/CVN Classes 

PMS - 18 months X X X X

FD Cert - 18 months X X X X

INSURV - triennial X X

 Hose: 3 times in 3 years

 Flt Dk: 3 times in 3 years

Other Navy Classes

PMS - annual X X X X X X

FD Cert - triennial X X

INSURV - triennial X X

 Hose: 4 times in 3 years

 Flt Dk: 2 times in 3 years

Notes for Table 1:

1. PMS discharges are scheduled by the ship. The ships are assumed to schedule their PMS maintenance tests to coincide with a demonstration required by an off-ship inspection team, when 

possible. The tests that satisfy off-ship inspection teams are assumed to be separate, not combined.

2. PMS tests are required annually, although, for some ships the periodicity is 18 months. Flight deck certification is required on all air capable ships every 3 years, except for aircraft carriers 

additional certifications are required after industrial work on the flight deck; the assumed average periodicity for aircraft carriers is every 18 months. INSURV underway material inspections are 

required every 3 years, only on Navy and MSC ships. For MSC ships, the USCG Office of Marine Inspection requires demonstration of foam making capability every 2 years.

3. Data are derived from references 2, and 3-9. 
Table 2. Annual Discharge Due to Tests, Inspections And Certifications

The Number The Number The Discharge Solution Solution Foam Seawater Clean-up

Ship Of Armed of Foam Events Disch. Per Disch. per Con. Disch. Disch. Seawater

 Class Ships Force Foam Dispensing Per Year Station per Class Per Class Per Class Per Class

Per Class Owner Stations Means Per Station Event (gal) (gal) (gal) (gal) (gal)

(See Table 1) (See Note 3) (See Note 4) (See Note 4) (See Note 4) (See Note 5)

WAGB 1 USCG 1 Hose 1 125 125 8 118 0

WAGB 2 USCG 1 Hose 1 125 250 15 235 0

WHEC 12 USCG 2 Hose 1 125 3000 180 2820 0

WMEC 31 USCG 1 Hose 1 125 3875 233 3643 0

WTGB 9 USCG 1 Hose 1 125 1125 34 1058 0

T-AE 26 8 MSC 2 Hose 1.5 125 3000 180 2910 0

8 MSC 2 Fl. Dk 1.167 353 6599 396 6203 54989

T-AFS 1 8 MSC 2 Hose 1.5 311 7459 448 7012 0

8 MSC 2 Fl. Dk 1.167 350 6529 392 6137 54410

T-AGOS 1 5 MSC 1 Hose 1.5 125 938 56 881 0

19 4 MSC 1 Hose 1.5 125 750 45 705 0

T-AGS 26 2 MSC 1 Hose 1.5 125 375 23 353 0

T-AGS 45 1 MSC 1 Hose 1.5 125 188 11 176 0

T-AGS 51 2 MSC 1 Hose 1.5 125 375 23 353 0

T-AGS 60 4 MSC 1 Hose 1.5 125 750 45 705 0

T-AH 19 2 MSC 1 Hose 1.5 384 1152 69 1083 0

2 MSC 1 Monitor 1.167 500 1167 70 1097 9725

T-AKR 11 MSC 2 Foam Mkr. 1.167 107 2747 82 2665 22893

11 MSC 2 Hose 1.5 125 4125 124 4001 0

11 MSC 2 Fl. Dk. 1.167 1707 43826 1315 42511 365213

T-AO 187 12 MSC 2 Hose 1.5 125 4500 270 4230 0

12 MSC 2 Fl. Dk. 1.167 360 10083 605 9478 84024

T-ARC 7 1 MSC 1 Hose 1.5 125 188 11 176 0

1 MSC 1 Fl. Dk. 1.167 360 420 25 395 3501

T-ATF 166 7 MSC 1 Hose 1.5 125 1313 79 1234 0

7 MSC 1 Fl. Dk. 1.167 125 1021 61 960 8509

AGF 11 2 NAVY 4 Hose 1.33 125 1330 80 1250 0

2 NAVY 4 Fl. Dk. 0.67 1021 5470 328 5142 45587

AGOR 21 1 NAVY 1 Hose 1.33 125 166 10 156 0

1 NAVY 1 Fl. Dk. 0.67 0 0 0 0 0
Table 2. Annual Discharge Due to Tests, Inspections And Certifications

The Number The Number The Discharge Solution Solution Foam Seawater Clean-up

Ship Of Armed of Foam Events Disch. Per Disch. per Con. Disch. Disch. Seawater

 Class Ships Force Foam Dispensing Per Year Station per Class Per Class Per Class Per Class

Per Class Owner Stations Means Per Station Event (gal) (gal) (gal) (gal) (gal)

(See Table 1) (See Note 3) (See Note 4) (See Note 4) (See Note 4) (See Note 5)

AGOR 23 2 NAVY 1 Hose 1.33 125 333 20 313 0

2 NAVY 1 Fl. Dk. 0.67 0 0 0 0 0

AO 177 5 NAVY 2 Hose 1.33 125 1663 100 1563 0

5 NAVY 2 Fl. Dk. 0.67 273 1829 110 1719 15243

AOE 1 4 NAVY 2 Hose 1.33 125 1330 80 1250 0

4 NAVY 2 Fl. Dk. 0.67 464 2489 149 2339 20738

AOE 6 3 NAVY 3 Hose 1.33 125 1496 90 1406 0

3 NAVY 3 Fl. Dk. 0.67 374 2258 135 2123 18817

ARS 50 4 NAVY 1 Monitor 1 1000 4000 240 3760 0

4 NAVY 1 Hose 1 250 1000 108 892 0

AS 33 1 NAVY 2 Hose 1.33 125 333 20 313 0

1 NAVY 2 Fl. Dk. 0.67 270 362 22 340 3015

AS 39 3 NAVY 2 Hose 1.33 125 998 60 938 0

3 NAVY 2 Fl. Dk. 0.67 314 1261 76 1185 630

CG 47 27 NAVY 3 Hose 1.33 125 13466 808 12658 0

27 NAVY 3 Fl. Dk. 0.67 170 9212 553 8659 76765

CGN 36 2 NAVY 2 Hose 1.33 125 665 40 625 0

2 NAVY 2 Fl. Dk. 0.67 144 386 23 363 3216

CGN 38 1 NAVY 2 Hose 1.33 125 333 20 313 0

59/63/65 4 NAVY 17 Hose 1 250 17000 1836 15164 0

4 NAVY 17 Fl. Dk. 1 1000 68000 4080 63920 566667

CVN 65/68 8 NAVY 16 Hose 1 250 32000 1920 30080 0

CVN 65/68 8 NAVY 20 Fl. Dk. 1 1000 160000 9600 150400 1333333

DDG 963 31 NAVY 2 Hose 1.33 125 10308 618 9689 0

31 NAVY 2 Fl. Dk. 0.67 130 5416 325 5091 45133

DDG 51 18 NAVY 2 Hose 1.33 125 5985 359 5626 0

18 NAVY 2 Fl. Dk. 0.67 210 5065 304 4761 2533

DDG 993 4 NAVY 2 Hose 1.33 125 1330 80 1250 11083

4 NAVY 2 Fl. Dk. 0.67 130 699 42 657 349
Table 2. Annual Discharge Due to Tests, Inspections And Certifications

The Number The Number The Discharge Solution Solution Foam Seawater Clean-up

Ship Of Armed of Foam Events Disch. Per Disch. per Con. Disch. Disch. Seawater

 Class Ships Force Foam Dispensing Per Year Station per Class Per Class Per Class Per Class

Per Class Owner Stations Means Per Station Event (gal) (gal) (gal) (gal) (gal)

(See Table 1) (See Note 3) (See Note 4) (See Note 4) (See Note 4) (See Note 5)

FFG 7 43 NAVY 2 Hose 1.33 125 14298 858 13440 0

43 NAVY 2 Fl. Dk. 0.67 182 10510 631 9879 87582

IX 308 2 NAVY 1 Hose 1.33 125 333 20 313 0

IX 35 2 NAVY 1 Hose 1.33 125 333 20 313 0

IX 501 1 NAVY 1 Hose 1.33 125 166 10 156 0

LCC 19 2 NAVY 2 Hose 1.33 125 665 40 625 0

2 NAVY 2 Fl. Dk. 0.67 320 857 51 805 7140

LHA 1 5 NAVY 12 Hose 1.33 250 19950 1197 18753 0

5 NAVY 12 Fl. Dk. 0.67 1000 40200 2412 37788 335000

LHD 1 4 NAVY 12 Hose 1.33 250 15960 958 15002 0

4 NAVY 12 Fl. Dk. 0.67 1000 32160 1930 30230 268000

LPD 4 8 NAVY 4 Hose 1.33 125 5320 319 5001 0

8 NAVY 4 Fl. Dk. 0.67 1021 21882 1313 20569 182347

LPH 2 2 NAVY 10 Hose 1 250 5000 540 4700 0

2 NAVY 10 Fl. Dk. 0.67 1000 13400 804 12596 111667

LSD 36 5 NAVY 4 Hose 1.33 125 3325 200 3126 0

5 NAVY 4 Fl. Dk. 0.67 365 4888 293 4595 40736

LSD 41 8 NAVY 4 Hose 1.33 125 5320 319 5001 0

8 NAVY 4 Fl. Dk. 0.67 936 20068 1204 18864 167232

LSD 49 3 NAVY 4 Hose 1.33 125 1995 120 1875 0

3 NAVY 4 Fl. Dk. 0.67 936 7525 452 7074 62712

LST 1179 3 NAVY 1 Hose 1.33 125 499 30 469 0

3 NAVY 1 Fl. Dk. 0.67 216 434 26 408 3618

MCM 1 14 NAVY 1 Hose 1.33 125 2328 140 2188 0

MHC 51 12 NAVY 1 Hose 1.33 125 1995 120 1875 0

PC 1 13 NAVY 1 Hose 1.33 125 2161 130 2032 0

13 NAVY 1 Fl. Dk. 0.67 162 1408 85 1324 11737

Misc. (See 

Note 6) 30 MSC N/A N/A N/A N/A 27500 1650 25850 220000

TOTAL 722537 42902 679931 4244144
Table 2. Annual Discharge Due to Tests, Inspections And Certifications

Notes for Table 2:

1. Values in this table are upper bound estimates, because all discharge is assumed to occur within 12 n. m. of shore.

2. Discharges are due to maintenance tests of the proportioning accuracy of the foam proportioners, to demonstrations of foam making capability for

flight deck certification teams, and to demonstrations of foam making capability for the Board of Inspection and Survey. Discharges to bilges, by hose

nozzles or fixed sprinklers, are not tabulated because the foam solution is not pumped overboard within 12 n.m. of shore.

3. The discharge flow through hoses is 125 gpm or 250 gpm, depending on the ship's installed equipment. The discharge rate through fixed flight deck

sprinklers is .06 gpm/ft2 X Flight Deck area. For aircraft carriers, and the big deck amphibious ships, LHD, LHA, and LPH, flight deck discharge is

calculated at 1000 gpm per zone.

4. Total hose flow is No. of ships X No. of stations per ship X Hose nozzle flow rate X 1 minute. Foam is 6% of total flow, and seawater is 94% of total

flow rate. For ships with fixed speed foam injection pumps, foam flow is 27 gpm and seawater flow = total flow - 27 gpm. Total flight deck flow is No. of

ships X flight deck area X .06 gpm/ft2 X 1 minute. For aircraft carriers and the big deck amphibious ships, LHD, LHA, and LPH, the total flow is No. of

ships X No. of zones per ship X 1000 gpm per zone X 1 minute. For both cases, foam is 6% of total flow, and seawater is 94% of total flow. For WTGB

and T-AKR Class ships foam is 3% of total flow and seawater is 97% of total flow; these ships use a more concentrated foam concentrate than other

ships.

5. The flow from demonstrations and tests of flight deck hoses is directed over the side. No seawater is needed for clean up. The flow through fixed

flight deck sprinklers is cleaned off the ship by seawater from the firemain, either through hose nozzles or the fixed flight deck sprinklers. As an average

figure to account for both options, the cleanup flow is assumed to be .05 gpm/ft2, or 833 gpm per zone, flowing for 10 minutes.

6. Aboard MSC ships with helicopter landing capabilities, the presence of foam must be demonstrated at flight deck nozzles and hoses before each

flight operation. Assuming two such operations per month per ship, the total annual discharge of fluoroprotein foam concentrate for the 30 ships involved

is 30 ships X 55 gallons foam concentrate per ship per year, which equals 1650 gallons/year. The concentrate is assumed to be 6% of the total flow, so

the total flow of solution is 1650/.06 or 27,500 gallons of seawater foam solution per year. The water portion is assumed to be 94% of the total flow.

Cleanup seawater flow is assumed to be eight times the total solution flow, or 220,000 gallons.

7. To perform a maintenance test of the proportioning accuracy of a proportioning station, foam solution will be directed over the side via a hose nozzle

rated at 125 gpm or 250 gpm, depending on the ship's installed equipment. Test is assumed to require 1 minute of flow.

8. To demonstrate foam-making ability for an off-ship inspection team, foam will be discharged over the side through hose nozzles and onto the flight

deck through the fixed sprinklers. Demonstration is assumed to require 1 minute of flow.

9. Data are derived from Table 1 , specific references 1, 2, 11, and general references.
Table 3. Upper Bound Estimates of Annual Mass Loading and Constituent Concentrations

Due to AFFF Discharge

Annual discharge of AFFF/seawater solution, gals 722,500

Annual discharge of AFFF concentrate, gals 42,900

Annual discharge of AFFF concentrate, lbs 366,366 8.54/lb/gal density

Annual discharge of seawater in the solution, gals 680,000

Annual discharge of cleanup seawater, gals 4,244,000

Annual discharge of seawater, including cleanup, gals 4,924,000

Mass Loading Concentration

Constituent Wt %

Low

Wt %

High

Low (lb) High

(lb)

Low

mg/L

High

mg/L

Fresh water 78.0% 81.0% 286,000 297,000 47,400 49,200

2-(2-butoxyenthoxy)-ethanol 9.5% 10.4% 34,800 38,500 5,800 6,400

urea 3.0% 7.0% 11,000 25,600 1,800 4,300

alkyl sulfate salts (2) 1.0% 5.0% 3,700 18,300 610 3,040

amphoteric fluoroalkylamide derivative 1.0% 2.0% 3,700 7,300 610 1,220

perfluoroalkyl sulfonate salts (5) 0.1% 1.0% 370 3,700 61 610

triethanolamine 0.1% 1.0% 370 3,700 61 610

methyl-1H-benzotriazole 0.0% 0.1% 0 370 0 61

Constituent Concentration Mass Loading

Total nitrogen 500 μg/L 16.8 lb

Bis(2-ethylhexyl) phthalate in seawater 22 μg/L 0.74 lb

Copper in seawater 45.59 μg/L 1.87 lb

Nickel in seawater 15.24 μg/L 0.62 lb

Iron in seawater 21.28 μg/L 0.87 lb

Notes:

1. Conversion: 1 μg/L = 8.345 X 10-9 lb/gal

2. Concentrations in mg/L are for the diluted AFFF/seawater solution. The concentrations are accurate for hoses

discharged over the side, but overstated by about 30% for flight deck discharges which are washed over the side

with additional seawater. Calculation is pounds of constituent, divided by gallons of discharged solution, and

converted to mg/L.

3. Data derived from Table 2, and References 12, 17.
Table 4. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Constituents Log-normal

Mean

Effluent

Minimum

Concentration

Effluent

Maximum

Concentration

Effluent

Federal

Acute WQC

Most Stringent

State Acute WQC

Classicals (μg/L)

Total nitrogen 500 None 200 (HI)A

Organics (μg/L)

Bis(2-ethylhexyl)

phthalate

22 BDL 428 None 5.92 (GA)

Metals (μg/L)

Copper

 Dissolved 24.9 BDL 150 2.4 2.4 (CT, MS)

 Total 62.4 34.2 143 2.9 2.5 (WA)

Iron

 Total 370 95.4 911 None 300 (FL)

Nickel

 Total 15.2 BDL 52.1 74.6 8.3 (FL, GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington

Table 5. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

NSTM Ch 555 X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality PMS Cards X

3.2 Rate X X

3.3 Constituents X

3.4 Concentrations MSDS Sheets

4.1 Mass Loadings X

4.2 Environmental Concentrations X X

4.3 Potential for Introducing NonIndigenous Species

X X
Boiler Blowdown

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Boiler Blowdown
Boiler Blowdown

2

2.0 DISCHARGE DESCRIPTION

This section describes boiler blowdown and includes information on: the equipment that

is used and its operation (Section 2.1), general description of the constituents of the discharge

(Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

There are two ways to produce steam for use on ships: conventionally powered boilers

and nuclear powered ship steam generators. Conventionally powered boilers and nuclear

powered ship steam generators are discussed separately in this report.

2.1.1 Conventionally Powered Ship Boiler Blowdown

Boilers are used to produce steam for the majority of surface vessels that have steam

systems. Aboard conventionally powered steam ships, the main propulsion boilers supply steam

at high pressure and temperature to the main propulsion turbines, ship service turbogenerators,

and a host of auxiliary and hotel services. Many gas turbine and diesel-powered ships have

auxiliary or waste heat boilers that produce steam at relatively low pressure for hotel services.

The water supplied to the boiler system (feedwater) is treated to minimize the formation

of scale and to inhibit corrosion in the boiler and boiler system piping. All main propulsion

boilers in the Navy now use the chelant treatment system, which replaced the coordinated

phosphate (COPHOS) treatment system used in main propulsion boilers.1 Main and auxiliary

boilers of the Military Sealift Command (MSC) ships use boiler feedwater chemistry prescribed

by the original equipment manufacturer.2 Auxiliary boilers aboard U.S. Coast Guard (USCG)

vessels are treated in accordance with USCG instructions.3

The process of boiling water to make steam creates higher concentrations of particulates

(the result of corrosion products and sludge forming minerals in the boiler water) and chemicals

in the boiler water. The feedwater that is added to maintain the water level in the boiler (boiler

water) has a lower concentration of chemicals and dilutes the chemical concentrations that

develop during steam generation. Even with careful boiler water treatment management, water

or a water/steam mixture must be periodically released from the boiler to remove particulates and

sludge and to control boiler water chemical treatment concentrations. This process is referred to

as a "boiler blowdown." Blowdowns are accomplished by releasing controlled amounts of boiler

water through sea connections that exit the ship below the waterline.

There are four types of boiler blowdown procedures: surface blowdown, scum

blowdown, bottom blowdown, and continuous blowdown. Surface blowdowns are used to

remove particulates and dissolved materials in the boiler water and to control boiler water

chemistry. If contamination or boiler water treatment chemical over-addition exist, both are

reduced by a surface blowdown. Scum blowdowns are used to remove surface scum. Bottom

blowdowns are used to control the amount of sludge in the boiler water. Continuous blowdowns
Boiler Blowdown

3

are used in all chelant treatment systems to rid the boiler of dissolved metal chelates and

suspended matter.1 All boiler blowdowns are performed in accordance with published guidance.

In all cases, except bottom blowdown, blowdowns can be conducted while the boiler is

operating. Bottom blowdowns for propulsion and auxiliary boilers are conducted only when the

boiler is secured.1 Waste heat boiler bottom blowdowns can be conducted while the boiler is

operating. The four boiler blowdown procedures are conducted in the following ways:

• Surface blowdowns discharge approximately five percent of the total volume of

water in the boiler.4,5 During a surface blowdown, the water level in the boiler is

increased three to four inches, the surface blowdown valve is opened and then

closed when the boiler empties to the normal water level.

• Scum blowdowns discharge approximately one percent of the total volume of

water in the boiler.4,5 During a scum blowdown, the water level in the boiler is

increased by one inch and the surface blowdown valve is opened and then closed

when the boiler empties to the normal water level.1

• Bottom blowdowns discharge approximately ten percent of the total volume of

water in the boiler.4,5 For a bottom blowdown, the water level in the boiler is

increased six inches, the bottom blowdown valve is opened and then closed when

the boiler empties to the normal water level.1

• Continuous blowdowns discharge approximately four percent of the total volume

of water in the boiler per day.5,6 This discharge flows to the bilge of the vessel.

Thus, continuous blowdowns are not considered in the total blowdown volume in

this report and are covered by the Surface Vessel Bilgewater/OWS Discharge

NOD Report.

Ships normally receive steam and electrical power from the pier while they are in port

during extended upkeep periods. However, there are occasions when a steam powered ship can

have a main propulsion boiler operating in port or at anchor for the operation of a turbogenerator

set and to provide hotel service steam. Auxiliary boilers can also be operated in port to provide

hotel service steam. When a boiler is secured in port (laid-up), one of six different methods is

used. Only one of these methods, placing the boiler under a steam blanket, results in boiler

blowdowns. A secured boiler is placed under a steam blanket by keeping steam continuously

applied to the boiler. This steam can be from shore or from an operating boiler on the ship. The

steam blanket excludes oxygen, thereby minimizing the potential for corrosion in the boiler.

Boilers under a steam blanket require a blowdown because the steam applied to the boiler

condenses and increases the boiler's water level. A blowdown returns the water to its proper

level.
Boiler Blowdown

4

2.1.1.1 Chelant Feedwater Treatment

The chelant system adds ethylenediaminetetraacetic acid (EDTA) to the boiler feedwater

in powder form. Only distilled water is used as feedwater in the system. EDTA reacts with

metal ions and forms soluble metal chelates (that do not precipitate) that are removed during

blowdowns.7 This helps reduce boiler scaling by removing calcium and magnesium. Hydrazine

is used to eliminate residual dissolved oxygen in the feedwater, thus inhibiting the corrosive

effects of oxygen in the boiler.

2.1.1.2 Coordinated Phosphate Chemistry

COPHOS systems treat the feedwater to the boiler to reduce boiler scale and corrosion,

thus ensuring boiler system reliability. COPHOS systems also use only distilled water as

feedwater. Chemicals such as trisodium phosphate, disodium phosphate, and sodium hydroxide

are used to precipitate scale forming magnesium and calcium.1

Auxiliary and waste heat boilers on Navy ships use a feedwater chemical treatment

system similar to COPHOS. This system uses disodium phosphate to reduce boiler corrosion

and scale.1

2.1.1.3 Drew Ameroid Chemistry

Drew Ameroid systems treat the feedwater to the boiler with disodium phosphate,

sodium hydroxide, and morpholine to control scale and corrosion in the boiler. Main propulsion

boilers aboard MSC ships, operating at pressures greater than 850 pounds per square inch (psi),

use the Drew Ameroid “Ultra Marine” system of treatment. Main propulsion boilers aboard

MSC ships, operating at pressures less than 850 psi, use the Drew Standard system. Auxiliary

and waste heat boilers on MSC ships use the Drew AKG-100 chemical treatment system.2 Three

different treatment systems are used due to the different operating temperatures of each type of

boiler. The treatment chemicals are the same for all three systems but the proportions of the

chemicals are different depending on the operating temperature of the boiler.

2.1.1.4 USCG Boiler Water Chemistry

There are no steam-powered ships in the USCG; however, many USCG ships have

auxiliary boilers. The preferred method of water treatment in the USCG is a magnetic water

treatment (MWT) system, which does not utilize any chemicals. The MWT system uses a device

that generates a magnetic field in the water stream to help prevent scale formation. Although the

preferred method of treatment is MWT, some USCG ships treat their boiler water with

COPHOS, as defined by Navy guidance.3,8

2.1.2 Nuclear Powered Ship Steam Generator Blowdown

All nuclear-powered ships have steam generators which require periodic blowdowns

(typically about once per week) to maintain safe operation of the system.4 Section 3 and 4
Boiler Blowdown

5

contain discussions of constituents, concentrations, and mass loadings from nuclear powered

ships steam generators, but further information on the process description is classified.

2.1.3 Safety Valve Testing

Testing is necessary to ensure the proper operation of all main and auxiliary boiler safety

valves. Safety valves are installed on each boiler to prevent a boiler rupture in the event of

excessive pressure buildup. They are installed on the upper portion of the boiler and only

discharge steam. Unlike surface and bottom blowdowns, liquid and particulate matter are not

discharged from safety valves. Main propulsion boilers usually have three or four safety valves,

and auxiliary or waste heat boilers have two valves. Periodic testing results in a very short

discharge of steam at full boiler pressure to the atmosphere through an escape pipe on the ship’s

smokestack. This testing must be performed annually for each boiler. Safety valves must also be

tested after each boiler hydrostatic test and whenever a boiler is placed back in service after a

repair.9 For MSC ships, safety valve tests are performed annually during each USCG inspection.

These tests are typically performed in port.

Safety valves are tested to measure the exact pressure at which the safety valves fully lift

and reset. These pressures are defined by the boiler specifications. If the valves do not lift or

reseat at the specified pressure, the test must be repeated after making adjustments to the safety

valves until the exact pressures are met.8 Although steam is discharged at full boiler pressure,

the release is to the atmosphere through an escape pipe on the back of the smokestack and only

small amounts of condensate reach the water. The discharge is in the form of water vapor

released to the atmosphere.

Safety valve testing is also performed on each nuclear powered ship steam generator.

This discharge is identical to safety valve testing on conventionally-powered ship boilers;

however, the discharge exits below the waterline instead of being released to the atmosphere

through an escape pipe. Safety valve testing is performed once every five years on each nuclear

steam generator.

2.2 Releases to the Environment

Boiler and steam generator blowdown discharges are infrequent, of short duration

(seconds), in small volumes (approximately 310 gallons maximum), and at high pressures (up to

1200 psi). The discharge consists of water and steam or sludge-bearing water at elevated

temperatures (above 325° F) and pressures. The discharge can contain metals or boiler water

treatment chemicals. The frequency of the discharge is based on boiler and steam generator

water chemistry and operation and is therefore not predictable. Boiler and steam generator

blowdown discharges are released through hull fittings located below the ship’s waterline

(underwater discharge).
Boiler Blowdown

6

2.3 Vessels Producing the Discharge

Table 1 list the various Navy, MSC, and USCG vessels which generate boiler blowdown

discharge. Ships that use steam for propulsion purposes produce the largest volume of discharge.

These ships use high pressure steam (1200 and 600 psi steam systems) to drive propulsion and

auxiliary equipment. Diesel and gas turbine powered ships can use fuel fired or waste heat

boilers, which operate at pressures up to 150 psi, to generate steam for auxiliary systems.

Vessels that use auxiliary and waste heat boilers are also identified in Table 1. All nuclear

powered ships have steam generators. There are 89 submarines, 3 nuclear powered cruisers, and

8 nuclear powered aircraft carriers that blow down steam generator water.4 Army, Marine Corps,

and Air Force vessels do not utilize steam systems and do not generate this discharge.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Boiler blowdowns can occur when a boiler is operating, after it has been secured, or when

under a steam blanket. Thus, these discharges occur within and beyond 12 nautical miles (n.m.)

from shore. Safety valve testing on nuclear powered ship steam generators only occurs in port.

3.2 Rate

The volume of water in the boiler while steaming (steaming volume) is used to determine

the amount of water/sludge discharged during surface, scum, and bottom blowdowns. These

volumes are listed in Table 1 for each ship class and a sample calculation is provided below.1

Surface blowdowns discharge five percent of the steaming water volume, scum blowdowns

discharge one percent of the steaming water volume, and bottom blowdowns discharge ten

percent of the steaming water volume.1 The number of blowdowns per year within 12 n.m. were

estimated based on a Naval Ship Systems Engineering Station report on boiler blowdown

discharges and revised based on vessel operation within 12 n.m.5,10 These estimates for each

ship category are listed in Table 2. USCG ships with MWT do not use chemical boiler water

treatments, but are included in the blowdown table to include their thermal effect and because

their blowdown contains metal constituents.3 USCG ships with COPHOS treated feedwater are

also included in the table. The majority of USCG vessel operations are typically performed

within 12 n.m. of shore; therefore, the total number of bottom and surface blowdowns is higher

than for Navy vessels.10,11
Boiler Blowdown

7

Boiler Blowdown Volume, gal per year = (discharge)(number of blowdowns)

Where:

discharge (gal) = (Boiler steaming volume, gal)(percent volume discharged per blowdown)

number of blowdowns = number of blowdowns with 12 n.m. per year

The total blowdown discharge volume within 12 n.m. of shore is 570,860 gallons for

Navy main propulsion boilers and 190,348 gallons for Navy auxiliary and waste heat boilers.

Total blowdown discharge volume within 12 n.m. is 205,800 gallons for MSC main propulsion

boilers and 58,500 gallons for MSC auxiliary and waste heat boilers. The total blowdown

discharge volume from USCG auxiliary boilers is 93,600 gallons. The total boiler blowdown

discharge volume within 12 n.m. for all Navy, MSC, and USCG ships is 1,119,108 gallons.

Blowdowns for nuclear powered ships steam generators results in a total volume of

3,615,000 gallons per year.12

The volume discharged from safety valve testing on nuclear powered ships steam

generators is not available. The safety valves are tested once every five years. The available

information is in the form of mass loadings and is discussed in Section 4.1.

3.3 Constituents

Boiler blowdown for conventionally powered ships (e.g., steam, diesel, and gas turbine)

was sampled under the UNDS sampling program. Samples were taken from five ship classes:

the LHD 1 class, the CG 47 class, the LSD 49 class, the T-AO 187 class, and WHEC 378 class.

LHD 1 class uses chelant water treatment; CG 47 and LSD 49 classes use COPHOS water

treatment; T-AO 187 class uses the Drew Ameroid water treatment; and WHEC 378 uses

magnetic water treatment. Boiler samples were analyzed for metals, organics, and classicals

based on the boiler blowdown process, system designs, and analytical data available. In addition,

hydrazine, a boiler treatment chemical, was specifically tested for since it was not in the

aforementioned analyte classes and it was most likely to be present in boiler blowdown. The

results of the sampling are provided in Table 3.

The surface blowdown sample for T-AO-187 class was contaminated at the sampling

station, which is also used by the ship to sample diesel jacket water (a closed loop cooling

system) through common sampling piping.13 The bottom blowdown sample was taken from the

same sampling system, but was completed after the surface blowdown sample was taken and

after additional flushing of the piping system had occurred. The constituent concentrations for

the bottom blowdown sample appear to be similar to other systems sampled. Even though the

surface blowdown constituent concentrations are suspect, they have been used to calculate mass

loadings since no other data is available at this time.

The sampling of nuclear powered ships steam generators was conducted separate from the

sampling performed on conventionally-powered boilers. Constituent data for nuclear powered

ships steam generators is listed in Table 4.12
Boiler Blowdown

8

Of the constituents detected in boiler and steam generator blowdown and safety valve testing

discharges, antimony, arsenic, cadmium, copper, chromium, lead, nickel, selenium, thallium,

zinc, and bis(2-ethylhexyl) phthalate are priority pollutants as defined by the EPA. There are no

constituents in boiler or steam generator blowdown that have been identified as bioaccumulators.

3.4 Concentrations

A summary of the analytical results are presented in Table 3.14 This table shows the

constituents, the log-normal mean or concentration value for single sample data, the frequency of

detection for each constituent, the minimum and maximum concentrations for multiple sample

data, and the mass loadings of each constituent. For the purposes of calculating the log-normal

mean, a value of one-half the detection limit was used for non-detected results. The

concentrations of constituents in nuclear powered ships steam generator blowdowns are provided

in Table 4.15 No constituent concentration data are available for safety valve testing discharges.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria.

Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

Based on the discharge volume estimates developed in Tables 1 and 2 and the log-normal

mean discharge concentrations, mass loadings are presented in Table 3. Table 5 is present in

order to highlight constituents with log-normal mean concentrations that exceed ambient water

quality criteria. A sample calculation of the estimated annual mass loading for copper is shown

here:

Mass Loading for Copper (Total)

Mass Loading = (Net Positive Log-normal Mean Concentration)(Flow Rate)

(203 μg/L)(3.785 L/gal)(590,343 gal/yr)(g/1,000,000 μg)(lb/453.593 g) ≅ 1 lb/yr

The annual mass loadings are reported for the entire fleet. The total annual discharge of

copper is only 7.2 pounds per year for conventionally powered ships which is discharged over a

large geographical area. The largest metal mass loading discharged is iron at 37.5 pounds per

year for conventionally powered boilers which is discharged over a large geographical area.

These loadings include the constituent concentration data from the T-AO 203 surface blowdown

sample even though this sample has been determined to be contaminated.

The annual mass loadings per ship class are reported for the ship classes that the samples
Boiler Blowdown

9

were taken. The total loading of copper for the LHD 1 class (Chelant) is 0.063 pounds, for the

CG 47 and LSD 49 classes (COPHOS) is 1.6 pounds, for the WHEC 378 class (MWT) is 0.008

pounds, and for the T-AO 187 class (Drew) is 0.194 pounds. A sample calculation of the

estimated annual mass loading for copper on the LHD 1 is shown here:

Mass Loading on the LHD 1 for Copper (Total)

 = (Surface Blowdown Log-normal Mean Concentration)(Surface Blowdown Flow Rate) +

 (Bottom Blowdown Log-normal Mean Concentration)(Bottom Blowdown Flow Rate)

 = (203 μg/L)(3.785 L/gal)(32,240 gal/yr)(g/1,000,000 μg)(lb/453.593 g) +

 (40.6 μg/L)(3.785 L/gal)(24,800 gal/yr)(g/1,000,000 μg)(lb/453.593 g) ≅ 0.063 lb/yr

Nuclear powered ships steam generator blowdown mass loadings are listed in Table 6.

The annual mass loading of copper from nuclear powered ships steam generators is

approximately 3.2 pounds per year.

The total annual discharge of copper is only 11.62 pounds for the entire fleet or 0.03

pound per ship per year, which is discharged over a large geographical area. The largest metal

discharge is iron at approximately 38.5 pounds annually for the entire fleet or 0.11 pound per

ship per year.

Since safety valve testing releases only steam, and not liquid nor particulate matter as in

surface and bottom blowdowns, the mass of constituents discharged is expected to be much

smaller than that discharged from boiler blowdown. Table 7 lists the discharges from safety

valve testing from nuclear powered ships steam generators.15 The total mass loadings of all

constituents for all nuclear powered ships for safety valve testing is approximately 4.38 pounds

per year.

4.2 Environmental Concentrations

The constituent concentrations and their corresponding Federal and most stringent state

water quality criteria (WQC) are listed in Tables 8 and 9. These tables include the constituent

concentrations from the T-AO 203. Federal and most stringent state WQC for metals are based

on the dissolved fraction of the metal.

For conventionally powered boilers, copper concentrations for all feedwater treatment

systems exceeded Federal and most stringent state WQC. Iron concentrations for all feedwater

treatment systems exceeded Florida’s WQC. Lead concentrations for all feedwater treatment

systems, except chelant, exceeded Florida’s and Georgia’s WQC but did not exceed the Federal

WQC except for Drew Chemicals feedwater treatment. Nickel concentrations for the chelant,

Drew Chemicals and COPHOS feedwater treatment systems exceeded Federal and most stringent

state WQC. Nickel concentrations for the magnetic water treatment system exceeded the most

stringent state (Florida and Georgia) WQC but did not exceed the Federal WQC. Zinc

concentrations for the chelant, Drew Chemicals and COPHOS feedwater treatment systems

exceeded Federal and most stringent state WQC. Nitrogen (as ammonia, nitrate/nitrite, and total

kjeldahl nitrogen) concentrations for all feedwater treatment systems exceeded most stringent

state WQC. Phosphorous concentrations for all feedwater treatment systems other than Drew
Boiler Blowdown

10

Chemicals for Bottom Blowdown exceeded most stringent state WQC. Bis(2-Ethylhexyl)

phthalate for Drew Chemicals feedwater treatment systems and COPHOS Bottom Blowdown

feedwater treatment system exceeded most stringent state WQC.

For nuclear powered ships steam generators, copper concentrations exceed Federal and

most stringent state WQC. Lead concentrations exceed Florida’s WQC. Nickel concentrations

for the CVN 65 carrier exceed both Federal and most stringent state water quality criteria; all

other ships are below the Federal WQC for nickel, but are above the most stringent state WQC.

Nitrogen (as ammonia, nitrate/nitrite, and total kjeldahl nitrogen) and phosphorous exceed the

most stringent state WQC.

Although the concentrations of copper from boiler blowdowns are greater than water

quality criteria at the point of discharge, the turbulent mixing, pressure of the blowdown

discharge, and small volumes of the blowdown will cause concentrations to decrease rapidly.

The estimated discharge velocity at boiler pressure (1200 psi) is 422 ft/sec. This translates to

discharge rates of 68 gal/sec for a 2.0 inch diameter discharge fitting and 38.74 gal/sec for a 1.5

inch discharge fitting. As a comparison, at 100 psi (auxiliary boiler pressure) the discharge

velocity is 121 ft/sec, which translates to a discharge rate of 11.22 gal/sec from a 1.5 inch

diameter discharge fitting. The LHA1 class ships have the boilers that produce the largest

volume blowdown of 310 gallons. A bottom blowdown from a boiler on an LHA 1 class ship

will only discharge 0.09 grams of copper. Therefore, it is expected concentrations of copper,

lead, and nickel will fall below WQC briefly after discharge.

4.3 Thermal Effects

The potential for boiler blowdown to cause thermal environmental effects was evaluated

by modeling the thermal plume for boiler blowdown generated under conservative conditions and

then comparing the calculated thermal plume to the state thermal plume size requirements. The

thermal effects were modeled by using a batch discharge approach which uses thermodynamic

equations and geometry to estimate the plume size. The steps to estimate the maximum size of

the thermal plume for a given acceptable mixed temperature are given below:16

• calculate the total heat and mass injected in a blowdown;

• calculate the volume of water needed to dilute this mass of water such that the

acceptable mixed temperature is obtained; and

• use geometry to find the region centered on the release point (and assuming a totally

vertically mixed column) that will provide the volume required to reduce the

temperature to the desired temperature criteria.

The discharge is directed downward at a high flow rate and at high velocities. Therefore,

the plume is assumed to expand outward and equally in all directions, thus forming a vertically

cylindrical shape. The velocity of the discharge at the discharge fitting would be 422 ft/sec,

which would put the discharge rate at 68 gal/sec from a 2.0 inch diameter discharge fitting and

38.74 gal/sec from a 1.5 inch diameter discharge fitting. As a comparison, at 100 psig (auxiliary

boiler pressure), the velocity of the discharge would be 121 ft/sec, which would put the discharge
Boiler Blowdown

11

rate at 11.22 gal/sec from a 1.5 inch diameter discharge fitting.

The bottom blowdown discharges from an LHA 1 Class vessel and an AFS 1 Class vessel

were modeled. The LHA 1 uses the chelant treatment system and has main propulsion boilers

(the largest size) and the AFS 1 uses Drew chemistry with average size boilers. They represent a

large boiler blowdown volume and an average boiler blowdown volume. The LHA was modeled

with a batch discharge of 310 gallons at roughly 504 °F (262 °C) through a 2-inch diameter pipe

at the bottom of the ship. The AFS 1 was modeled with a batch discharge of 150 gallons at 495

°F (257 °C) through a 1.5-inch diameter pipe at the bottom of the ship. A sample calculation is

provided at the end of this report. The plume characteristics were compared to thermal mixing

zone criteria for Virginia and Washington State, which are the only two states with established

thermal plume mixing zone criteria. The Washington State thermal regulations require that when

natural conditions exceed 16 °C, no temperature increases will be allowed that will raise the

receiving water temperature by greater than 0.3 °C. The mixing zone requirements state that

mixing zones shall not extend for a distance greater than 200 feet plus the depth of the water over

the discharge point, or shall not occupy greater than 25% of the width of the water body. The

Virginia thermal regulations state that any rise above natural temperature shall not exceed 3 °C.

Virginia’s mixing zone requirements state that the plume shall not constitute more than one-half

of the receiving watercourse. They shall not extend downstream at any time a distance more than

five times the width of the receiving watercourse at the point of discharge.

The assumptions for all the thermal modeling conducted under the UNDS program are

listed below and the results of the thermal modeling for this discharge are summarized in Table

11.16

• The discharge will occur during a simulated slack tide event, using a minimum water

body velocity (0.03 m/s);

• The discharge would occur during the winter months (largest difference in

temperature between the discharge and receiving water temperatures), which results

in the largest thermal plume; and

• The average depth of water at the pier is 40 feet.

Using these assumptions, boiler blowdown discharges from all Navy ships meet Virginia

and Washington State thermal mixing zone criteria, Table 10.16

Safety valve testing from nuclear powered ships steam generators is discharged in small,

intermittent bursts of steam that condenses when reaching the water. The volume of water

discharged is too small to be effectively modeled and the thermal effects are negligible due to the

immediate mixing with surrounding waters.

4.4 Potential for Introducing Non-Indigenous Species

The potential for introducing non-indigenous species is not significant, since the source

of the water is treated freshwater that is heated to high temperatures (over 325 °F) and high

pressures (up to 1200 psi).
Boiler Blowdown

12

5.0 CONCLUSIONS

5.1 Boiler and Nuclear Powered Ship Steam Generators Blowdowns

Boiler and nuclear powered ships steam generator blowdowns have a low potential to

cause an adverse environmental effect because:

• Mass loadings of copper, lead, nickel, bis(2-ethylhexyl) phthalate, ammonia, nitrogen,

and phosphorous are small.

• This discharge rapidly dissipates because it occurs at high flow rates (up to 68 gal/sec)

and it is a small volume (310 gallons or less). Modeling the discharge plume shows

the constituent concentrations and temperature will be below water criteria within a

short distance from the ship for all ship classes that discharge boiler blowdown.

• Boiler blowdown is discharged intermittently throughout the U.S. at Armed Forces

ports, and each individual port receives only a fraction of the total fleetwide mass

loading.

5.2 Safety Valve Testing

Safety valve testing discharge from nuclear powered ships steam generators is released to

the water. However, the total mass discharged is small, only 4.38 pounds of all constituents per

year for all nuclear powered ships combined. The small volumes of the discharge cause the

thermal loading to dissipate in the receiving waters almost immediately after entry. Therefore,

safety valve testing has a low potential to cause an adverse environmental effect.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Sampling

data from four surface ships provided concentrations, and mass loadings were calculated from

the rate and the concentrations. Table 13 shows the source of data used to develop this NOD

report.

Specific References

1. Naval Ships’ Technical Manual (NSTM), Chapter 220, Volume 2, Revision 7, Boiler

Water/Feed Water Test & Treatment. Pages 21-18 to 21-26, 22-1 to 22-51, 29-1 to 29-

41, 30-9 to 30-25, and 31-1 to 31-36. December 1995.
Boiler Blowdown

13

2. Drew Ameroid Marine Division, Ashland Chemical Company. Fax Transmission to

George Stewart on Boiler Control Limits. January 1997.

3. Coast Guard Specification, Chapter 220 Boilers and Force Circulation Steam Generators.

COMDTINST M9000.6B.

4. UNDS Equipment Expert Structured Questions - Nuclear Steam Generator Blowdown.

August 16, 1996. Amy J. Potts NAVSEA 08U.

5. Boiler Blowdown Discharges, Naval Ship Systems Engineering Station Serial No. 9220,

Ser 044C/4060. August 23, 1991.

6. UNDS Equipment Expert Meeting Minutes. Boiler Blowdown. August 16, 1996.

7. Chelant Boiler Feedwater Treatment Implementation - Report of Travel. Naval Surface

Warfare Center, Carderock Division, Serial No. 9220, Ser 622/296. March 10, 1995.

8. Personal Communication Between LT Joyce Aivalotis, USCG, and Leslie Panek, Versar,

Inc., Information on Boiler Water Treatment. April 9, 1997.

9. Naval Ship's Technical Manual (NSTM), Chapter 221, Vol. 1. Boilers. Pages 1 to 6, 12

to 30, 106 to 124, 173, 184 to 187, and 205 to 209. September 15, 1993.

10. Personal Communication Between Leslie Panek, Versar, Inc., and George Stewart, M.

Rosenblatt & Son, Inc., Boiler Blowdown Frequency Within 12 n.m. February 3, 1997.

11. Personal Communication Between LT Joyce Aivalotis, USCG, and Craig Berry, M.

Rosenblatt & Son, Inc., Information on Coast Guard Blowdown Practices. September 12,

1997.

12. NAVSEA Memo Ser. 08U/C97-13818 dated 17 September 1997, Nuclear-Powered Ship

Steam Generator Blowdown Effluent Data for UNDS Discharge Characterization.

13. Personal Communication Between Craig Berry, M. Rosenblatt & Son, Inc., and Paul

Devoe, MSC, on 21 October, 1997.

14. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

15. UNDS Equipment Expert Meeting Action Item Response from Charles Taylor, NAVSEA

08. Provide Information on Safety Valve Testing on Nuclear Ships. May 12, 1997.

16. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed

Services. Versar, Inc. July 3, 1997.

General References
Boiler Blowdown

14

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Blank, David A.; Arthur E. Bock; and David J. Richardson. Introduction to Naval Engineering,

Second Edition. Naval Institute Press, 1985.
Boiler Blowdown

15

Ganic, Ejup N. and Tyler G. Hicks. Essential Engineering Information and Data. McGraw-Hill,

Inc., 1991.

Memorandum for the Director of Environmental Protection/Occupational Safety and Health,

SEA-00T. “Implementation of Vessel Uniform National Discharge Standards for Liquid

Baumeister, Theodore; Eugene A. Avallone; and Theodore Baumeister, III. Marks’ Standard

Handbook for Mechanical Engineers. McGraw-Hill Book Company, 1978.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.

UNDS Ship Database, August 1, 1997.
Boiler Blowdown

16

Calculation Sheet # 1

Thermal Batch Discharge Screening Calculations

A. Assumptions and Given Conditions:

1. Saturated liquid heat loss(specific heat, cp) from 262 °C down to 100 °C emits 0.9 cal/g-°C

2. Water heat loss (specific heat, cp) from 100 down to regulation temperature (7.44°C

Virginia regulation) emits 1 cal/g-°C

3. Heat transfer will occur under conditions of constant pressure

4. Maximum rise in water temperature will be assumed to equal the Virginia regulation of

3°C

5. Ambient temperature is assumed to be 4.44 °C

6. Assume plume will disperse in the shape of a vertical cylinder 4 m in depth

7. Calculations will be based on an LHA 1 blowdown event, therefore:

• Blowdown discharge temperature is assumed to be 262 °C

• Blowdown discharge volume is assumed to be 310 gallons

The heat required to change temperature without a phase change is given by the following

equation:

Q = (m)(cp)(ΔT)

where: Q = heat (calories)

m = mass of water (grams)

cp = constant pressure specific heat (cal/g-°C)

ΔT = change in temperature (°C)

B. Determine Mass of Water in Discharge:

 Initial volume of water in steam form is 310 gallons of water (LHA 1 Blowdown):

 Conversion from gallons of water to mass of water:

(8.343 lbs/gallons)(454 grams/lbs)(310 gallons) = 1.17 x 106 grams

C) High Temperature Water Heat Loss

Q = (m)(cp)(ΔT)

Q = (1.17 x 106 grams)(0.9 cal/gram/°C)(262 - 100 °C)

Q = 170,586,000 calories
Boiler Blowdown

17

D) Water Heat Loss

Q = (m)(cp)(ΔT)

Q = (1.17 x 106 grams)(1 cal/g-°C)(100 - 7.44 °C(Virginia regulation))

Q = 108,295,200 calories

E). Determine Volume of Surrounding Water to Absorb Heat

Calculate the volume of surrounding water required to absorb heat in order to obtain completely

mixed water at the regulatory limit (gallons). Assume that the heat lost by the steam and water in

the discharge is the same as the heat gained by the surrounding water.

 i) Mass of Water Required

Let X= the mass of water required to obtain the mixture, then

ΣQ = (m)(cp)(ΔT)

(108,295,200) + (170,586,000) = (X grams of water)(1 cal/g-°C)(3 °C)

92,960,400 grams = X

Converting to gallons:

(92,960,400 grams)(1 lb/454 grams) (1 gall/8.343lbs) = 24,542 gallons

 ii) Total Volume of Water Required to Meet Virginia Regulations = 24,542 gallons + 310

gallons

= 24,850 gallons

F). Determine Dimensions of Cylinder

The cylinder of water (estimated plume shape) over the water depth to bottom of 4 m (estimated

value based on process knowledge):

Volume = 24,850 gallons x 0.0037854 m3/gallon = 94 m3

Volume = (π)(d2/4)(h) where d = cylinder diameter and h = cylinder height

Rearranging:

d

2

= (vol)(4)/(π)(h)

h=4 m (water depth to bottom)

vol=94 m3

d = 5.5 m (diameter of plume cylinder)
Boiler Blowdown

18

Table 1. Annual Surface, Scum, and Bottom Blowdown Volumes for each Ship Class of the Navy, MSC, and USCG

Armed Force

Owner

Ship Classes with

Main Propulsion

Boilers

Number of

Ships per

Class

Number of

Boilers per

Ship

Boiler Volume

During Steaming

(gallons per boiler)

Surface Blowdown

Volume per year (5% of

boiler steaming volume

in gallons)

Scum Blowdown Volume per

year (1% of boiler steaming

volume in gallons)

Bottom Blowdown

Volume per year (10%

of boiler steaming

volume in gallons)

Total Blowdown

Volume per year

within 12 n.m.

(gallons)

Navy CV 63 3 8 2,200 58,080 10,560 52,800 121,440

CV 59 1 8 2,000 17,600 3,200 16,000 36,800

LPH 2 2 2 1,600 7,040 1,280 6,400 14,720

LPD 7 3 2 1,300 8,580 1,560 7,800 17,940

LPD 4 3 2 1,200 7,920 1,440 7,200 16,560

LPD 14 2 2 1,200 5,280 960 4,800 11,040

LSD 36 5 2 1,600 17,600 3,200 16,000 36,800

AGF 3 1 2 1,200 2,640 480 2,400 5,520

AGF 11 1 2 1,300 2,860 520 2,600 5,980

AO 177 5 2 2,900 31,900 5,800 29,000 66,700

AOE 1 4 4 1,900 33,440 6,080 30,400 69,920

AS 33 1 2 1,500 3,300 600 3,000 6,900

AS 39 3 2 1,400 9,240 1,680 8,400 19,320

LCC 19 2 2 1,400 6,160 1,120 5,600 12,880

LHD 1 4 2 3,100 27,280 4,960 24,800 57,040

LHA 1 5 2 3,100 34,100 6,200 31,000 71,300

 Total Boiler Blowdown for Navy Main Propulsion Boilers =570,860

MSC T-AE 26 8 3 1,500 39,600 NA 36,000 75,600

T-AFS 1 8 3 1,500 39,600 NA 36,000 75,600

T-AGM 22 1 2 1,000 2,200 NA 2,000 4,200

T-AG 194 2 2 1,000 4,400 NA 4,000 8,400

T-AH 19 2 2 1,000 4,400 NA 4,000 8,400

T-AKR 287 8 2 1,000 17,600 NA 16,000 33,600

 Total Boiler Blowdown for MSC Main Propulsion Boilers =205,800

Note: Information obtained from NAVSSES Memo of 23 August, 1991,5 and M. Rosenblatt & Son, Inc.
Boiler Blowdown

19

Table 1. Annual Surface, Scum, and Bottom Blowdown Volumes for each Ship Class of the Navy, MSC, and USCG

Armed Force

Owner

Ship Classes with

Auxiliary or

Waste Heat

Boilers

Number of

Ships per

Class

Number of

Boilers per

Ship

Boiler Volume

During Steaming

(gallons per boiler)

Surface Blowdown

Volume per year (5% of

boiler steaming volume

in gallons)

Scum Blowdown Volume per

year (1% of boiler steaming

volume in gallons)

Bottom Blowdown

Volume per year (10%

of boiler steaming

volume in gallons)

Total Blowdown

Volume per year

within 12 n.m.

(gallons)

NAVY DDG 993 4 3 200 6,000 240 4,800 11,040

CG 47 27 3 100 20,250 810 16,200 37,260

DD 963 31 3 200 46,500 1,860 37,200 85,560

AOE 6 3 2 310 4,650 186 3,720 8,556

LSD 41 8 2 310 12,400 496 9,920 22,816

LSD 49 3 2 310 4,650 186 3,720 8,556

ARS 50 4 3 300 9,000 360 7,200 16,560

 Total Boiler Blowdown for Navy auxiliary and waste heat boilers =190,348

MSC T-AFS 1 8 2 300 6,000 NA 9,600 15,600

T-ARC 7 1 2 300 750 NA 1,200 1,950

T-AGS 26 2 2 300 1,500 NA 2,400 3,900

T-AGS 45 1 2 300 750 NA 1,200 1,950

T-AGS 51 2 2 300 1,500 NA 2,400 3,900

T-AGS 60 4 2 300 3,000 NA 4,800 7,800

T-AO 187 12 2 300 9,000 NA 14,400 23,400

 Total Boiler Blowdown for MSC Auxiliary and Waste Heat Boilers =58,500

USCG WLIC 160 4 2 100 2,400 NA 2,400 4,800

WLR 115 1 2 100 600 NA 600 1,200

WIX 295 1 2 100 600 NA 600 1,200

WAGB 399* 2 2 100 1,200 NA 1,200 2,400

WAGB 290* 1 2 100 600 NA 600 1,200

WHEC 378* 12 2 100 7,200 NA 7,200 14,400

WMEC 210A 5 2 100 3,000 NA 3,000 6,000

WMEC 210B 11 2 100 6,600 NA 6,600 13,200

WLB 180A* 8 2 100 4,800 NA 4,800 9,600

WLB 180B* 2 2 100 1,200 NA 1,200 2,400

WLB 180C* 13 2 100 7,800 NA 7,800 15,600

WLM 157* 9 2 100 5,400 NA 5,400 10,800

WTGB 140* 9 2 100 5,400 NA 5,400 10,800

 Total Boiler Blowdown for Coast Guard Auxiliary Boilers =93,600

 Total Boiler Blowdown for all Ships =1,119,108

Notes:

 Information obtained from NAVSSES Memo of 23 August, 1991,5 and M. Rosenblatt & Son, Inc.

 *=These boilers use magnetic water treatment and do not discharge any chemicals. Their volumes are included because they contribute a thermal load.

 NA=USCG Auxiliary boilers do not have surface or scum blow connections and the MSC does not perform scum blowdowns.
Boiler Blowdown

20

Table 2. Estimated Blowdown Frequencies for Calculation of Total Boiler Blowdown

Volume within 12 n.m.

Armed Force Owner and

Boiler Type

Number of Surface

Blowdowns per year per

boiler within 12 n.m.

Number of Scum

Blowdowns per year per

boiler within 12 n.m.

Number of Bottom

Blowdowns per year per

boiler within 12 n.m.

Navy

Main Propulsion 22 20 10

Auxiliary and Waste Heat 25 10 20

MSC

Main Propulsion 22 20 10

Auxiliary and Waste Heat 25 10 20

USCG*

Auxiliary 60 none 30

Notes:

 Information taken from a NAVSSES Memo of 23 August 1991,5 detailing boiler blowdowns per year and revised

based ship operation, time in port, and operation within 12 n.m.

* = The USCG auxiliary boilers conduct surface blowdowns once per day.

 Most of their activity is performed within 12 n.m. and therefore the number of bottom blowdowns are elevated to

control boiler water chemistry.
Boiler Blowdown

21

Table 3. Summary of Detected Analytes

Constituent Concentration Frequency of Mass Loading

Chelant Surface Blowdown Detection

CLASSICALS (mg/L) (lbs/yr)

Alkalinity 38 1 of 1 102

Ammonia As Nitrogen 0.44 1 of 1 1

Biochemical Oxygen Demand 8 1 of 1 21

Chloride 24 1 of 1 64

Nitrate/Nitrite 0.23 1 of 1 1

Sulfate 12 1 of 1 32

Total Dissolved Solids 290 1 of 1 779

Total Kjeldahl Nitrogen 2.5 1 of 1 7

Total Organic Carbon (Toc) 13 1 of 1 35

Total Phosphorous 0.97 1 of 1 3

Total Sulfide (Iodometric) 7 1 of 1 19

Volatile Residue 184 1 of 1 494

HYDRAZINE (mg/L) (lbs/yr)

Hydrazine 0.009 1 of 1 0.03

METALS (μg/L) (lbs/yr)

Aluminum

 Dissolved 630 1 of 1 2

 Total 494 1 of 1 1

Antimony

 Dissolved 8.3 1 of 1 0.022

 Total 9.7 1 of 1 0.026

Arsenic

 Dissolved 1 1 of 1 0.003

 Total 2.5 1 of 1 0.007

Barium

 Dissolved 1.7 1 of 1 0.005

 Total 2.2 1 of 1 0.006

Boron

 Total 29.6 1 of 1 0.080

Calcium

 Dissolved 51.6 1 of 1 0.1

 Total 114 1 of 1 0.3

Cobalt

 Total 10.7 1 of 1 0.03

Copper

 Dissolved 207 1 of 1 1

 Total 203 1 of 1 1
Boiler Blowdown

22

Constituent Concentration Frequency of Mass Loading

Chelant Surface Blowdown Detection

METALS (Cont'd) (μg/L) (lbs/yr)

Iron

 Dissolved 626 1 of 1 2

 Total 884 1 of 1 2

Magnesium

 Dissolved 179 1 of 1 0.5

 Total 195 1 of 1 1

Manganese

 Dissolved 93.5 1 of 1 0.3

 Total 95.5 1 of 1 0.3

Molybdenum

 Dissolved 17.6 1 of 1 0.05

 Total 18.1 1 of 1 0.05

Nickel

 Dissolved 1,860 1 of 1 5

 Total 1,810 1 of 1 5

Sodium

 Dissolved 40,100 1 of 1 108

 Total 39,300 1 of 1 106

Zinc

 Dissolved 594 1 of 1 2

 Total 601 1 of 1 2

ORGANICS (μg/L) (lbs/yr)

Benzoic Acid 1,230 1 of 1 3
Boiler Blowdown

23

Table 3. Summary of Detected Analytes (Cont’d)

Constituents of Concentration Frequency of Mass Loading

Chelant Bottom Blowdown Detection

CLASSICALS (mg/L) (lbs/yr)

Alkalinity 30 1 of 1 62

Ammonia As Nitrogen 0.11 1 of 1 0.2

Biochemical Oxygen Demand 9 1 of 1 19

Chloride 13 1 of 1 27

Nitrate/Nitrite 0.39 1 of 1 1

Sulfate 7,830 1 of 1 16,183

Total Dissolved Solids 102 1 of 1 211

Total Kjeldahl Nitrogen 0.47 1 of 1 1

Total Organic Carbon (TOC) 12 1 of 1 25

Total Phosphorous 8.4 1 of 1 17

Total Recoverable Oil And Grease 2.45 1 of 1 5

Total Sulfide (Iodometric) 4 1 of 1 8

Volatile Residue 50 1 of 1 103

METALS (μg/L) (lbs/yr)

Aluminum

 Dissolved 430 1 of 1 1

 Total 477 1 of 1 1

Antimony

 Dissolved 4.5 1 of 1 0.009

 Total 5.55 1 of 1 0.011

Arsenic

 Total 1.3 1 of 1 0.003

Barium

 Dissolved 0.75 1 of 1 0.002

 Total 0.85 1 of 1 0.002

Calcium

 Total 94.5 1 of 1 0.2

Copper

 Dissolved 75.9 1 of 1 0.2

 Total 40.6 1 of 1 0

Iron

 Dissolved 222 1 of 1 0.5

 Total 344 1 of 1 1

Manganese

 Dissolved 59.9 1 of 1 0.1

 Total 61.3 1 of 1 0.1

Molybdenum

 Dissolved 16 1 of 1 0.03

 Total 18.2 1 of 1 0.04
Boiler Blowdown

24

Constituents of Concentration Frequency of Mass Loading

Chelant Bottom Blowdown Detection

METALS (Cont'd) (μg/L) (lbs/yr)

Nickel

 Dissolved 1,740 1 of 1 4

 Total 1,835 1 of 1 4

Selenium

 Total 6 1 of 1 0.01

Sodium

 Dissolved 37,700 1 of 1 78

 Total 38,750 1 of 1 80

Thallium

 Dissolved 1 1 of 1 0.002

Zinc

 Dissolved 377 1 of 1 1

 Total 382 1 of 1 1

ORGANICS (μg/L) (lbs/yr)

Benzoic Acid 1,385 1 of 1 3
Boiler Blowdown

25

Table 3. Summary of Detected Analytes (Cont’d)

Constituents of Concentration Frequency of Mass Loading

Magnetic Surface Blowdown Detection

CLASSICALS (mg/L) (lbs/yr)

Alkalinity 30 1 of 1 8

Ammonia As Nitrogen 0.22 1 of 1 0.1

Biochemical Oxygen Demand 5 1 of 1 1

Chemical Oxygen Demand (COD) 13 1 of 1 4

Chloride 17 1 of 1 5

Nitrate/Nitrite 0.78 1 of 1 0.2

Sulfate 36 1 of 1 10

Total Dissolved Solids 132 1 of 1 37

Total Kjeldahl Nitrogen 1 1 of 1 0.3

Total Organic Carbon (TOC) 6 1 of 1 2

Total Phosphorous 0.05 1 of 1 0.01

Total Recoverable Oil And Grease 1.1 1 of 1 0.3

Total Sulfide (Iodometric) 16 1 of 1 4

Total Suspended Solids 7 1 of 1 2

Volatile Residue 49 1 of 1 14

HYDRAZINE (mg/L) (lbs/yr)

Hydrazine 0.007 1 of 1 0.003

METALS (μg/L) (lbs/yr)

Arsenic

 Total 1.3 1 of 1 0.0004

Barium

 Dissolved 41.9 1 of 1 0.01

 Total 42.8 1 of 1 0.01

Boron

 Dissolved 38.3 1 of 1 0.01

 Total 39.9 1 of 1 0.01

Calcium

 Dissolved 28,900 1 of 1 8

 Total 31,300 1 of 1 9

Copper

 Dissolved 15.8 1 of 1 0.004

 Total 64.9 1 of 1 0.02

Iron

 Total 4,170 1 of 1 1

Lead

 Dissolved 22.8 1 of 1 0.006

 Total 193 1 of 1 0.054
Boiler Blowdown

26

Constituents of Concentration Frequency of Mass Loading

Magnetic Surface Blowdown Detection

METALS (Cont'd) (μg/L) (lbs/yr)

Magnesium

 Dissolved 1,270 1 of 1 0.4

 Total 2,220 1 of 1 1

Manganese

 Total 83 1 of 1 0.02

Nickel

 Total 27.6 1 of 1 0.01

Selenium

 Total 32.4 1 of 1 0.01

Sodium

 Dissolved 8,080 1 of 1 2

 Total 5,380 1 of 1 2

Zinc

 Total 53.1 1 of 1 0.01
Boiler Blowdown

27

Table 3. Summary of Detected Analytes (Cont’d)

Constituents of Concentration Frequency of Mass Loading

Magnetic Bottom Blowdown Detection

CLASSICALS (mg/L) (lbs/yr)

Alkalinity 34 1 of 1 10

Ammonia As Nitrogen 1.4 1 of 1 0.4

Chloride 13 1 of 1 4

Nitrate/Nitrite 0.93 1 of 1 0.3

Sulfate 108 1 of 1 30

Total Dissolved Solids 207 1 of 1 58

Total Organic Carbon (TOC) 3.2 1 of 1 1

Total Phosphorous 0.14 1 of 1 0.04

Total Sulfide (Iodometric) 11 1 of 1 3

Total Suspended Solids 40 1 of 1 11

Volatile Residue 174 1 of 1 49

METALS (μg/L) (lbs/yr)

Aluminum

 Total 100 1 of 1 0.03

Arsenic

 Dissolved 1.15 1 of 1 0.0003

Barium

 Dissolved 18.4 1 of 1 0.005

 Total 20.2 1 of 1 0.006

Boron

 Total 26.7 1 of 1 0.007

Calcium

 Dissolved 25,750 1 of 1 7

 Total 27,400 1 of 1 8

Copper

 Total 63.1 1 of 1 0.02

Iron

 Dissolved 116 1 of 1 0.03

 Total 1855 1 of 1 1

Lead

 Dissolved 2.2 1 of 1 0.001

 Total 41.7 1 of 1 0.012

Magnesium

 Dissolved 2,455 1 of 1 1

 Total 3,000 1 of 1 1

Manganese

 Dissolved 15.3 1 of 1 0.004

 Total 40.6 1 of 1 0.01

Nickel

 Total 14.7 1 of 1 0.004

Sodium

 Dissolved 6,385 1 of 1 2

 Total 5,140 1 of 1 1

Zinc

 Total 49.9 1 of 1 0.01
Boiler Blowdown

28

Table 3. Summary of Detected Analytes (Cont’d)

Constituents of Concentration Frequency of Mass Loading

Drew Surface Blowdown Detection

CLASSICALS (mg/L) (lbs/yr)

Alkalinity 945 1 of 1 1,030

Ammonia As Nitrogen 1.8 1 of 1 2

Chemical Oxygen Demand (COD) 2,030 1 of 1 2,213

Chloride 148 1 of 1 161

Nitrate/Nitrite 115 1 of 1 125

Sulfate 66 1 of 1 72

Total Dissolved Solids 2,540 1 of 1 2,769

Total Kjeldahl Nitrogen 10 1 of 1 11

Total Organic Carbon (TOC) 100 1 of 1 109

Total Phosphorous 0.26 1 of 1 0.3

Total Recoverable Oil And Grease 3.5 1 of 1 4

Total Sulfide (Iodometric) 10 1 of 1 11

Total Suspended Solids 45 1 of 1 49

HYDRAZINE (mg/L) (lbs/yr)

Hydrazine 0.1 1 of 1 0.11

METALS (μg/L) (lbs/yr)

Aluminum

 Total 1,140 1 of 1 1

Arsenic

 Dissolved 24.7 1 of 1 0.03

 Total 23.5 1 of 1 0.03

Barium

 Dissolved 13.6 1 of 1 0.01

 Total 60 1 of 1 0.07

Boron

 Dissolved 177,000 1 of 1 193

 Total 175,000 1 of 1 191

Cadmium

 Total 5 1 of 1 0.01

Calcium

 Dissolved 25,400 1 of 1 28

 Total 29,900 1 of 1 33

Copper

 Dissolved 14.8 1 of 1 0

 Total 2,340 1 of 1 3

Iron

 Dissolved 70.9 1 of 1 0.1

 Total 24,800 1 of 1 27
Boiler Blowdown

29

Constituents of Concentration Frequency of Mass Loading

Drew Surface Blowdown Detection

METALS (Cont'd) (μg/L) (lbs/yr)

Lead

 Dissolved 2.9 1 of 1 0.003

 Total 463 1 of 1 1

Magnesium

 Dissolved 178 1 of 1 0.2

 Total 9,140 1 of 1 10

Manganese

 Total 261 1 of 1 0.3

Molybdenum

 Dissolved 10.6 1 of 1 0.01

 Total 10.7 1 of 1 0.01

Nickel

 Total 125 1 of 1 0.1

Sodium

 Dissolved 697,000 1 of 1 760

 Total 660,000 1 of 1 720

Tin

 Total 62.4 1 of 1 0.1

Titanium

 Total 28.3 1 of 1 0.03

Zinc

 Dissolved 47.3 1 of 1 0.1

 Total 7,850 1 of 1 9

ORGANICS (μg/L) (lbs/yr)

2-(Methylthio) Benzothiazole 213 1 of 1 0.2

Bis(2-Ethylhexyl) Phthalate 16 1 of 1 0.02
Boiler Blowdown

30

Table 3. Summary of Detected Analytes (Cont’d)

Constituents of Concentration Frequency of Mass Loading

Drew Bottom Blowdown Detection

CLASSICALS (mg/L) (lbs/yr)

Alkalinity 45 1 of 1 50

Ammonia As Nitrogen 1.5 1 of 1 2

Biochemical Oxygen Demand 8 1 of 1 9

Chloride 49 1 of 1 55

Nitrate/Nitrite 0.32 1 of 1 0.4

Sulfate 4.8 1 of 1 5

Total Dissolved Solids 112 1 of 1 125

Total Kjeldahl Nitrogen 11 1 of 1 12

Total Organic Carbon (TOC) 24 1 of 1 27

Total Recoverable Oil And Grease 2.85 1 of 1 3

Total Sulfide (Iodometric) 10 1 of 1 11

Volatile Residue 81 1 of 1 90

HYDRAZINE (mg/L) (lbs/yr)

Hydrazine 0.007 1 of 1 0.01

METALS (μg/L) (lbs/yr)

Aluminum

 Dissolved 63.4 1 of 1 0.07

Arsenic

 Dissolved 8.3 1 of 1 0.01

Barium

 Dissolved 15.3 1 of 1 0.02

 Total 19.8 1 of 1 0.02

Calcium

 Dissolved 74.3 1 of 1 0.1

 Total 83.6 1 of 1 0.1

Copper

 Dissolved 127 1 of 1 0.1

 Total 153 1 of 1 0.2

Iron

 Dissolved 44.8 1 of 1 0.05

 Total 1,001 1 of 1 1

Lead

 Total 7.35 1 of 1 0.01

Magnesium

 Dissolved 80 1 of 1 0.09

 Total 82 1 of 1 0.09
Boiler Blowdown

31

Constituents of Concentration Frequency of Mass Loading

Drew Bottom Blowdown Detection

METALS (Cont’d) (μg/L) (lbs/yr)

Manganese

 Dissolved 2.95 1 of 1 0.00

 Total 21 1 of 1 0.02

Nickel

 Total 12.6 1 of 1 0.01

Selenium

 Total 12.7 1 of 1 0.01

Sodium

 Dissolved 1,590 1 of 1 2

 Total 1,425 1 of 1 2

Zinc

 Dissolved 97.8 1 of 1 0.1

 Total 277 1 of 1 0.3

ORGANICS (μg/L) (lbs/yr)

Bis(2-Ethylhexyl) Phthalate 13 1 of 1 0.01
Boiler Blowdown

32

Table 3. Summary of Detected Analytes (Cont’d)

Constituents of Log Normal Frequency of Minimum Maximum Mass Loading

COPHOS Surface Blowdown Mean Detection Concentration Concentration

CLASSICALS (mg/L) (mg/L) (mg/L) (lbs/yr)

Alkalinity 97.3 2 of 2 91 104 75

Ammonia As Nitrogen 0.21 2 of 2 0.11 0.39 0.2

Chloride 1.22 1 of 2 BDL 3 1

Hexane Extractable Material 3.87 1 of 2 BDL 6 3

Nitrate/Nitrite 0.45 2 of 2 0.24 0.85 0.3

Sulfate 3.16 1 of 2 BDL 4 2

Total Dissolved Solids 81.0 2 of 2 17 386 62

Total Kjeldahl Nitrogen 0.45 2 of 2 0.28 0.71 0.3

Total Organic Carbon (TOC) 0.87 1 of 2 BDL 1.5 1

Total Phosphorous 11.5 2 of 2 2.6 51 9

Total Recoverable Oil And Grease 8.14 2 of 2 3.4 19.5 6

Total Sulfide (Iodometric) 4.30 1 of 2 BDL 37 3

Total Suspended Solids 11.5 2 of 2 6 22 9

Volatile Residue 67.7 2 of 2 23 199 52

HYDRAZINE (mg/L) (mg/L) (mg/L) (lbs/yr)

Hydrazine 0.01 1 of 2 BDL 0.0019 0.01

METALS (μg/L) (μg/L) (μg/L) (lbs/yr)

Aluminum

 Dissolved 53.7 1 of 2 BDL 103 0.04

Barium

 Total 2.01 1 of 2 BDL 8.1 0.002

Calcium

 Total 36.9 1 of 2 BDL 64.9 0.03

Copper

 Dissolved 103 2 of 2 56.7 187 0.08

 Total 3,390 2 of 2 1,310 8,780 3

Iron

 Dissolved 440 2 of 2 334 579 0.3

 Total 4,327 2 of 2 2,480 7,550 3

Lead

 Dissolved 2.49 1 of 2 BDL 6.2 0.002

 Total 22.4 2 of 2 8.2 61.4 0.017

Magnesium

 Total 91.2 1 of 2 BDL 260 0.070

Manganese

 Dissolved 3.00 2 of 2 1.7 5.3 0.002

 Total 85.7 2 of 2 57.8 127 0.066
Boiler Blowdown

33

Constituents of Log Normal Frequency

of

Minimum Maximum Mass Loading

COPHOS Surface Blowdown Mean Detection Concentration Concentration

METALS (Cont'd) (μg/L) (μg/L) (μg/L) (lbs/yr)

Molybdenum

 Dissolved 3.46 1 of 2 BDL 8 0.003

 Total 2.68 1 of 2 BDL 4.8 0.002

Nickel

 Dissolved 12.3 1 of 2 BDL 19 0.009

 Total 473 2 of 2 253 883 0.4

Sodium

 Dissolved 22,520 2 of 2 6,170 82,200 17

 Total 22,505 2 of 2 6,460 78,400 17

Thallium

 Dissolved 0.77 1 of 2 BDL 1.2 0.001

Tin

 Dissolved 3.49 1 of 2 BDL 6.1 0.003

 Total 3.69 1 of 2 BDL 6.8 0.003

Titanium

 Total 4.15 1 of 2 BDL 6.9 0.003

Zinc

 Dissolved 26.0 2 of 2 23.4 28.8 0.02

 Total 143 2 of 2 67.2 304 0.11

BDL = Below Detection Limit

Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or

more samples with the analyte below detection levels (i.e., “non-detect” samples), estimated analyte concentrations

equivalent to one-half of the detection levels were also used to calculate the log-normal mean. For example, if a

“non-detect” sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the lognormal mean calculation.
Boiler Blowdown

34

Table 3. Summary of Detected Analytes (Cont’d)

Constituents of Log Normal Frequency

of

Minimum Maximum Mass Loading

COPHOS Bottom Blowdown Mean Detection Concentration Concentration

CLASSICALS (mg/L) (mg/L) (mg/L) (lbs/yr)

Alkalinity 44.5 2 of 2 30 66 36

Ammonia As Nitrogen 0.13 2 of 2 0.12 0.14 0.1

Chloride 1.22 1 of 2 BDL 3 1

Hexane Extractable Material 3.26 1 of 2 BDL 6 3

Nitrate/Nitrite 0.44 2 of 2 0.24 0.81 0.4

Sulfate 4.47 1 of 2 BDL 8 4

Total Dissolved Solids 110 2 of 2 80 150 88

Total Kjeldahl Nitrogen 0.20 1 of 2 BDL 0.8 0.2

Total Organic Carbon (TOC) 1.26 1 of 2 BDL 3.2 1

Total Phosphorous 21.8 2 of 2 15.3 31 17

Total Recoverable Oil And Grease 1.34 2 of 2 0.8 2.25 1

Total Sulfide (Iodometric) 3.08 1 of 2 BDL 19 2

Total Suspended Solids 3.46 1 of 2 BDL 6 3

Volatile Residue 42.0 2 of 2 22 80 34

HYDRAZINE (mg/L) (mg/L) (mg/L) (lbs/yr)

Hydrazine 0.01 1 of 2 BDL 0.021 0.01

METALS (μg/L) (μg/L) (μg/L) (lbs/yr)

Aluminum

 Dissolved 58.2 2 of 2 56.6 91.7 0.05

 Total 51.8 1 of 2 BDL 95.8 0.04

Antimony

 Dissolved 3.69 1 of 2 BDL 2.3 0.003

Barium

 Total 1.37 2 of 2 0.85 2.2 0.001

Calcium

 Total 73.5 2 of 2 48.9 200 0.06

Copper

 Dissolved 80.0 2 of 2 47.55 135 0.06

 Total 1,724 2 of 2 662 4,490 1

Iron

 Total 1430 2 of 2 1210 1690 1

Lead

 Dissolved 2.12 2 of 2 1.5 3 0.002

 Total 8.63 2 of 2 4.7 15.9 0.007

Magnesium

 Dissolved 40.4 1 of 2 BDL 70 0.032

 Total 57.1 1 of 2 BDL 102 0.046
Boiler Blowdown

35

Constituents of Log Normal Frequency of Minimum Maximum Mass Loading

COPHOS Bottom Blowdown Mean Detection Concentration Concentration

METALS (Cont’d) (μg/L) (μg/L) (μg/L) (lbs/yr)

Manganese

 Dissolved 2.24 2 of 2 1.7 5.4 0.002

 Total 36.1 2 of 2 30.7 42.5 0.029

Molybdenum

 Dissolved 2.81 1 of 2 BDL 5.25 0.002

 Total 2.79 1 of 2 BDL 5.2 0.002

Nickel

 Dissolved 15.8 2 of 2 12.95 19.4 0.013

 Total 183 2 of 2 119 280 0.1

Sodium

 Dissolved 32,390 2 of 2 19,250 54,500 26

 Total 38,737 2 of 2 28,500 52,650 31

Thallium

 Dissolved 0.65 1 of 2 BDL 1.2 0.001

Tin

 Dissolved 2.85 1 of 2 BDL 6.1 0.002

Titanium

 Total 3.61 1 of 2 BDL 7.9 0.003

Zinc

 Dissolved 8.02 1 of 2 BDL 14.3 0.01

 Total 58.5 2 of 2 46.9 73 0.05

ORGANICS (μg/L) (μg/L) (μg/L) (lbs/yr)

Bis(2-Ethylhexyl) Phthalate 10.8 1 of 2 BDL 42 0.01

BDL = Below Detection Limit

Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or

more samples with the analyte below detection levels (i.e., “non-detect” samples), estimated analyte concentrations

equivalent to one-half of the detection levels were also used to calculate the log-normal mean. For example, if a

“non-detect” sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the lognormal mean calculation.
Boiler Blowdown

36

Table 4. Maximum Concentration of Constituents Detected in Nuclear Powered Ship

Steam Generator Blowdown

Analyte SSN & SSBN CVN 68 Class CVN 65

 Submarines Carriers Only

Metals μg/L μg/L μg/L

Aluminum 40 20 20

Antimony 5 U U

Arsenic 3 20 U

Barium 1 10 U

Cadmium 2 10 10

Calcium 4 70 150

Chromium 2 5 50

Copper 40 150 50

Iron 50 20 80

Lead 10 15 50

Magnesium 1 15 200

Manganese 1 20 20

Molybdenum 20 20 U

Nickel 25 30 90

Silver 1 20 U

Sodium 160,000 160,000 360,000

Tin 2 20 U

Titanium 3 10 U

Zinc 4 10 50

Classicals mg/L mg/L mg/L

Ammonia 0.30 0.30 0.30

Chemical Oxygen Demand 30.00 30.00 30.00

Chloride 0.05 0.05 0.05

Nitrate + Nitrite (as N) 70.00 70.00 70.00

Sulfate 300.00 300.00 300.00

Sulfide 2.00 2.00 2.00

Total Dissolved Solids 1000.00 1000.00 1000.00

Total Kjeldahl Nitrogen 16.00 16.00 16.00

Total Organic Carbon 3.00 3.00 3.00

Total Phosphorous 100.00 100.00 100.00

Total Suspended Solids 2.00 2.00 2.00

Organics mg/L mg/L mg/L

Hydrazine 0.10 0.10 0.10

Note:

 U = Analyte analyzed for but not detected
Boiler Blowdown

37

Table 5. Estimated Annual Mass Loadings of Constituents for Conventionally Powered

Steam Boilers and Auxiliary and Waste Heat Boilers

Constituents of Concentration Estimated Annual

Chelant Surface Blowdown Mass Loading

CLASSICALS (mg/L) (lbs/yr)

Ammonia as Nitrogen 0.44 1

Nitrate/Nitrite 0.23 1

Total Kjeldahl Nitrogen 2.5 7

Total NitrogenA2.8 8

Total Phosphorous 0.97 3

METALS (μg/L) (lbs/yr)

Copper

 Dissolved 207 1

 Total 203 1

Iron

 Dissolved 626 2

 Total 884 2

Nickel

 Dissolved 1,860 5

 Total 1,810 5

Zinc

 Dissolved 594 2

 Total 601 2

Constituents of Concentration Estimated Annual

Chelant Bottom Blowdown Mass Loading

CLASSICALS (mg/L) (lbs/yr)

Ammonia as Nitrogen 0.11 0.2

Nitrate/Nitrite 0.39 1

Total Kjeldahl Nitrogen 0.47 1

Total NitrogenA0.86 2

Total Phosphorous 8.4 17

METALS (μg/L) (lbs/yr)

Copper

 Dissolved 75.9 0.2

 Total 40.6 0

Iron

 Total 344 1

Nickel

 Dissolved 1,740 4

 Total 1,835 4

Zinc

 Dissolved 377 1

 Total 382 1

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Boiler Blowdown

38

Table 5. Estimated Annual Mass Loadings of Constituents for Conventionally Powered

Steam Boilers and Auxiliary and Waste Heat Boilers (Cont'd)

Constituents of Concentration Estimated Annual

Magnetic Surface Blowdown Mass Loading

CLASSICALS (mg/L) (lbs/yr)

Ammonia as Nitrogen 0.22 0.1

Nitrate/Nitrite 0.78 0.2

Total Kjeldahl Nitrogen 1 0.3

Total NitrogenA1.8 0.5

Total Phosphorous 0.05 0.01

METALS (μg/L) (lbs/yr)

Copper

 Dissolved 15.8 0.004

 Total 64.9 0.02

Iron

 Total 4170 1

Lead

 Dissolved 22.8 0.006

 Total 193 0.054

Nickel

 Total 27.6 0.01

Constituents of Concentration Estimated Annual

Magnetic Bottom Blowdown Mass Loading

CLASSICALS (mg/L) (lbs/yr)

Ammonia as Nitrogen 1.4 0.4

Nitrate/Nitrite 0.93 0.3

Total NitrogenA0.93 0.3

Total Phosphorous 0.14 0.04

METALS (μg/L) (lbs/yr)

Copper

 Total 63.1 0.02

Iron

 Total 1855 1

Lead

 Total 41.7 0.012

Nickel

 Total 14.7 0.004

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Boiler Blowdown

39

Table 5. Estimated Annual Mass Loadings of Constituents for Conventionally Powered

Steam Boilers and Auxiliary and Waste Heat Boilers (Cont'd)

Constituents of Concentration Estimated Annual

Drew Surface Blowdown Mass Loading

CLASSICALS (mg/L) (lbs/yr)

Ammonia as Nitrogen 1.8 2

Nitrate/Nitrite 115 125

Total Kjeldahl Nitrogen 10 11

Total NitrogenA125 136

Total Phosphorous 0.26 0.3

METALS (lbs/yr)

Copper

 Dissolved 14.8 0

 Total 2,340 3

Iron

 Total 24,800 27

Lead

 Total 463 1

Nickel

 Total 125 0.1

Zinc

 Total 7,850 9

ORGANICS (μg/L) (lbs/yr)

Bis(2-Ethylhexyl) Phthalate 16 0.02

Constituents of Concentration Estimated Annual

Drew Bottom Blowdown Mass Loading

CLASSICALS (mg/L) (lbs/yr)

Ammonia as Nitrogen 1.5 2

Nitrate/Nitrite 0.32 0.4

Total Kjeldahl Nitrogen 11 12

Total NitrogenA11 12

METALS (μg/L) (lbs/yr)

Copper

 Dissolved 127 0.1

 Total 153 0.2

Iron

 Total 1,001 1

Lead

 Total 7.35 0.01

Nickel

 Total 12.6 0.01

Zinc

 Dissolved 97.8 0.1

 Total 277 0.3

ORGANICS (μg/L) (lbs/yr)

Bis(2-Ethylhexyl) Phthalate 13 0.01

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Boiler Blowdown

40

Table 5. Estimated Annual Mass Loadings of Constituents for Conventionally Powered

Steam Boilers and Auxiliary and Waste Heat Boilers (Cont'd)

Constituents of Log Normal Estimated Annual

COPHOS Surface Blowdown Mean Concentration Mass Loading

CLASSICALS (mg/L) (lbs/yr)

Ammonia as Nitrogen 0.21 0.2

Nitrate/Nitrite 0.45 0.3

Total Kjeldahl Nitrogen 0.45 0.3

Total NitrogenA0.9 0.6

Total Phosphorous 11.5 9

METALS (μg/L) (lbs/yr)

Copper

 Dissolved 103 0.08

 Total 3,390 2.60

Iron

 Dissolved 440 0.34

 Total 4,327 3.32

Lead

 Total 22.4 0.02

Nickel

 Dissolved 12.3 0.01

 Total 472.7 0.36

Zinc

 Total 143 0.11

Constituents of Log Normal Estimated Annual

COPHOS Bottom Blowdown Mean Concentration Mass Loading

CLASSICALS (mg/L) (lbs/yr)

Ammonia as Nitrogen 0.13 0.1

Nitrate/Nitrite 0.44 0.4

Total Kjeldahl Nitrogen 0.2 0.2

Total NitrogenA0.64 0.6

Total Phosphorous 21.8 17

METALS (μg/L) (lbs/yr)

Copper

 Dissolved 80.0 0.06

 Total 1,724 1.38

Iron

 Total 1430 1.14

Lead

 Total 8.63 0.01

Nickel

 Dissolved 15.8 0.01

 Total 183 0.15

ORGANICS (μg/L) (lbs/yr)

Bis(2-Ethylhexyl) Phthalate 10.8 0.01

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Boiler Blowdown

41

Table 6. Mass Loadings for Nuclear Powered Ship Steam Generators

Analyte Discharge

Concentration

from CVN 65

(μg/L)

Discharge

Concentration

from CVN 68

(μg/L)

Discharge

Concentration

from Submarines

(μg/L)

Total Loading for

1 CVN 65 per

year*

(pounds/year)

Total Loading for

7 CVN 68s per

year*

(pounds/year)

Total Loading for 72

SSNs and 17 SSBNs

per year*

(pounds/year)

Total Loading From All

Steam Generator ships and

subs within 12 n.m.

(pounds/year)

Copper 50 150 40 0.09 2.72 0.41 3.22

Lead 50 15 10 0.09 0.27 0.10 0.47

Nickel 90 30 25 0.17 0.54 0.25 0.97

Ammonia 30 30 30 0.06 0.54 0.30 0.90

Nitrate/Nitrite 70,000 70,000 70,000 126 1270 710 2106

Total Kjeldahl

Nitrogen

16,000 16,000 16,000 28.8 290 162 481

Total NitrogenA86,000 86,000 86,000 155 1560 872 2587

Total

Phosphorous

100,000 100,000 100,000 190 1800 1000 2990

Notes:

* = Loadings are based on total volumes within 12 n.m. including 225,000 gallons per year for CVN 65, 310,000 gallons per year for CVN 68 Class, 16,000 gallons

per year each SSN Class vessel, and 4,000 gallons per year for each SSBN Class vessel.

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Boiler Blowdown

42

Table 7. Naval Nuclear Propulsion Summary of Steam Generator Safety

Valve Testing Loadings Per Year (maximum values)

Material Discharged Loading for Submarines

and Cruisers (pounds per

vessel, per year)

Total Loading for all

Submarines and Cruisers

(pounds per year)

Total Loading for

Carriers (pounds per

vessel, per year)

Total Loading for all Carriers

(pounds per year)

Phosphorous (as phosphate) 0.003 0.3 0.006 (CVN 65 only) 0.006

Sulfur (as sulfite and sulfate) 0.000 0 0.008 (CVN 65 only) 0.008

Nitrogen (as nitrite or nitrate) 0.001 0.1 0.000 0

Nitrogen (as amines) 0.03 3 0.08 0.64

Hydrazine 0.000 0 0.001 0.008

Organic Acids 0.001 0.1 0.001 0.008

Sodium 0.002 0.2 0.007 (CVN 65 only) 0.007

 Total 3.7 0.68

Note:

 Information taken from NAVSEA 08 summary information, May 1997.15
Boiler Blowdown

43

Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Constituents of Concentration Federal Acute Most Stringent State

Chelant Surface Blowdown WQC Acute WQC

CLASSICALS (μg/L) (μg/L)

Ammonia as Nitrogen 440 None 6 (HI)A

Nitrate/Nitrite 230 None 8 (HI)A

Total Kjeldahl Nitrogen 2500 None -

Total NitrogenB2800 None 200 (HI)A

Total Phosphorous 970 None 25 (HI) A

METALS (μg/L) (μg/L) (μg/L)

Copper

 Dissolved 207 2.4 2.4 (CT, MS)

 Total 203 2.9 2.5 (WA)

Iron

 Dissolved 626 None 300 (FL)

 Total 884 None 300 (FL)

Nickel

 Dissolved 1,860 74 74 (CA, CT)

 Total 1,810 74.6 8.3 (FL, GA)

Zinc

 Dissolved 594 90 90 (CA, CT, MS)

 Total 601 95.1 84.6 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA= California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Boiler Blowdown

44

Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria

(Cont’d)

Constituents of Concentration Federal Acute Most Stringent State

Chelant Bottom Blowdown WQC Acute WQC

CLASSICALS (μg/L) (μg/L)

Ammonia as Nitrogen 110 None 6 (HI) A

Nitrate/Nitrite 390 None 8 (HI)A

Total Kjeldahl Nitrogen 470 None -

Total NitrogenB860 None 200 (HI)A

Total Phosphorous 8400 None 25 (HI) A

METALS (μg/L) (μg/L) (μg/L)

Copper

 Dissolved 75.9 2.4 2.4 (CT, MS)

 Total 40.6 2.9 2.5 (WA)

Iron

 Total 344 None 300 (FL)

Nickel

 Dissolved 1,740 74 74 (CA, CT)

 Total 1,835 74.6 8.3 (FL, GA)

Zinc

 Dissolved 377 90 90 (CA, CT, MS)

 Total 382 95.1 84.6 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA= California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Boiler Blowdown

45

Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria

(Cont’d)

Constituents of Concentration Federal Acute Most Stringent State

Magnetic Surface Blowdown WQC Acute WQC

CLASSICALS (μg/L) (μg/L)

Ammonia as Nitrogen 220 None 6 (HI) A

Nitrate/Nitrite 780 None 8 (HI)A

Total Kjeldahl Nitrogen 1000 None -

Total NitrogenB1800 None 200 (HI)A

Total Phosphorous 50 None 25 (HI) A

METALS (μg/L) (μg/L) (μg/L)

Copper

 Dissolved 15.8 2.4 2.4 (CT, MS)

 Total 64.9 2.9 2.5 (WA)

Iron

 Total 4,170 None 300 (FL)

Lead

 Total 193 217.2 5.6 (FL, GA)

Nickel

 Total 27.6 74.6 8.3 (FL, GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Boiler Blowdown

46

Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria

(Cont’d)

Constituents of Concentration Federal Acute Most Stringent State

Magnetic Bottom Blowdown WQC Acute WQC

CLASSICALS (μg/L) (μg/L)

Ammonia as Nitrogen 1400 None 6 (HI) A

Nitrate/Nitrite 780 None 8 (HI)A

Total NitrogenB780 None 200 (HI)A

Total Phosphorous 140 None 25 (HI) A

METALS (μg/L) (μg/L) (μg/L)

Copper

 Total 63.1 2.9 2.5 (WA)

Iron

 Total 1855 None 300 (FL)

Lead

 Total 41.7 217.2 5.6 (FL, GA)

Nickel

 Total 14.7 74.6 8.3 (FL, GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

FL = Florida

GA = Georgia

HI = Hawaii

WA = Washington
Boiler Blowdown

47

Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria

(Cont’d)

Constituents of Concentration Federal Acute Most Stringent State

Drew Surface Blowdown WQC Acute WQC

CLASSICALS (μg/L) (μg/L)

Ammonia as Nitrogen 1800 None 6 (HI) A

Nitrate/Nitrite 115,000 None 8 (HI)A

Total Kjeldahl Nitrogen 10,000 None -

Total NitrogenB125,000 None 200 (HI)A

Total Phosphorous 260 None 25 (HI) A

METALS (μg/L) (μg/L) (μg/L)

Copper

 Dissolved 14.8 2.4 2.4 (CT, MS)

 Total 2,340 2.9 2.5 (WA)

Iron

 Total 24,800 None 300 (FL)

Lead

 Total 463 217.2 5.6 (FL, GA)

Nickel

 Total 125 74.6 8.3 (FL, GA)

Zinc

 Total 7,850 95.1 84.6 (WA)

ORGANICS (μg/L) (μg/L)

Bis(2-Ethylhexyl) Phthalate 16 None 5.92 (GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Boiler Blowdown

48

Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria

(Cont’d)

Constituents of Concentration Federal Acute Most Stringent State

Drew Bottom Blowdown WQC Acute WQC

CLASSICALS (μg/L) (μg/L)

Ammonia as Nitrogen 1500 None 6 (HI) A

Nitrate/Nitrite 320 None 8 (HI)A

Total Kjeldahl Nitrogen 11,000 None -

Total NitrogenB11,000 None 200 (HI)A

METALS (μg/L) (μg/L) (μg/L)

Copper

 Dissolved 127 2.4 2.4 (CT, MS)

 Total 153 2.9 2.5 (WA)

Iron

 Total 1,001 None 300 (FL)

Lead

 Total 7.35 217.2 5.6 (FL, GA)

Nickel

 Total 12.6 74.6 8.3 (FL, GA)

Zinc

 Dissolved 97.8 90 90 (CA, CT, MS)

 Total 277 95.1 84.6 (WA)

ORGANICS (μg/L) (μg/L)

Bis(2-Ethylhexyl) Phthalate 13 None 5.92 (GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Boiler Blowdown

49

Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria

(Cont’d)

Constituents of

COPHOS

Log Normal

 Mean

Minimum

Concentration

Maximum

Concentration

Federal

Acute

Most Stringent

State

Surface Blowdown WQC Acute WQC

CLASSICALS (μg/L) (μg/L) (μg/L) (μg/L) (μg/L)

Ammonia as Nitrogen 210 110 390 None 6 (HI) A

Nitrate/Nitrite 450 240 850 None 8 (HI)A

Total Kjeldahl Nitrogen 450 280 710 None -

Total NitrogenB900 None 200 (HI)A

Total Phosphorous 11,500 2600 51,000 None 25 (HI) A

METALS (μg/L) (μg/L) (μg/L) (μg/L) (μg/L)

Copper

 Dissolved 103 56.7 187 2.4 2.4 (CT, MS)

 Total 3,390 1,310 8,780 2.9 2.5 (WA)

Iron

 Dissolved 440 334 579 None 300 (FL)

 Total 4,327 2,480 7,550 None 300 (FL)

Lead

 Total 22.4 8.2 61.4 217.2 5.6 (FL, GA)

Nickel

 Dissolved 12.3 BDL 19 74 74 (CA, CT)

 Total 473 253 883 74 8.3 (FL, GA)

Zinc

 Total 143 67.2 304 95.1 84.6 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA= California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington

BDL = Below Detection Limit
Boiler Blowdown

50

Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria

(Cont’d)

Constituents of

COPHOS

Log Normal

 Mean

Minimum

Concentration

Maximum

Concentration

Federal

Acute

Most Stringent

State

Bottom Blowdown WQC Acute WQC

CLASSICALS (μg/L) (μg/L) (μg/L) (μg/L) (μg/L)

Ammonia as Nitrogen 130 120 140 None 6 (HI) A

Nitrate/Nitrite 440 240 810 None 8 (HI)A

Total Kjeldahl Nitrogen 200 BDL 800 None -

Total NitrogenB640 None 200 (HI)A

Total Phosphorous 21,800 15,300 31,000 None 25 (HI) A

METALS (μg/L) (μg/L) (μg/L) (μg/L) (μg/L)

Copper

 Dissolved 80.0 47.6 135 2.4 2.4 (CT, MS)

 Total 1,724 662 4490 2.9 2.5 (WA)

Iron

 Total 1,430 1,210 1,690 None 300 (FL)

Lead

 Total 8.63 4.7 15.9 217.2 5.6 (FL, GA)

Nickel

 Dissolved 15.8 12.95 19.4 74 74 (CA, CT)

 Total 183 119 280 74.6 8.3 (FL, GA)

ORGANICS (μg/L) (μg/L) (μg/L) (μg/L) (μg/L)

Bis(2-Ethylhexyl)

Phthalate

10.8 BDL 42 None 5.92 (GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA= California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington

BDL = Below Detection Limit
Boiler Blowdown

51

Table 9. Concentrations of Constituents that Exceed Water Quality Criteria for Nuclear

Powered Steam Generators (maximum values) (μg/L)

Analyte Discharge

Concentration

from Submarines

Discharge

Concentration from

CVN 68 Class

carriers

Discharge

Concentration from

CVN 65 Class

carrier

Federal

Acute WQC

Most Stringent

State Acute WQC

Copper 40 150 50 2.4 2.4 (CT, MS)

Lead 10 15 50 210 5.6 (FL, GA)

Nickel 25 30 90 74 8.3 (FL, GA)

Ammonia 30 30 90 None 6 (HI)A

Nitrate/Nitrite 70,000 70,000 70,000 None 8 (HI)A

Total Kjeldahl

Nitrogen

16,000 16,000 16,000 None -

Total

NitrogenB

86,000 86,000 86,000 None 200 (HI)A

Phosphorous 100,000 100,000 100,000 None 25 (HI)A

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

Table 10. Summary of Thermal Effects of Boiler Blowdown Discharge

Ship

Modeled

Discharge

Temp (°F)

Discharge

Volume

(gals)

Ambient

Water

Temp (°F)

Predicted

Plume

Width and

Length

(m)*

Allowable

Plume

Width (m)

Allowable

Plume

Length (m)

Predicted

Plume

Depth (m)

Washington State (0.3°C Δ T)

LHA 1 503 310 50 19.7 400 73 4

AFS 1 495 150 50 13.4 400 73 4

Virginia (3.0°C Δ T)

LHA 1 503 310 40 5.5 3,200 32,000 4

AFS 1 495 150 40 3.7 3,200 32,000 4

Note: The discharge was modeled such that the resultant plume is cylindrical shaped, therefore

the plume width and length are equal.
Boiler Blowdown

52

Table 11. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Thermal Effects X

4.4 Potential for Introducing NonIndigenous Species

X
Catapult Water Brake Tank and Post Launch Retraction Exhaust

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Catapult Water Brake Tank and Post Launch Retraction Exhaust
Catapult Water Brake Tank and Post Launch Retraction Exhaust

2

2.0 DISCHARGE DESCRIPTION

This section describes the catapult water brake tank and post launch retraction exhaust

and includes information on: the equipment that is used and its operation (Section 2.1), general

description of the constituents of the discharge (Section 2.2), and the vessels that produce this

discharge (Section 2.3).

2.1 Equipment Description and Operation

Every Navy aircraft carrier is equipped with four steam catapults for launching aircraft.

High pressure steam from the catapult wet steam accumulator is used to operate each catapult.

Each catapult has a dedicated water brake tank and catapult steam exhaust piping. During each

catapult cycle, lubricating oil is applied to the catapult power cylinder. Different amounts of

lubricating oil are applied depending on catapult model. Mod 2 catapults use more lubricating

oil per catapult cycle than Mod 1 catapults (see Section 3.2.1).

Catapults are operated every time an aircraft is launched and for testing purposes.

Catapults are normally tested after an aircraft carrier is built, before an aircraft carrier is sent out

on deployment, and after major repairs and overhauls. Catapult testing before deployments is

called “no-load” testing because there is no load applied to the catapult. Catapult testing after

building and after major repairs and overhauls is called “dead-load” testing because a weight is

applied to the catapult to simulate the weight of an aircraft. During catapult testing, lubricating

oil is supplied to the catapult’s power cylinder in the same fashion as during aircraft launching

operations.

The forward motion of the catapult piston is stopped by means of a water brake that is

supplied by high pressure water from the water brake tank. As the catapult operates, the

lubricating oil is carried into the water brake and subsequently into the water brake tank. During

the retraction of the catapult piston, the steam left in the power cylinder and a small amount of

residual oil are discharged overboard through the catapult exhaust piping. A smaller fraction of

the residual oil also leaks by the catapult cylinder sealing strips and into the catapult trough.

Catapult trough discharge is addressed in a separate NOD report on deck runoff.

2.1.1 Catapult Water Brake Tank

The catapult water brake tank supplies freshwater to the catapult water brake, which is

used to stop the forward motion of the catapult piston. Water from the catapult water brake tank

is injected into the water brake during each catapult cycle at approximately 1,300 gallons per

minute (gpm) using two 650-gpm pumps.1 When the catapult piston enters the water brake, it

forces water from the water brake into the upper portion of the water brake tank. Figure 1

provides an illustration.

The oil used to lubricate the catapult power cylinder conforms to both SAE J1966, Grade

60 and Military Specification MIL-L-6082E grade 1100 standards.2 During each catapult cycle,

oil is sprayed onto the internal surface of the catapult power cylinder. As the catapult piston
Catapult Water Brake Tank and Post Launch Retraction Exhaust

3

travels down the catapult power cylinder, lubricating oil is carried with the catapult piston into

the water brake.1 Over the course of multiple launches, and because water is recirculated through

the catapult water brake and the water brake tank, oil builds up in the water brake tank. The oil

accumulates on the surface of the water in the water brake tank in the form of an oil-water

emulsion. Heat is added to the water from heat accumulated in the oil, the action of the pistons,

and by conduction from the steam-heated catapult piston. The accumulated oil also inhibits

cooling at the surface of the water brake tank. Consequently, the water temperature rises.

Excessive water temperature adversely affects the catapult water brake performance.

To prevent excessive water temperatures in the water brake tank, the accumulated oil is

periodically skimmed. The water brake tank is equipped with an oil-skimming funnel and a 2.5-

inch pipe for draining the oil from the tank. Fresh cool water is added to the water brake tank via

a freshwater fill line to raise the water level in the tank, thus causing the floating oil and oil/water

mixture to flow into the skimming funnel. The funnel drain piping discharges the oil and

oil/water mixture overboard above the waterline. The contents of the water brake tank drain

overboard until the liquid level falls below the top of the drain funnel. Oil accumulation in the

water brake tank is directly related to the number of catapult cycles. During aircraft launch

operations, the water brake tank is skimmed on an as-needed basis.3

As mentioned previously, aircraft carriers perform no-load catapult tests before leaving

port on deployment and dead-load tests after building, major repairs and overhauls. The number

of no-load and dead-load tests, however, do not generate enough lubricating oil in the water

brake tank to require that the tank to be skimmed within 12 nautical miles (n.m.).

2.1.2 Post-Launch Retraction Exhaust

During the post-launch retraction of the catapult piston, the expended steam and residual

oil from the catapult power cylinder walls are discharged overboard below the water line through

copper/nickel piping. The exhaust steam exits the catapult power cylinder at approximately 350

o

F (i.e., the operating temperature of the catapults) and cools and condenses as it flows through

the exhaust piping overboard. The temperature of the final discharge is estimated to be 200 oF.

2.2 Releases to the Environment

2.2.1 Water Brake Tank

Discharge from the water brake tank is released overboard above the water line and

consists of freshwater, lubricating oil, and small amounts of metals introduced by the catapult

systems.

2.2.2 Post-Launch Retraction Exhaust

Discharge from the post-launch retraction exhaust is released overboard below the water

line and consists of condensed steam with lubricating oil and small amounts of metals from the

catapult.
Catapult Water Brake Tank and Post Launch Retraction Exhaust

4

2.3 Vessels Producing the Discharge

The Navy’s aircraft carriers are the only armed forces vessels that generate this discharge.

Of the 11 aircraft carriers that are homeported in the United States, eight are equipped with Mod

1 catapults, and the three newest aircraft carriers are equipped with Mod 2 catapults. There are a

total of 12 aircraft carriers

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

3.1.1 Catapult Water Brake Tank

The catapult water brake tank discharge is generated on an as-needed basis during aircraft

carrier flight operations, which occur beyond 12 n.m. from shore.1,4,5 Catapult testing, which

occurs within 12 n.m. does not generate a sufficient quantity of oil in the water brake tank to

require discharge. In addition, OPNAVINST 5090.1B prohibits oil from being discharged within

12 n.m. of shore, including the oil contained in this discharge.

Because this discharge does not occur within 12 n.m. of shore, it is not discussed further

in this report.

3.1.2 Post-Launch Retraction Exhaust

The post-launch retraction exhaust discharge is generated during all catapult operations

including aircraft launching and catapult testing. Because catapults are operated within 12 n.m.

of shore during no-load/dead-load testing, the post-launch retraction exhaust discharge occurs on

a limited basis within 12 n.m.

3.2 Rate

The discharge for the post-launch retraction exhaust discharge consists of condensed

steam and the residual oil from lubricating the catapult power cylinders. During each catapult

cycle, approximately 1,000 pounds of water from the wet accumulator are flashed to steam to

drive the catapult piston down the flight deck, and 0.415 gallon of oil is injected onto the catapult

power cylinder wall for Mod 1 catapults, and 0.83 gallon of oil for Mod 2 catapults.6 Based on

operating experience, approximately 890 pounds of water and 0.10 gallon of oil from Mod 1

catapults, or 0.42 gallon of oil from Mod 2 catapults, are discharged overboard during each
Catapult Water Brake Tank and Post Launch Retraction Exhaust

5

catapult cycle.6

An aircraft carrier performs approximately 50 no-load catapult tests per year.3 Therefore,

all 11 aircraft carriers homeported in the United States perform approximately 550 no-load test

shots per year. At a fleet-wide average rate of 0.19 gallon of oil (weighted average discharge of

0.10 gallon for Mod 1 catapults and 0.42 gallon for Mod 2 catapults) and 890 pounds of steam

condensate per each catapult test, the annual fleet-wide discharge of oil and condensed steam

from no-load catapult tests within 12 n.m. is approximately 105 gallons of oil and 490,000

pounds of condensed steam.

Major catapult overhauls and modifications are not normal occurrences for aircraft

carriers. In general, one to two aircraft carriers annually undergo a major overhaul or

modification that requires 60 dead-load catapult test shots to recertify the catapult. Assuming

that on average, the catapults on 1.5 carriers are overhauled each year (i.e., six catapults), an

estimated 360 dead-load catapult test shots are performed annually fleet-wide within 12 n.m.

Thus, an estimated 69 gallons of oil (at a rate of 0.19 gallon per test) and 320,000 pounds of

steam condensate (at a rate of 890 pounds per test) are discharged annually from dead-load

catapult testing.

Thus, 174 gallons of oil and 810,000 pounds of condensed steam (~97,000 gallons) are

discharged annually, fleetwide, from post-launch retraction exhaust during no-load and dead-load

catapult testing.

3.3 Constituents

The post-launch retraction exhaust discharge consists of steam and condensed steam with

associated non-organic metal constituents and lubricating oil. The lubricating oils are comprised

primarily of higher chain (C17 and higher) paraffins and olefins.7,8 Another UNDS discharge,

Steam Condensate Discharge, is similar to the condensed steam discharge from the catapult

retraction stroke, with the exception of the oil content. The Steam Condensate NOD Report

analyzes steam condensate originating from shore-based facilities. The steam condensate from

ship heating supplied from shore facilities consists primarily of condensed steam that is generally

collected and pumped or drained overboard. The discharge from the catapult retraction exhaust

is steam, condensed steam, and oil that is vented overboard under pressure. The condensed

steam portion of both discharges will, however, be somewhat similar. Based on the data

presented in that report, nitrogen (as ammonia, nitrate/nitrite, and total nitrogen), phosphorous,

and the priority pollutants antimony, arsenic, benzidine, bis(2-ethylhexyl) phthalate, cadmium,

copper, lead, nickel, selenium, thallium, and zinc can be present in the condensed steam in postlaunch retraction exhaust. There are no known bioaccumulators in this discharge.

3.4 Concentrations

Approximately 890 pounds of catapult condensed steam and 0.19 gallon of oil is

discharged during each catapult cycle. The density of water at 70 oF (i.e., ambient temperature) is

8.32 pounds per gallon (lbs/gal) or 0.998 kilograms per liter (kg/l) and the oil density is of 7.32
Catapult Water Brake Tank and Post Launch Retraction Exhaust

6

lbs/gal or 0.878 kg/l. Therefore, the concentration of oil in the exhaust discharge is

approximately 1,560 mg/L. The calculation is presented below:

Where the subscripts o refer to oil and w refer to water.

Table 1 shows the concentrations of the priority pollutants identified in the Steam

Condensate NOD Report. It is assumed that the same constituents would be found in the

condensed steam from the catapult retraction exhaust in similar concentrations to those found in

steam condensate originating from facilities.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria.

Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

As estimated in Section 3.2, approximately 174 gallons of oil are discharged annually

from no-load and dead-load testing in post-launch retraction exhaust. This results in an annual

fleet-wide mass loading of 1,275 pounds (based on a conversion factor of 7.33 pounds of

oil/gallon).

Of the non-oil constituents in the 810,000 pounds of catapult condensed steam generated

annually fleet wide from post-launch retraction exhaust (see Section 3.2) less than one pound of

pollutants are estimated to be discharged from no-load and dead-load testing. The mass loadings

were estimated using the following equation:

4.2 Environmental Concentrations

The condensed steam and oil from the post-launch retraction exhaust exits the ship via

the exhaust piping. The estimated concentration of oil in the discharge is approximately 1,560

mg/L. This value exceeds the most stringent state water quality criteria (WQC), which is

Florida’s 5 mg/L criterion (Table 2). Concentrations this high are likely to cause a sheen in the

[(0.19 galo ) (7.32 lbso /galo )(453,590 mg/lb)] /[(890 lbsw )(gal/8.32 lbsw )(3.785 l/gal)] =

≅1560 mg/l

(log-normal mean conc. μg/l)(g/1,000,000 μg) (lbs/453.593 g) (annual volume l/yr) ≅ mass

loading (lbs/yr)
Catapult Water Brake Tank and Post Launch Retraction Exhaust

7

receiving waters.

Assuming the concentrations of the priority pollutants shown in Table 1 are

representative of condensed steam discharged in post-launch retraction exhaust discharge, there

would be four priority pollutants - benzidine, bis(2-ethylhexyl) phthalate, copper, and nickel -

discharged in excess of Federal and/or the most stringent state WQC. Two other constituents,

nitrogen (as ammonia, nitrate/nitrite, and total nitrogen) and phosphorous, exceed the most

stringent state WQC. Table 2 shows the concentrations of these constituents and the applicable

WQC.

4.3 Thermal Effects

The thermal effects of the post-launch retraction exhaust were screened for potential

adverse effects to determine if the resulting thermal plume exceeded water quality criteria for

temperature.9 Based upon the evaluation of the exhaust discharge, the thermal effects rapidly

dissipate within a short distance of the point of discharge.9 Under the most stringent criteria

(e.g., Washington State), the resulting plume from the post-launch retraction exhaust is estimated

to be approximately 20 feet in diameter and extends to approximately 12 feet in depth.9 These

dimensions are within limits established for Washington.9

4.4 Potential for Introducing Non-Indigenous Species

During catapult launch operations, seawater is not transported. Therefore, there is no

potential for transporting non-indigenous species.

5.0 CONCLUSIONS

The catapult water brake tank discharge does not occur within 12 n.m. because flight

operations are not conducted within this zone. Therefore, this discharge has no potential to cause

an adverse environmental effect within 12 n.m.

The post-launch retraction exhaust has a potential for adverse environmental effect

because significant amounts of oil are discharged at high concentrations during the short duration

of the discharge event. The high concentrations exceed water quality criteria and discharge

standards. The high concentrations of oil are likely to cause an oil sheen.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. process

information and assumption were used to estimate the rate of discharge. Based on this estimate

and on the reported concentration of oil constituents, the concentration of the oil constituents in

the environment resulting from this discharge were then estimated. Table 3 shows the source of

the data used to develop this NOD report.
Catapult Water Brake Tank and Post Launch Retraction Exhaust

8

Specific References

1. UNDS Equipment Expert Meeting Minutes - Catapult Discharges. July 26, 1996.

2. Commander, Naval Sea Systems Command. Memorandum Ser PMS312B/1760.

Pollution of Coastal Waters Attributed to Catapult Lube Oil. December 16, 1997.

3. Commander Naval Air Forces, U.S. Atlantic Fleet. Responses to TYCOM Questionnaire.

M. Rosenblatt & Son, Inc. May 20, 1997.

4. UNDS Equipment Expert Meeting Minutes - Catapult Trough, Water Brake Tank, Jet

Blast Deflector and Arresting Cables. August 22, 1996.

5. UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Steam

Blowdown Discharge. August 20, 1997.

6. Steve Opet, NAWCADLKE. Information on Volume of Water and Temperature for

Catapult Shots. April 11, 1997. Clarkson Meredith, Versar, Inc.

7. Perry and Chilton. Chemical Engineers’ Handbook. Fifth Ed. McGraw Hill. 1953

8. Patty's Industrial Hygiene and Toxicology, 3rd Ed., Volume IIB. G.D. and F.E. Clayton,

Editors. New York: 1981.

9. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed

Services. Versar, Inc. July 3, 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Catapult Water Brake Tank and Post Launch Retraction Exhaust

9

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

U.S. Navy Technical Manual NAVAIR 51-15ABD-3, Illustrated Parts Breakdown Catapults.

December 1, 1986.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, pg 15366. March 23, 1995.

Committee Print Number 95-30 of the Committee of Public Works and Transportation of the

House of Representatives, Table 1.

Jane's Information Group, Jane's Fighting Ships. Capt. Richard Sharpe, Ed. Sentinel House:

Surrey, United Kingdom, 1996.

UNDS Phase I Sampling Data Report, Volumes 1-13. October 1997.
Catapult Water Brake Tank and Post Launch Retraction Exhaust

10

Table 1. Estimated Post-Launch Retraction Exhaust Discharge Constituents,

Concentrations, and Mass Loadings Based Upon Steam Condensate Sampling Data

Constituents

Concentrations (μg/L)

 Log Normal

Rate of Wet

Accumulator

Fleet-Wide Mass

Loading

From Steam Condensate1 Mean2 Range Discharge (l/yr)3(pounds/yr)

Antimony

 Total 7.13 BDL - 26.8 367,000 5.8 x 10-3

Arsenic

 Total 0.74 BDL - 2.3 367,000 6.0 x 10-4

Cadmium

 Total 2.86 BDL - 6.1 367,000 2.3 x 10-3

Copper

 Dissolved 13.4 BDL - 49.0 367,000 1.1 x 10-2

 Total 20.1 BDL - 91.0 367,000 1.6 x 10-2

Lead

 Dissolved 3.58 BDL - 12.7 367,000 2.9 x 10-3

 Total 4.38 BDL - 18.9 367,000 3.5 x 10-3

Nickel

 Dissolved 10.3 BDL - 22 367,000 8.3 x 10-3

 Total 11.6 BDL - 34.7 367,000 9.4 x 10-3

Selenium

 Total 2.87 BDL - 3.5 367,000 2.3 x 10-3

Thallium

 Dissolved 1.18 BDL - 13.3 367,000 9.5 x 10-4

Zinc

 Dissolved 13.94 7.15 - 21.9 367,000 1.1 x 10-2

 Total 11.35 BDL - 23.0 367,000 9.2 x 10-3

Ammonia as Nitrogen 180 120 - 370 367,000 1.4 x 10-1

Nitrate/Nitrite 440 300 - 810 367,000 3.4 x 10-1

Total Kjeldahl Nitrogen 1240 NA 367,000 9.6 x 10-1

Total Phosphorous 90 BDL - 270 367,000 7.1 x 10-2

Benzidine 32.8 BDL - 73.5 367,000 2.7 x 10-2

Bis(2-ethylhexyl) phthalate 19.4 BDL - 112 367,000 1.6 x 10-2

The constituents listed above are those expected to be found in the wet accumulator discharge. BDL denotes below

detection limit.

1. Constituents listed are the priority pollutants detected in steam condensate samples.

2. Highest of the dissolved and total log average values.

3. This value is the product of the annual condensed steam released from no-load and dead-load testing (810,000

pounds combined) cited in Section 3.2.1 and the conversion factors 0.0175 cubic foot/pound (inverse density of

water at 200 oF), 7.4805 gallons/cubic foot, and 3.785 liters/gallon.

Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or

more samples with the analyte below detection levels (i.e., “non-detect” samples), estimated analyte concentrations

equivalent to one-half of the detection levels were also used to calculate the log-normal mean. For example, if a

“non-detect” sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the lognormal mean calculation.
Catapult Water Brake Tank and Post Launch Retraction Exhaust

11

Table 2. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Post-Launch Retraction Exhaust Condensed Steam Discharge

Constituent Log-Normal Mean

Concentration (μg/L)

Federal Acute WQC (μg/L) Most Stringent State

Acute WQC (μg/L)

Oil 1,560,000 visible sheen 1 /15,00025,000 (FL)

Ammonia as

Nitrogen

180 None 6 (HI)A

Nitrate/Nitrite 440 None 8 (HI)A

Total Nitrogen 1240 None 200 (HI)A

Total Phosphorous 90 None 25 (HI)A

Benzidine 32.8 None 0.000535 (GA)

Bis(2-Ethylhexyl)

Phthalate

19.4 None 5.92 (GA)

Copper 3

 Dissolved 13.4 2.4 2.4 (CT, MS)

 Total 20.1 2.9 2.5 (WA)

Nickel 3

 Dissolved 10.3 74 74 (CA, CT)

 Total 11.6 74.6 8.3 (FL, GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

1

 Discharge of Oil. 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen on

receiving waters.

2

 International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as

implemented by the Act to Prevent Pollution from Ships (APPS).

3

 Assumes the constituents and their concentrations in this discharge are similar in concentration to the constituents

found in steam condensate that originates from shore facilities.

CA = California

CT = Connecticut

FL = Florida

GA = Georgia

HI= Hawaii

MS = Mississippi

WA = Washington
Catapult Water Brake Tank and Post Launch Retraction Exhaust

12

Table 3. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents X X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Thermal Effects X

4.4 Potential for Introducing NonIndigenous Species

X
Catapult Water Brake Tank and Post Launch Retraction Exhaust

13

Fig. 1 Water Brakes
Catapult Wet Accumulator Discharges

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Catapult Wet Accumulator Discharges
Catapult Wet Accumulator Discharges

2

2.0 DISCHARGE DESCRIPTION

This section describes the catapult wet accumulator discharges and includes information

on: the equipment that is used and its operation (Section 2.1), general description of the

constituents of the discharge (Section 2.2), and the vessels that produce this discharge (Section

2.3).

2.1 Equipment Description and Operation

Aircraft are launched from aircraft carriers using a steam driven catapult piston. Steam is

supplied to a catapult from a 16,000-gallon pressure vessel known as a catapult wet accumulator.

The wet accumulator contains a mixture of steam and saturated water at a high temperature and

pressure. As steam is released from the accumulator for a launch, the pressure drops in the

accumulator and water flashes to steam producing additional steam. The pressure from the steam

against the catapult piston forces the piston to accelerate rapidly, providing sufficient force and

velocity to launch the aircraft.1 Each aircraft carrier has four catapults.

Approximately 8,000 gallons of boiler feedwater are used when initially filling an

accumulator on conventionally-powered aircraft carriers. Similarly, 8,000 gallons of steam

generator feedwater are used when initially filling an accumulator on nuclear-powered aircraft

carriers. Feedwater from boilers and steam generators contain similar constituents. Feedwater is

distilled fresh water from the ship’s water generating plant. Steam from the ship’s main steam

plant is used to maintain the water level and to pressurize the accumulator to between 450 and

520 pounds per square inch (psi).2 The steam is provided to the accumulator through a manifold

that distributes the steam below the water level in the accumulator. Figures 1 and 2 show a

schematic of a wet accumulator and its associated external and internal piping.

The continuous addition and condensation of steam during flight operations, while

standing by for flight operations, or during catapult testing causes the water level in an

accumulator to rise. Blowdowns are required to keep water level within operating limits,

normally 40 to 50 inches of water.2 Blowdowns to control water levels release up to 5 inches

(750 gallons) of water from the accumulator.3 The water is blown down through a pipe that is

connected to the bottom of the accumulator and discharged overboard approximately 18 to 24

inches below the waterline through a seachest.1

Blowdowns also can be performed using a steam blowdown valve that is connected at the

top of the accumulator. This valve can also be used to control the water level in the accumulator;

however, its primary function is to reduce the pressure in the accumulator to atmospheric

pressure prior to emptying the accumulator. Wet accumulators are emptied before major

maintenance or if an aircraft carrier will be in port for 72 hours or longer.2,4 To empty the wet

accumulator, multiple blowdowns are performed over an extended period of time (up to 12

hours) to slowly reduce pressure and to minimize noise.
Catapult Wet Accumulator Discharges

3

2.2 Releases to the Environment

Aircraft carrier catapult wet accumulators are initially charged with boiler or steam

generator feedwater and fed with steam from the steam plant as the catapult is operated. The

feedwater is treated with chemicals at specified rates to prevent scaling and corrosion, including

oxygen scavengers and chelating agents. Unlike boilers, wet accumulators are unfired pressure

vessels and scale and corrosion are not significant problems. Therefore, the treatment chemicals

in the initial charge of boiler feedwater are expected to be unreacted and discharged from the wet

accumulator during flight operations and blowdowns.5,6,7,8 With each blowdown, the

concentration of feed chemicals is reduced in the accumulator, and the concentration in the

accumulator tank approaches that of steam condensate.

Some of the steam supplied to the accumulator is used directly to drive the catapult, while

some condenses to distilled water, diluting the initial charge of boiler feedwater in the wet

accumulator. The steam supplied to the wet accumulator is pure water with very minor amounts

of constituents derived from the materials of construction of the steam generating and handling

systems (e.g., copper nickel piping). In addition, there may be small amounts of water treatment

chemicals. The constituents are expected to be similar to those found in steam condensate based

on process knowledge of similarities in the materials of construction. The amounts of these

constituents in steam directed to the wet accumulator are expected to be less than the amounts

contained in steam condensate discharge because steam condensate discharge is produced from

steam that has longer contact times with piping and equipment of the shore steam system. For

the purposes of this NOD report, condensed wet accumulator steam was considered similar to

steam condensate. Steam condensate is a separate UNDS discharge and is described in detail in

the Steam Condensate NOD report.

2.3 Vessels Producing the Discharge

Only the Navy’s aircraft carriers produce this discharge. There are 12 aircraft carriers in

the Navy, one of which is homeported in Japan. All of the remaining 11 aircraft carriers are

homeported in the United States.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Wet accumulator blowdowns occur as a result of flight operations and catapult testing.

Blowdowns resulting from flight operations occur outside 12 nautical miles (n.m.). Blowdowns

resulting from catapult tests occur within 12 n.m.
Catapult Wet Accumulator Discharges

4

Wet accumulators are emptied before major maintenance or when a ship will be in port

for greater than 72 hours. In both cases, aircraft carriers empty the accumulator outside 12 n.m.

when returning to port. However, after major maintenance has been performed on a wet

accumulator or catapult, the wet accumulator is refilled and the entire catapult system tested in

port. If the aircraft carrier will be in port for more than 72 hours after testing is complete, the

accumulator will be emptied in port.4

3.2 Rate

Before each test, the wet accumulator is filled with approximately 8,000 gallons of boiler

or steam generator feedwater. Based on process knowledge, approximately 50 catapult shots are

performed during each test. Wet accumulators are emptied before major maintenance of the

catapult system or if an aircraft carrier will be in port for 72 hours or longer. After catapult

testing, the wet accumulator is blown down or drained of the original 8,000 gallons of feedwater

and approximately 1,100 gallons of condensed steam accumulated from the catapult shots. To

empty the wet accumulator, multiple blowdowns are performed over an extended period of time

(up to 12 hours) to reduce pressure slowly and minimize noise. A blowdown of 5 inches of water,

which is equivalent to approximately 750 gallons of water, typically takes about 5 minutes to

complete.

Each of the 11 aircraft carriers in the fleet has four wet accumulators, which are tested as

described above approximately once every 1.5 years. Thus, fleetwide, approximately 235,000

gallons of water are discharged within 12 n.m. each year from wet accumulators:

Similarly, approximately 33,000 gallons of condensed steam are discharged annually:

3.3 Constituents

The constituents in the feedwater that is used to fill a wet accumulator include disodium

phosphate, ethylenediaminetetraacetic acid (EDTA), and hydrazine. None of these constituents

are priority pollutants. Based on the analysis of steam condensate samples, the priority pollutants

antimony, arsenic, benzidine, bis(2-ethylhexyl) phthalate, cadmium, copper, lead, nickel,

selenium, thallium, and zinc can be present in the condensed steam in the wet accumulator.

There are no known bioaccumulators in this discharge.

Wet Accumulator Annual Blowdown Volume (gallons per year) = (Wet accumulator feedwater

capacity) (4 accumulators per carrier) (11 carriers) / (Frequency of test) = (8,000 gallons/accumulator)(4

accumulators/carrier)(11 carriers) / (1.5 years) = 235,000 gallons per year

33,000 gallons/year = (1,125 gallons/accumulator)(4 accumulators/carrier)(11 carriers) / (1.5 years)
Catapult Wet Accumulator Discharges

5

3.4 Concentrations

Table 1 shows the concentrations of the constituents identified in Section 3.3. The table

is divided into two sections. The first section shows the concentrations of the pollutants detected

in steam condensate. As explained in Section 2.2, the steam supplied to the wet accumulator is

expected to contain lower concentrations of these constituents than measured in steam

condensate samples. Nevertheless, to be conservative, the concentrations of these constituents in

steam condensate were used to estimate the mass loadings from the condensed steam portion of

wet accumulator discharge.

The second section of Table 1 shows specified concentrations of boiler feedwater

treatment chemicals. As stated in section 2.2 and to be conservative, these chemicals were

assumed to be discharged at these concentrations in the boiler feedwater portion of wet

accumulator discharge.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality standards. In

Section 4.3, the thermal effect of this discharge is discussed. In Section 4.4, the potential for the

transfer of non-indigenous species is discussed.

4.1 Mass Loading

Table 1 shows the estimated mass loadings of the constituents in wet accumulator

discharge that were identified in Section 3.3. Fleet-wide annual mass loadings (in pounds/year)

were estimated by multiplying the concentration of the constituents (in micrograms per liter

(μg/L)) by the discharge rates from Section 3.2 (converted to liters per year) and the appropriate

conversion factors using the following equation:

The annual volume for this discharge is a combination of the volume of steam condensed

per year (33,000 gallons) and the volume of feedwater (235,000 gallons) charged into the wet

accumulator.

As shown in Table 1, the amounts of priority pollutants discharged annually from the

condensed steam portion of wet accumulator discharge are significantly less than one pound.

Because the constituent concentrations used to calculate the mass loadings are actually from

steam condensate discharge -- thought to overestimate pollutant concentrations in wet

(log-normal mean conc. μg/l)(g/1,000,000 μg) (lbs/453.593 g) (annual volume l/yr)

≅ mass loading (lbs/yr)
Catapult Wet Accumulator Discharges

6

accumulator steam -- the actual mass loadings in the condensed steam portion of wet

accumulator discharge are probably lower. The annual, fleet-wide mass loadings of the boiler

feedwater chemicals in wet accumulator discharge are estimated to be 195, 49, and 49 pounds for

disodium phosphate, EDTA, and hydrazine, respectively.

4.2 Environmental Concentrations

Wet accumulator discharge is released directly to the environment. The estimated

concentrations of the constituents in the discharge are shown in Table 1. The constituent

concentrations for the condensed steam portion of the discharge shown in Table 1 are considered

to be maximums for the reasons previously cited.

Based upon a comparison of the concentrations of all constituents in Table 1 to Federal

and most stringent state water quality criteria (WQC), the concentrations of nitrogen (as

ammonia, nitrate/nitrite, and total nitrogen), phosphorous, benzidine, bis(2-ethylhexyl) phthalate,

copper, and nickel shown in Table 1 are discharged in excess of Federal and/or the most stringent

state WQC. Table 2 shows the comparison of concentrations of those constituents that exceed

WQC to their WQC.

The discharge will not significantly increase concentrations of pollutants near the ship.

To empty the wet accumulator, multiple blowdowns are performed over an extended period of

time (up to 12 hours) to reduce pressure slowly and minimize noise, so concentrations near the

ship will be lower because the incremental discharges allow concentrations to dissipate.

4.3 Thermal Effects

The potential for catapult wet accumulator discharge to cause thermal environmental

effects was evaluated by modeling the thermal plume using mixing conditions that would

produce the largest plume and then comparing the thermal plume to state thermal discharge

requirements. Thermal effects of catapult wet accumulator discharge were modeled using

thermodynamic equations to estimate the plume size and temperature gradients in the receiving

water body.9 The model was run under conditions that would estimate the maximum plume size

(e.g., minimal wind, slack water) for a wet accumulator on an aircraft carrier. The plume

characteristics were compared to thermal mixing zone criteria for Virginia and Washington

State.9 Of the five states that have a substantial presence of Armed Forces vessels, only Virginia

and Washington have established thermal mixing zone dimensions. Other coastal states require

that thermal mixing zones be established on a case-by-case basis. Based upon this analysis, the

discharge of a wet accumulator pierside does not cause thermal effects that exceed any known

state criteria.9

4.4 Potential for Introducing Non-Indigenous Species

Given that the water in wet accumulators is condensed steam at a temperature of 460oF,

and the charging feedwater to the wet accumulators is distilled fresh water from the ship’s water

generating plant, there is no potential for the transport of non-indigenous species.
Catapult Wet Accumulator Discharges

7

5.0 CONCLUSION

Catapult wet accumulator discharge has a low potential to cause an adverse

environmental effect because:

• Mass loadings of benzidine, bis(2-ethylhexyl) phthalate, nitrogen, phosphorous,

copper, and nickel within 12 n.m. are small, less than a pound per year combined

fleetwide, discharged at concentrations near WQC;

• The discharge contains small quantities of water treatment chemicals;

• Resulting contributions to environmental concentrations from the discharge are

expected to be insignificant because the discharge event is spread out over

multiple blowdowns that allow concentrations to dissipate; and

• The discharge of a wet accumulator pierside does not cause thermal effects that

exceed known state thermal mixing zone criteria.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources were obtained. Process

information and assumptions were used to estimate the rate of discharge. Based on this estimate

and on concentration requirements of boiler feedwater chemistry, the concentrations of feedwater

chemistry constituents resulting from this discharge were then estimated. Table 3 shows the

sources of data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Discharges,

Round Two Meeting. March 14, 1997.

2. UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Steam

Blowdown. August 20, 1996.

3. Joe Hungerbuhler, NSWCCD-SSES 9223. Information on Catapult Wet Accumulator

Blowdown. November 1, 1996. Clarkson Meredith, Versar, Inc.

4. Commander, Naval Air Force, U.S. Atlantic Fleet. Responses to TYCOM Questionnaire.

M. Rosenblatt and Son, Inc. May 20, 1997.

5. Naval Ship Systems Engineering Station, Memorandum - Boiler Blowdown Discharges.

August 23, 1991.
Catapult Wet Accumulator Discharges

8

6. UNDS Equipment Expert Meeting Structured Questions - Nuclear Steam Generator

Blowdown/Safety Valve Testing Effluents. NAVSEA 08U, August 16, 1996.

7. NSWC, Carderock Division, Memorandum - Chelant Boiler Feedwater Treatment

Implementation. March 18, 1995.

8. Naval Ships’ Technical Manual (NSTM), Chapter 220, Volume 2, Revision 7, Sections

21 and 22. Boiler Water/Feed Water Test & Treatment. December 1995.

9. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed

Services. Versar, Inc. July 3, 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
Catapult Wet Accumulator Discharges

9

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Steve Opet, NAWCADLKE. Information on Average Number of Shots per Catapult. April 4,

1997. Clarkson Meredith, Versar, Inc.

UNDS Equipment Expert Meeting Minutes - Aircraft Launch Equipment and Recovery

Equipment Discharge Meeting. August 22, 1996.

Jane's Information Group, Jane's Fighting Ships, Capt. Richard Sharpe, Ed. Sentinel House:

Surrey, United Kingdom, 1996.

Patty's Industrial Hygiene and Toxicology, 3rd Edition, George D. and Florence E. Clayton, Ed.

John Wiley & Sons: New York, 1981.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Catapult Wet Accumulator Discharges

10

Figure 1. Wet Accumulator Steam, Feed, and Blowdown Piping
Catapult Wet Accumulator Discharges

11

Figure 2. Wet Accumulator Internal Steam Charging Manifold
Catapult Wet Accumulator Discharges

12

Table 1. Estimated Catapult Wet Accumulator Discharge Constituents, Concentrations,

and Mass Loadings Based Upon Steam Condensate Sampling Data

Constituents

Concentrations (μg/l)

 Log Normal Concentration

Rate of Wet

Accumulator

Fleet-Wide Mass

Loading

From Steam Condensate1 Mean2 Range Discharge (l/yr)3(pounds/yr)

Antimony

 Total 7.13 BDL - 26.8 125,000 2.0 x 10-3

Arsenic

 Total 0.74 BDL - 2.3 125,000 2.0 x 10-4

Cadmium

 Total 2.86 BDL - 6.1 125,000 7.9 x 10-4

Copper

 Dissolved 13.4 BDL - 49.0 125,000 3.7 x 10-3

 Total 20.1 BDL - 91.0 125,000 5.5 x 10-3

Lead

 Dissolved 3.58 BDL - 12.7 125,000 9.9 x 10-4

 Total 4.38 BDL - 18.9 125,000 1.2 x 10-3

Nickel

 Dissolved 10.3 BDL - 22 125,000 2.8 x 10-3

 Total 11.6 BDL - 34.7 125,000 3.2 x 10-3

Selenium

 Total 2.87 BDL - 3.5 125,000 7.9 x 10-4

Thallium

 Dissolved 1.18 BDL - 13.3 125,000 3.3 x 10-4

Zinc

 Dissolved 13.94 7.15 - 21.9 125,000 3.8 x 10-3

 Total 11.35 BDL - 23.0 125,000 3.1 x 10-3

Ammonia as Nitrogen 180 120 - 370 125,000 4.9 x 10-2

Nitrate/Nitrite 440 300 - 810 125,000 1.2 x 10-1

Total Nitrogen 1240 NA 125,000 3.4 x 10-1

Total Phosphorous 90 BDL - 270 125,000 2.5 x 10-2

Benzidine 32.8 BDL - 73.5 125,000 9.0 x 10-3

Bis(2-ethylhexyl) phthalate 19.4 BDL - 112 125,000 5.3 x 10-3

From Boiler Feedwater Treatment Chemicals4

Disodium phosphate 100,000 NA 888,000 196

Ethylenediaminetetraacetic

acid (EDTA)

25,000 NA 888,000 49

Hydrazine 25,000 NA 888,000 49

The constituents listed above are those expected to be found in the wet accumulator discharge. BDL denotes below detection

limit.

1. Constituents listed are the priority pollutants detected in steam condensate samples.

2. Highest of the dissolved and total log average values.

3. This value is the product of the annual wet accumulator discharge cited in section 3.2 and the conversion factor of 3.785

liters per gallon.

4. These concentrations are based on the specified rates of application of these constituents to boiler feedwater to inhibit

scaling and corrosion.

Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or more samples

with the analyte below detection levels (i.e., “non-detect” samples), estimated analyte concentrations equivalent to one-half of the

detection levels were also used to calculate the log-normal mean. For example, if a “non-detect” sample was analyzed using a

technique with a detection level of 20 mg/L, 10 mg/L was used in the log-normal mean calculation.
Catapult Wet Accumulator Discharges

13

Table 2. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Catapult Wet Accumulator Discharge

Constituent Log-Normal Mean

Concentration (μg/L)

Federal Acute WQC (μg/L) Most Stringent State

Acute WQC (μg/L)

Ammonia as Nitrogen 180 None 6 (HI)A

Nitrate/Nitrite 440 None 8 (HI)A

Total Nitrogen 1240 None 200 (HI)A

Total Phosphorous 90 None 25 (HI)A

Benzidine 32.8 None 0.000535 (GA)

Bis(2-Ethylhexyl)

Phthalate

19.4 None 5.92 (GA)

Copper 1

 Dissolved 13.4 2.4 2.4 (CT, MS)

 Total 20.1 2.9 2.5 (WA)

Nickel 1

 Total 11.6 74.6 8.3 (FL, GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

1

 Assumes the constituents and their concentrations in this discharge are similar in concentration to the constituents

found in steam condensate that originates from shore facilities.

CT = Connecticut HI = Hawaii

FL = Florida MS = Mississippi

GA = Georgia WA = Washington

Table 3. Data Sources

Data Sources

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X X

3.2 Rate X

3.3 Constituents X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Thermal Effects X

4.4 Potential for Introducing NonIndigenous Species

X
Cathodic Protection

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Cathodic Protection
Cathodic Protection

2

2.0 DISCHARGE DESCRIPTION

This section describes the discharge associated with cathodic protection and includes

information on: the equipment that is used and its operation (Section 2.1), general description of

the constituents of the discharge (Section 2.2), and the vessels that produce this discharge

(Section 2.3).

2.1 Equipment Description and Operation

Nearly all vessels use some form of cathodic protection to prevent metal hulls and

underwater structures from corroding. The Armed Forces (Navy, Air Force, Army, Military

Sealift Command (MSC)) and the U.S. Coast Guard (USCG) use cathodic protection, in

conjunction with corrosion-resistant coatings, to protect their vessels. This combination provides

an optimal corrosion control system which utilizes the advantages of each individual system.

While coatings are the primary means of controlling corrosion, nearly all coatings have some

defects (whether from wear or damage) and some components are uncoated by design (e.g.,

propellers). Cathodic protection could, in theory, be used alone to protect a hull and other

external underwater structures, but the number of anodes for sacrificial-anode-based systems or

power requirements for Impressed Current Cathodic Protection (ICCP)-based systems would

increase greatly. When used in conjunction with coatings, cathodic protection reduces the effects

of wear and failure of the paint systems and reduces the associated required repairs and

maintenance. Without cathodic protection systems, vessels would be subject to severe corrosion

(i.e., dissolution and discharge of hull material) of the underwater hull and appendages resulting

in either increased underwater repairs and maintenance or more frequent dry-docking of the

vessels for renewal of underwater hull paint systems.

The two types of cathodic protection used by the Armed Forces -- sacrificial anodes and

ICCP systems -- are illustrated schematically in Figure 1. Small boats and craft which have

wood, aluminum, fiberglass or rubber (inflatable) hulls do not require cathodic protection to

protect these materials from corrosion (but may have small anodes located near the propellers for

their protection). Also, many of the small boats and craft with steel hulls that utilize sacrificial

anodes are stored out of the water on trailers or blocks.

2.1.1 Sacrificial Anodes

When sacrificial anodes are used, the anodes are physically connected (e.g., by bolts or

welding) to ship components and structures. As shown in Figure 2, an electrochemical cell is

formed between the anode and the cathode (the structure to which the anode is connected)

through the surrounding electrolyte (usually seawater). The anode is preferentially corroded or

“sacrificed”, producing a flow of electrons to the cathode which results in a reduction or

elimination of corrosion at the cathode. Large ships with mandatory dry-dock inspection and

overhaul intervals of less than three years, as well as the most boats and small craft, use

sacrificial anodes to protect the underwater hull. The numbers and sizes of the anodes are

determined by the wetted surface area of the hull, the planned replacement cycle of the anodes,

and the corrosion history of the vessel.
Cathodic Protection

3

Sacrificial anodes continually corrode when immersed and require routine replacement to

maintain sufficient mass and surface area for adequate cathodic protection. On average, zinc

anodes are estimated to be completely consumed every six years.1,2,3,4 The consumption rate

depends on the service environment, the condition of the hull coating, and the location of the

anode on the hull.

Zinc anodes are used almost exclusively by DoD and USCG vessels for sacrificial

cathodic protection of hulls,5 with aluminum anode usage limited to a few (less than 5) Navy

submarines. Naval Sea Systems Command (NAVSEA) continues to evaluate aluminum anodes

for use on other Navy ships and their use requires prior NAVSEA authorization and design

review.5

Aluminum anodes have 3.4 times the current capacityi of zinc anodes due primarily to

differences in valence (3 for aluminum vice 2 for zinc) and density.5 The lower density of

aluminum anodes also results in aluminum anodes occupying more volume than zinc anodes of

the same weight. Development of the military specification6 for aluminum anodes has only

recently been completed although commercial aluminum anodes have been available for many

years. Aluminum anodes are not as readily available as zinc anodes and are more prone to

passivate (become inactive) than zinc anodes, but may be considered for use where the benefits

of increased current capacity and reduced weight offset the disadvantages of increased volume.

Sacrificial anodes used to prevent corrosion of heat exchangers, condensers, evaporators,

sewage collection, holding and transfer tanks, ballast tanks, bilges, sea chests, sonar domes, or

other non-hull areas or components are not addressed in this NOD report, but in NOD reports

describing these discharges (e.g. Seawater Cooling Discharge and Clean Ballast).

2.1.2 ICCP Systems

The Armed Forces also use ICCP systems (see Figure 3) to protect hulls in lieu of

sacrificial anodes. ICCP systems are employed when the wetted surface of the hull and other

underwater components requiring cathodic protection is large or a controllable system is

required.5

 ICCP systems protect against corrosion using direct current (DC) from a source within

the ship in lieu of current provided by a sacrificial anode. Except for the source of current, the

mechanism of protection is identical for sacrificial anode cathodic protection and ICCP (see

Figure 1). The current is passed through platinum-plated tantalum anodes designed for a 20-year

service life. A silver/silver chloride (Ag/AgCl) reference electrode (control reference cell)

measures the electrical potential of the hull and is used to determine how much current is

required from the ICCP system to provide adequate cathodic protection.

 

i Current capacity, a sacrificial anode material property, is the total current available per unit mass over the life of

the anode, commonly expressed as (amp-hr/kg) or (amp-yr/lb). The current capacity for zinc and aluminum anodes

is 812 amp-hr/kg and 2759 amp-hr/kg, respectively. Current capacity should not be confused with the maximum

output current of an anode, which is a function of the anode material, anode surface area, system resistance, and

driving potential. For most common types of zinc anodes used on underwater hulls, the maximum output current is

approximately 0.4 amps per anode.5
Cathodic Protection

4

2.2 Releases to the Environment

2.2.1 Sacrificial Anodes

As the zinc or aluminum anode is consumed (oxidized), ionized zinc or aluminum is

released into the receiving waters. Water at the cathode (such as the steel hull) is reduced

forming hydroxyl (OH-) ions which combine with the zinc or aluminum ions to form zinc or

aluminum hydroxide if excess oxygen is present. Another possible reaction produces hydrogen

at the cathode, especially in deaerated seawater.

In addition, oxidants (primarily chlorine and bromine) could also be produced in

secondary reactions because of the electrical potential of the anode. Precise reactions and

probabilities will vary with conditions in the seawater environment. However, the relatively low

electrical potential of the sacrificial anode (-1.05 volts average) compared with ICCP systems (-

15volts Ag/AgCl reference electrode) will result in less oxidant being formed. Those oxidants

which are formed will rapidly react with the surface of the sacrificial anode to form zinc or

aluminum chloride, or react with oxidant-demanding substances in the water. Due to the

relatively low electrical potential of sacrificial anodes and the rapid reactive nature of the anode

surface, the possible generation of oxidants by sacrificial anodes will not be considered further.

2.2.2 ICCP Systems

ICCP systems operate at higher electrical potentials than sacrificial anodes and

consequently can generate more oxidants. Precise primary and secondary reactions of oxidants

will vary with seawater conditions such as salinity, temperature, ammonia content, pH, etc., but

will primarily consist of various chlorinated and brominated substances. These substances

include: hypochlorous and hypobromous acids, hypochlorite and hypobromite, chloro- and

bromo-organics, chloride, bromide, chloramines, and bromamines. These substances are

commonly called Chlorine-Produced Oxidants (CPO) when associated with brackish or

seawater.7

The general reactions related to CPO are initiated when chlorine (Cl2) is generated by the

reduction of chloride ions (Cl-) in seawater. The chlorine reacts to form hypochlorous acid

(HOCl) and the hypochlorite ion (OCl-) in the water. These two compounds, along with the

chlorine, are referred to as free chlorine. Free chlorine, the standard disinfection agent used in

water treatment facilities, undergoes four important types of reactions in natural waters: (1)

oxidation of reduced substances and subsequent conversion to chloride; (2) reaction with

ammonia and organic amines to form chloramines, collectively called combined chlorine; (3)

reaction with bromide to form hypobromous acid (HOBr) and hypobromite (OBr-), called free

bromine; and (4) reaction with organics to form chloro-organics. Free bromine reacts in a

manner similar to free chlorine, oxidizing reduced substances or forming bromamines (combined

bromine) or bromo-organics. Most common analytical methods for quantifying CPO measure

the sum of all free and combined chlorine and bromine in solution, but do not measure the

chloro- and bromo-organics.
Cathodic Protection

5

Human health issues are a concern for some of these chlorinated hydrocarbons, which are

suspected carcinogens and pose a concern when found in significant quantities in drinking water.

However, these small quantities of chloro- and bromo-organics are produced only in brackish or

seawater. These materials are not generated by ICCP systems in freshwater ports due to the low

concentrations of chlorides and bromides. Most drinking water is drawn from groundwater or

freshwater sources. Armed Forces vessels that are homeported in seawater or brackish water

ports are not docked near drinking water intakes. Given the limited quantity and the location of

discharge, exposure to drinking water intakes is unlikely. These chlorinated hydrocarbons are

not separately addressed further in this NOD report.

2.3 Vessels Producing the Discharge

Table 1 shows the vessels that produce this discharge.1,8,9,10 The table identifies whether

vessels use sacrificial anodes or ICCP systems. Boats and craft of the Navy, Naval Auxiliary,

USCG, MSC, Army, and Air Force use sacrificial anodes for cathodic protection. Of the

approximately 5000 miscellaneous small boats and craft, approximately 30% are expected to

have steel hulls and therefore cathodic protection. The remaining 70% are assumed to have hulls

constructed of fiberglass, wood, aluminum, or other non-ferrous materials which do not require

cathodic protection.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Discharge from cathodic protection systems associated with a vessel’s hull occurs

continuously whenever the vessel is waterborne. This discharge occurs both within and beyond

12 nautical miles (n.m.).

3.2 Rate

3.2.1 Sacrificial Anodes

The discharge from sacrificial anodes is characterized by a mass flux instead of a

volumetric flow rate because the “constituents” enter the receiving water directly (via corrosion

and dissolution). The following factors were used to calculate the average mass flux (also called

corrosion/dissolution) of sacrificial anodes while pierside and underway:

1. Based on underwater hull inspections and maintenance records one-half of an
Cathodic Protection

6

anode is consumed after three years.4

2. The corrosion/dissolution rate while underway is approximately three- to fivetimes the pierside rate based on field studies.3,11 A factor of four is used for

calculations. Probable explanations for this phenomenon are: (1) the fully aerated

seawater produced by a moving hull increases reaction rates; and (2) more

corrosion products and other deposits and surface films are removed due to the

erosion forces of the seawater.

3. Based on the actual vessel movement data available, the average Navy vessel

spends approximately 176 days in port (pierside) and transits to or from port

(underway) approximately 11 times each year.12 The average MSC vessel spends

approximately 94 days in port and performs approximately six transits. Vessel

movement estimates for the Air Force, Army, and USCG vessels were made

based on operational knowledge (see Table 2). The vessel movement data for the

Navy was used in dissolution calculations since it results in the highest period of

time that vessels are in port.

Using the above factors, the corrosion/dissolution rates were calculated for zinc anodes as

shown in Calculation Sheet 1. At pierside, the rate was calculated to be 7.4 x 10-6 (lb zinc/lb

anode)/hr, and underway, it was 3.0 x 10-5 (lb zinc/lb anode)/hr. These rates can also be

expressed as a function of wetted hull area using a conversion factor based on information

presented in Table 2 which lists the vessels incorporating sacrificial anode cathodic protection.

This relationship is stated as follows:

Average density of zinc anodes = (total amount of anodes) / (total wetted surface area)

 = (1,860,000 lb) / (10,826,000 ft2) = 0.17 lb/ft2

This results in average pierside and underway zinc generation rates of 1.3 x 10-6 and 5.1 x

10-6 (lb zinc/square foot of underwater surface area)/hr.

Shipboard experience with aluminum anodes is limited, but as with zinc anodes the

corrosion/dissolution rate of the anode is primarily determined by factors such as the area of bare

metal requiring protection. Rates for aluminum anodes can therefore be calculated based on

process knowledge and the previously calculated generation rates for zinc anodes. Using the

ratio of current capacity of aluminum to zinc anodes, generation rates for aluminum anodes are

2.2 x 10-6 (lb aluminum/lb anode)/hr pierside, and 8.8 x 10-6 (lb aluminum/lb anode)/hr

underway.

Current capacity ratio = (aluminum anode current capacity) / (zinc anode current capacity)

= (2759 amp-hr/kg) / (812 amp-hr/kg) = 3.4
Cathodic Protection

7

3.2.2 ICCP Systems

Oxidant discharges from operating ICCP systems are also characterized by mass flux

instead of flow rate because the constituents are created from the surrounding water due to

electrolysis. Precise reactions and probabilities depend on a variety of conditions as described in

Section 2.2.2.

In order to estimate the rate that CPOs are formed from ICCP systems, a sample of ICCP

system logs was reviewed and the average current output for Navy vessels in port was found to

be approximately 35 amperes (amps).13 Using the assumption that 100% of ICCP system current

goes into producing chlorine, an hourly pierside chlorine generation rate of 46.3 grams (g) per

vessel was calculated using Faraday’s Law:

(35 amps) (1 coulomb/amp-sec) (3,600 sec/hr) (35.45 g chlorine/mole) (mole/96,484 coulomb)

= 46.3 g chlorine/hr

Since ICCP systems are designed (i.e., anode design and system operating voltage) to

maximize cathodic protection provided to the hull, and generation of chlorine or CPO is a

secondary reaction, actual CPO generation rates are expected to be significantly lower.

ICCP anode deterioration rates have been measured at 4.4 to 6.1 milligrams/ampere per

year by the manufacturer.14 For a vessel operating an ICCP system at 35 amps in port for 176

days per year, the resulting dissolution rate of platinum using 6.1 milligrams/ampere per year is:

(6.1 mg/amp-year) (35 amps/ship) = 214 mg/(ship-year)

3.3 Constituents

3.3.1 Sacrificial Anodes

Zinc anodes are approximately 99.3% zinc and contain small amounts of cadmium and

aluminum (for activation).15 Table 3a lists the chemical composition of zinc anodes according

to military specifications.15 Zinc and cadmium are priority pollutants. None of the materials in

zinc anodes are bioaccumulators.

Aluminum anodes are approximately 95% aluminum, 5% zinc, and contain small

amounts of silicon and indium (for activation).6 Table 3b lists the chemical composition of

aluminum anodes according to military specifications.6 Zinc is a priority pollutant in aluminum

anodes. Aluminum anodes could possibly contain up to 0.001% mercury as an impurity;

mercury is a known bioaccumulator.
Cathodic Protection

8

3.3.2 ICCP Systems

The deterioration of ICCP anodes (see Section 3.2.2) produces 214 mg/yr per ship of

platinum. ICCP systems also produce by-products (oxidants) when they operate. In addition to

the reduction reactions at the hull, ICCP systems can also produce chlorine, bromine and other

oxidants (CPO) through secondary reactions at the anode because of the electrical potential

(voltage) of the anode (see Section 2.2). These constituents are the primary concern for the ICCP

portion of this discharge. Chlorine or CPOs are neither priority pollutants nor bioaccumulators,

though EPA has developed water quality criteria for chlorine/CPO.

3.4 Concentrations

The discharge due to cathodic protection is a mass flux rather than a flow. The resultant

concentration of constituents in the environment are discussed in Section 4.2.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

4.1.1 Sacrificial Anodes

The number of sacrificial anodes installed on a vessel is related to the area of wetted

surface needing protection and the area that is available for placing the anodes. The discharge

from sacrificial anodes is therefore proportional to vessel size (except for submarines because the

anodes only protect the propeller and stern appendages and not the hull). The amount of anodes

installed is based on:

1. One 23-pound zinc anode per 115 ft2 of total wetted area for large vessels (with

more than 3,000 ft2 of wetted area).3,5

2. One 23-pound anode per 400 ft2 of total wetted area for smaller vessels, boats, and

craft.3

3. 2,024 pounds (88 anodes) of zinc anodes per submarine.3

Using the large vessel criteria for all vessels with over 3,000 ft2 of wetted surface is a

conservative assumption because this criteria was written for large, high value vessels that have

long periods between drydockings (and thus, less opportunity for anode replacement). Vessels
Cathodic Protection

9

with wetted surface areas between 3,000 ft2 and 10,000 ft2 are drydocked more frequently,

increasing the opportunity for repainting and anode replacement, and therefore could use fewer

zinc anodes than the large vessel criteria. If the actual wetted surface area of a vessel was

unavailable, it was approximated using a formula in the Naval Ships’ Technical Manual

(NSTM), Chapter 633:5

S = 1.7 (l) (d) + (V) / (d)

where S = wetted surface area of the hull and appendages, in square feet

 l = length between perpendiculars, in feet

 d = molded mean draft at full displacement, in feet

V = molded volume of displacement in cubic feet

Where available, data on actual vessel movements were used to determine the number of

days in port, number of transits, and days underway operating within 12 n.m. for Navy, MSC,

USCG, and Army vessels. Where actual vessel movement data were not available, movement

data for vessels with similar missions were used. This information is shown in Table 2 and

Table 4. Using these data, the numbers of anodes installed on vessels, and anode

corrosion/dissolution rates, the mass flow rate of this discharge was calculated.ii When vessels

are in port, the pierside dissolution rate is used to calculate the constituent mass flow rate. When

vessels are operating within 12 n.m. of shore, the applicable dissolution rate is derived by

summing 66.7% of the pierside dissolution rate and 33.3% of the underway dissolution rate.

This applicable dissolution rate is then used to calculate the constituent mass flow rate. Total

constituent-specific mass flow rates are calculated by summing the pierside constituent mass

flow rate and the constituent mass flow rate when the vessel is operating within 12 n.m. An

example of the calculation for determining total constituent-specific mass loading is provided

below.

(305 days in port/yr) (24 hrs/day) (417 lb anode/class) (7.4x10-6 lb zinc/lb anode/hr) +

(60 days operating within 12 n.m./yr) (24 hrs/day) (417 lb anode/class) [(0.667) (7.4x10-6 lb

zinc/lb anode/hr) + (0.333) (3.0x10-5 lb zinc/lb anode/hr)] =

(22.59 lb zinc/yr/class) + (8.96 lb zinc/yr/class) = 31.55 lb zinc/yr/class

For the 89 submarines in the Navy fleet that use sacrificial anodes, the total estimated

annual loading of zinc within 12 n.m. is 6,360 pounds. Zinc anodes on submarines are required

to protect propellers and stern appendages, which are similar in surface area for all submarine

classes. Fifty-six of the Fleet’s 89 submarines are Los Angeles Class submarines. A Los

Angeles Class submarine has eighty-eight 23-pound zinc anodes (2,024 pounds total) to protect

propellers and stern appendages.3 The number of anodes on a Los Angeles Class submarine (88)

was used for all submarine classes because the surface areas of the propellers and stern

appendages are similar among submarine classes.

 

ii Most DOD vessels will be at anchor or otherwise stationary 2/3 of the time and conducting transits or otherwise

moving 1/3 of the the time when operating within 12 n.m. of shore. For mass loading calculation purposes, a

combination of the pierside and underway dissolution rates was used, weighted 66.7% and 33.3% respectively.

These percentages are based on fleet provided information.
Cathodic Protection

10

For surface vessels, an estimated 113,201 pounds of zinc is discharged annually within 12

n.m. The wetted surface areas and total amount of anodes used to calculate the zinc discharged

by vessels within 12 n.m. are presented in Table 2. The estimated mass loading was based on

1,805 surface vessels with a total wetted surface area of approximately 11 million square feet.

Mass loading for the approximately 5,000 small boats and craft of the Armed Forces was

estimated using the following information:

1. 30% have steel hulls, and therefore sacrificial anodes (the remaining have wood,

fiberglass, or aluminum hulls which do not require cathodic protection);

2. The average wetted surface area is 1,000 ft2 (the approximate wetted surface area

of a 65 ft tug boat), which is protected by approximately 58 pounds of zinc anodes

(23 pounds per 400 square feet);iii

3. Each vessel spends 100% of the time in the water (a conservative estimate since

many spend considerable time out of the water on trailers or blocks);

The resulting zinc discharged was then calculated using the static dissolution rate.

(5,000 vessels) (30%) (58 lb anodes/vessel) (100%) (7.4 x 10-6 lb zinc/lb anode/hr) (365 days/yr)

(24 hr/day) = 5,640 lb zinc/yr

Based on conservative assumptions, this calculation presents the maximum magnitude of

the discharge from small boats and craft, which represents approximately only 5% of the

previously estimated total annual discharge of 119,561 pounds of zinc (surface ships and

submarines combined) for a maximum combined total of 125,201 pounds of zinc per year. This

discharge could contain up to 626 pounds per year of aluminum and up to 88 pounds per year of

cadmium, based on the potential concentration of minor constituents in zinc anodes.

Aluminum anodes are currently used on no more than 5 submarines.16 Using the

information in Table 4, each submarine with zinc anodes discharges approximately 71.5 pounds

zinc/year within 12 n.m. This zinc loading was scaled for aluminum anodes using the current

capacity ratio derived in Section 3.2.1 and the maximum number of vessels with aluminum

anodes, resulting in a total fleetwide annual consumption (discharge) of 105 pounds of aluminum

anodes as shown below.

 

iii Small boats and craft are non-standard vessels with wetted surface areas ranging from under one hundred square

feet to one thousand square feet. Because adequate information is not available to characterize the surface area of

specific small boats and craft, the upper bound of this range, one thousand square feet, is used as a conservative

estimate of the average wetted surface area.
Cathodic Protection

11

(71.5 lb zinc anode/submarine) / (3.4) = 21.0 lb aluminum anode/submarine

(21.0 lb aluminum anode/submarine) (5 submarines) = 105 lb aluminum anodes consumed,

fleetwide

Based on the composition of aluminum anodes, this discharge is comprised of 100 pounds

aluminum, 5 pounds zinc, and could contain up to 0.21 pound per year of silicon and 0.02 pound

per year of indium. The maximum potential loading of mercury from aluminum anodes was

estimated to be 0.001 pound fleetwide, assuming that all aluminum anodes contain the highest

allowable amount of mercury.

4.1.2 ICCP Systems

The mass loading due to deterioration of ICCP anodes was calculated using the

previously discussed anode deterioration rate and the number of vessels with ICCP systems. For

the 267 vessels with ICCP systems, this results in a total fleet-wide platinum loading of:

(214 mg/yr) (273 vessels) = 57,138 mg/yr = 57 g/yr ≅ 2 ounces/yr

Annual CPO loadings were calculated using the estimated CPO generation rate of 46.3

g/hr per vessel (see Section 3.2). This rate was applied to the 273 vessels with ICCP systems

(see Table 1) and time spent in port for each class to calculate the mass loadings presented in

Table 5. The estimated annual loading of CPO based on the 273 vessels with ICCP systems is

98,000 pounds.

4.2 Environmental Concentrations

Two approaches were used to estimate the concentration of zinc and CPO in receiving

waters from cathodic protection systems. The first uses a simplified dilution model, based on

tidal flow in three major Armed Forces ports and is hereafter referred to as the “tidal prism”

approach. The second approach was based on a mixing zone proximate to the hull of a typical

Navy vessel. Each approach used the hourly zinc corrosion/dissolution rates and CPO

production rate developed in Section 3.2 (i.e., for zinc: a pierside rate of 1.3 x 10-6 (lb zinc/ft2)/hr

and an underway rate of 5.1 x 10-6 (lb zinc/ft2)/hr, and for CPO: 46.3 (g/vessel)/hr).

Tidal Prism. The tidal prism approach uses the mass of the constituent generated by

vessels and mixes this mass with a volume of water. The mass is calculated by determining the

number of vessels in a particular homeport, the type of cathodic protection system utilized, and

the number of hours each vessel spends in port (both pierside and in transit) along with the

aforementioned zinc and CPO generation rates. Together, these factors are used to calculate an

annual loading to the harbor. The water volume used is the sum of all outgoing tides over a year

times the surface area of the harbor. The sum of outgoing tides is called the “annual tidal

excursion” which is defined as the difference between mean high water and mean low water over

the course of a year. Annual tidal excursion data is readily available from the National

Oceanographic and Atmospheric Agency (NOAA), and the 1996 data17 was used for these

calculations.
Cathodic Protection

12

The tidal prism model assumes steady-state conditions, where zinc and CPO are

completely mixed with the harbor water and are removed solely by discharge from the port

during ebb tides. The outgoing tidal volumes are assumed to be carried away by long-shore

currents (i.e., those moving parallel to shore) and do not re-enter the harbor. The tidal prism

model also does not assume removal or concentration by other factors such as river flow,

precipitation, evaporation, sediment exchange, or natural decay. By not accounting for removal

or dilution due to river flow, precipitation, sediment exchange, and natural decay, the

calculations result in a higher constituent concentration. The effect of evaporation could be to

increase concentration due to water loss, or the effect could be neutral since water loss by

evaporation is replaced by (additional) water inflow from the sea. While the model assumes

complete mixing, there will be areas in the harbors with higher concentrations, primarily near the

source vessels, along with areas of lower concentration.

The three ports that are used for the tidal prism model shown in Tables 6a, 6b, and 6c

include Mayport, FL, San Diego, CA, and Pearl Harbor, HI. These ports were selected because

they have minimal river inflow, small but well-defined harbor areas, and a high number of

vessels of the armed forces. Each of these factors will tend to overestimate concentrations of

zinc and CPO, either due to less volume of water or high numbers of potential sources. Other

major ports, such as Norfolk (VA) and Bremerton (WA), were considered, but not included

because of large river effects and very large harbor areas. The 1996 annual tidal volumes (annual

tidal excursion times the harbor surface area) for the three ports (calculations provided in

Calculation Sheet 2) are shown below:

• San Diego, CA: 3.77 x 1013 liters;

• Mayport, FL: 6.67 x 1011 liters; and

• Pearl Harbor HI: 3.41 x 1012 liters.

Mixing Zone: For the mixing zone approach, the previously calculated zinc and CPO

generation rates were used for each discharge, but the resultant environmental concentrations

were calculated based on various volumes of water around a typical Armed Forces vessel (i.e., a

“mixing zone”) instead of the entire port, as above. A vessel with 19,850 ft2 of wetted surface

area (i.e., a FFG 7 Class frigate size vessel) was selected for modeling the environmental

concentration from sacrificial anodes since precise information was available for the number of

zinc anodes installed on that ship class. A vessel with 37,840 ft2 of wetted surface area (i.e., a

CG 47 Class cruiser size vessel) was selected for modeling ICCP system discharges because of

the large number of vessels in this ship class and it’s hull size is typical of most vessels with

ICCP systems.

The model assumes the hull to be a half immersed cylinder (see Calculation Sheets 3 and

4). The zinc and CPO generation rates were then applied to various sizes of mixing zones

(volumes of water surrounding the vessel), ranging from 0.1 to 100 feet from the hull, and

mixing rates (the time required for the mixing zone contents to be exchanged with a new volume

of clean seawater), ranging from 0.1 to 1 hour, to calculate resultant incremental zinc and CPO

concentration increases shown in Table 7. The maximum time of exchange of 1 hour
Cathodic Protection

13

corresponds to a realistic duration of slack tide, and is also the time required for a volume of

water flowing at 0.1 knots to flow past a 600 foot long vessel longitudinally. Actual exchange

times will usually be much less. For example, water flowing at 2 knots (typical for tidal flow)

past the same 600 foot long vessel results in a time of exchange of 3 minutes.

4.2.1 Sacrificial Anodes

The in-port (static) and transient (dynamic) zinc corrosion/dissolution rates of 7.4 x 10-6

and 3.0 x 10-5 pounds of zinc per pound of anode per hour, respectively, (see Calculation Sheet

1) were used for the tidal prism model. Only the static rate was used for the mixing zone model

since the highest potential concentrations would occur while the vessel is pierside.

Tidal prism. Based on the number and types of ships located in each of the three

harbors18 and the type of cathodic protection, the numbers of sacrificial anodes installed on each

of the vessels in each ship class were estimated, based on the information in Section 3.2.1. The

number and types of vessels using zinc sacrificial anodes at each port are listed in Table 6a.

Using the annual zinc loadings and annual tidal excursion volumes, the average zinc

concentrations caused by these vessels were calculated for each port (also shown in Table 6a).

The average zinc concentration estimated by the tidal prism model and the ambient zinc

concentrations19 are summarized below.

 Port Ambient Zinc from Anodes

• San Diego, CA: 11.3 μg/L 0.09 μg/L

• Mayport, FL: 5.0 μg/L 1.35 μg/L

• Pearl Harbor, HI: 12.8 μg/L 0.31 μg/L

As shown above, the contribution of zinc from sacrificial anodes makes up only a small

portion of the ambient concentration, except for Mayport, where almost 30 percent of the

ambient concentration can be attributed to the dissolution of zinc anodes. In each case, the

ambient concentrations are well below the Federal and most stringent state water quality criteria

(between 76 and 85 μg/L) as shown in Table 8. Resultant incremental concentration increases of

minor constituents (aluminum and cadmium) are shown in Table 6a and are at least 40,000 times

lower than the most stringent Federal or state WQC.

A similar tidal prism analysis can be performed for aluminum anode usage on

submarines. Assuming that Pearl Harbor and San Diego each have the maximum five

submarines with aluminum anodes, Table 6b shows the concentrations resulting from aluminum

sacrificial anodes to be 0.02 μg/L of aluminum and 2x10-7 μg/L of mercury for Pearl Harbor, and

much less for San Diego. These concentrations are significantly less than the most stringent state

WQC of 1,500 μg/L of aluminum (FL) and 0.025 μg/L of mercury (CT, FL, WA, and VA).

Incremental concentration increases for other minor constituents (zinc, silicon, and indium) are

also shown in Table 6b and are nearly 1,000,000 times lower than the most stringent Federal or

state WQC.
Cathodic Protection

14

Mixing zone. The mixing zone model calculated zinc concentrations within “envelopes”

or mixing zones of uniform size and shape around a vessel’s hull, assuming various exchange

rates. For calculation purposes, the mixing zones ranged from 0.1 foot to 100 feet from the hull,

and the exchange rates ranged from 0.1 hour to 1 hour. Actual exchange rates are rarely more

than one hour as discussed previously. Tabulated mixing zone calculations are presented in

Table 7 and do not include ambient concentrations of zinc in the water. Ambient zinc

concentrations for each port were then added to the mixing zone concentrations and compared to

ambient WQC.

Federal and state WQC exist for zinc (see Table 8). The Federal WQC is 81 μg/L for

chronic exposure. Washington state’s WQC of 76.6 μg/L for chronic exposure is the most

stringent state criteria.19 For exchange rates of one hour or less, any mixing zone of six inches or

more results in zinc concentrations (including the contribution of zinc from ambient water in

each port) less than the most stringent state WQC of 76.6 μg/L for chronic exposure. Ambient

zinc concentrations for Mayport, FL and Pearl Harbor, HI were obtained from EPA’s STORET

system. The Navy had more recent data on San Diego Bay and used this data rather than the data

from the STORET system.9,19 These concentrations are assumed to include any contributions of

zinc from sacrificial anodes.

The results of the mixing zone analysis developed for sacrificial zinc anodes (Table 7)

can be scaled to provide similar results for aluminum anodes using the current capacity ratio (3.4)

developed in Section 3.2.1 and the maximum allowable concentration of mercury (0.001%). The

sample calculation below was performed for the scenario from Table 7 that would produce the

highest estimated concentrations of aluminum and mercury (a time of exchange of one hour, and

a mixing zone of 0.1 foot):

Zinc concentration at radius of 0.1 ft = 236 μg/L

Aluminum concentration at same radius: = (236 μg/L)/(3.4) = 69.4 μg/L

Maximum potential mercury concentration at same radius = (69.4 μg/L)/(100,000)

The estimated concentration for aluminum (69.4 μg/L) is twenty times less than the most

stringent state chronic WQC of 1,500 μg/L (Fl), and there are no federal WQC for aluminum.

The estimated concentration for mercury (0.0007 μg/L) is 35 times less than Federal and most

stringent state chronic WQC (0.025 μg/L). Similar calculations can be performed for other

minor constituents of sacrificial anodes. In all cases, the resultant concentration increase is at

least 50 times less than the most stringent Federal and state WQC at a distance 0.1 feet from the

hull.

4.2.2 ICCP Systems

This discharge consists of various chlorinated and brominated substances (CPOs). As

discussed in Section 3.2.2, these generation rates assume that 100% of the current passed by the
Cathodic Protection

15

ICCP system creates CPOs, while in actuality, the current also produces metal complexes,

oxygen, hydrogen, and other compounds in addition to CPOs with each collateral reaction

consuming a portion of the total current. Seawater conditions have a strong influence on the type

and magnitude of secondary reactions at the hull and sacrificial anodes. Because seawater

conditions vary with geographic location, the extent of secondary chemical reactions cannot be

accurately predicted. Therefore, a conservative assumption that 100% of the current produces

CPOs is used.

In order to estimate the amount of CPOs generated by ICCP systems, ships’ logs for a

variety of vessels were reviewed to determine the average current produced by ICCP systems in

port (35 amps).13 From this information and Faraday’s Law, an hourly, pierside CPO generation

rate of 46.3 g/hr was calculated (see Section 3.2.2). This rate was used for both the tidal prism

and the mixing zone models.

Tidal prism. Using the same approach as described in Section 4.2.1 and CPO generation

rates, annual CPO loading due to the Armed Forces vessels in each of the three ports were

calculated as shown in Table 6c. The chronic criteria and concentrations estimated from the tidal

prism model are summarized below:

 Port Criteria CPO from ICCP

• San Diego, CA: N/A* 0.17 μg/L

• Mayport, FL: 10.0 μg/L 3.43 μg/L

• Pearl Harbor, HI: 7.5 μg/L 0.75 μg/L

* San Diego discharge limits are set on a case-by-case basis

This model assumes complete mixing and does not consider any decay or secondary

reactions. However, CPO is known to rapidly decay in seawater. In the first stage of CPO decay,

a portion of the CPO disappears within one minute, consumed by the instantaneous oxidant

demand. The rate of this first-stage reaction is related to temperature. One study, for example,

found that the percentage of CPO that disappeared within one minute varied from 4% at 0 °C to

20 Other factors that influence the initial rate of decay include ammonia

concentration and the nature of the oxidant demand. In the second stage of CPO decay, the CPO

remaining after the first stage is reduced more slowly. Second stage decay half-lives of between

1 and 100 minutes have been observed.20 In most cases, however, the majority of CPO will

disappear within an hour of being added to seawater.20,21

If these decay rates were incorporated into the tidal prism model, the average CPO

concentrations shown above for the three ports would be lower. For example, the average CPO

concentration of 3.43 μg/L in Mayport, FL was calculated assuming zero CPO decay for the

duration of a tidal excursion. Using average decay estimates (i.e., 25% first stage decay after one

minute, 50% second stage decay per hour) provides a 98.8% reduction in CPO for the 12 hour

duration of a tidal excursion, resulting in CPO concentrations orders of magnitude below WQC.
Cathodic Protection

16

Mixing zone. Using the mixing zone approach described for sacrificial anodes, CPO

concentrations within “envelopes” or mixing zones around a vessel’s hull were calculated. For

calculation purposes the mixing zones ranged from 0.1 foot to 100 feet from the hull, and the

mixing rates ranged from 0.1 hour to 1 hour. As stated previously, actual exchange rates are

rarely more than 1 hour, and may be as low as a few minutes.

Tabulated calculations of CPO mixing zone calculations are included in Table 7. For

exchange rates of 1 hour or less, any mixing zone of 5.5 feet or more results in CPO

concentrations below the most stringent state chronic WQC of 7.5 μg/L. EPA’s STORET system

does not contain monitoring data for chlorine; therefore, ambient conditions can not be

determined.

As for the tidal prism model calculations, these figures assume no decay of CPO. Using

the CPO decay rates discussed above, a 47.0% reduction in the CPO concentrations listed in

Table 6b for a 1 hour mixing zone exchange rate would be expected. Applying this decay rate to

the mixing zone model and assuming a time of exchange of one hour, any mixing zone with a

radius of 3 feet or more results in CPO concentrations caused by ICCP systems less than the most

stringent state chronic WQC of 7.5 μg/L.

4.3 Potential for Introducing Non-Indigenous Species

There is insignificant potential for transport of non-indigenous species by this discharge

because no water is retained nor transported.

5.0 CONCLUSIONS

5.1 Sacrificial Anodes

Cathodic protection discharges from sacrificial anodes have a low potential for causing

adverse environmental effects for the following reasons:

• the loadings from sacrificial zinc and aluminum anodes do not result in zinc or aluminum

concentrations, or concentrations of minor constituents, above ambient water quality

criteria in any of the harbors based on the results of the tidal prism model;

• zinc, aluminum, and mercury concentrations are below WQC within a distance of 0.5,

0.1, and 0.1 feet, respectively, during periods of slack water (little water movement in the

harbor); and

• loadings of mercury are small (less than 0.001 pound per year fleetwide).

This conclusion is based on corrosion/dissolution rates estimated from the average anode

replacement intervals for Navy vessels. The number of anodes per vessel class was based on

actual numbers or, in lieu of such data, estimated using the vessel’s wetted surface area. This
Cathodic Protection

17

approach was also applied to other Armed Forces vessels.

5.2 ICCP Systems

Cathodic protection discharges from Impressed Current Cathodic Protection (ICCP)

systems have a low potential for causing adverse environmental effects for the following reasons:

• the loadings from ICCP systems do not result in CPO concentrations above ambient water

quality criteria in any of the harbors based on the results of the tidal prism model; and

• CPO concentrations drop below WQC within a distance of 5.5 feet during periods of

slack water without considering CPO decay (which would reduce concentrations even

lower).

This conclusion is based on a review of ICCP system logs and the assumption that 100%

of the current passed from the ICCP system anodes generates CPO.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 9

shows the sources of data used to develop this NOD report.

Specific References

1. Commander, Submarine Force, U.S. Atlantic Fleet (Ser N451A/4270), UNDS Data Call

Package Submission: Encl: 688 & 726 Class Submarine Discharge Data Packages.

December 13, 1996.

2. Potential Impact of Environmental and Worker Health Laws on the Sacrificial Anode Life

Cycle. Ocean City Research Corp. June 1993.

3. M. Rosenblatt & Son, Inc., Zinc Anode Usage Guidance, April 23, 1997.

4. Commander, Naval Air Forces, U.S. Atlantic Fleet. Responses to TYCOM

questionnaire. M. Rosenblatt & Son, Inc. May 20, 1997.

5. Naval Ships’ Technical Manual (NSTM) Chapter 633, Cathodic Protection. Sections

2.3.2 to 2.3.5, 4.2.1, 4.3.1, 4.4 to 4.4.2, and Tables 3 and 4. August 1992.

6. Military Specification MIL-A-24779, Anodes, Sacrificial Aluminum Alloy, 1992

7. White, G.C., 1992, The Handbook of Chlorination and Alternative Disinfectants. Van

Nostrand Reinhold, New York, p.1308.
Cathodic Protection

18

8. UNDS Equipment Expert Meeting-Cathodic Protection, Sacrificial Anodes, Action Item

No. 124. November 14, 1996.

9. UNDS Cathodic Protection Evaluation. The Marine Environmental Support Office,

Naval Command, Control and Ocean Surveillance Center, San Diego, CA. February 13,

1997.

10. Dan Kailey, M. Rosenblatt & Son, Inc., Master UNDS Vessel List, Conrad Bernier,

Malcolm Pirnie, Inc., April 23, 1997.

11. Seelinger, Andrew; Shimko, LCDR Michael J., Impressed Current Cathodic Protection

and Physical Scale Modeling, CORROSION, CAUSES AND CONTROL Short Course,

Naval Postgraduate School, Monterey, CA. June 1992.

12. Kailey, Dan, M. Rosenblatt & Son, Inc., Vessel Schedule Data, Clarkson Meredith,

Versar, Inc., April 23, 1997.

13. M. Rosenblatt & Son, Inc., Summary of U.S. Navy Impressed Current Cathodic

Protection (ICCP) System Output, June 16, 1997

14. Electocatalytic, Inc. Shipboard Impressed Current Anodes. February, 1992.

15. Military Specification MIL-A-18001, Anodes, Sacrificial Zinc Alloy. 1993.

16. Dunstan Mensah, SEA 91T131, September 30, 1997, Inquiry on Aluminum Anode Usage

on Submarines, M. J. Shimko, M. Rosenblatt & Son, Inc.

17. The National Oceanic and Atmospheric Administration Homepage,

www.olld.nos.noaa.gov/long__wl.html, 1997.

18. The United States Navy, List of Homeports, Effective April 30, 1997.

19. U.S. Environmental Protection Agency, Office of Wetlands, Oceans and Watersheds,

Assessment and Watershed Protection Division, Retrieval from STORET Database.

1997.

20. Davis, M.H., and Coughlan, J., 1983. A Model for Predicting Chlorine Concentrations

Within Marine Cooling Circuits and its Dissipation at Outfalls. In Jolley, R.L., Brunds,

W.A., Cotruvo, J.A., Cumming, R.B., Mattice, J.S., and Jacobs, V.A. (eds.), Water

Chlorination: Environmental Impact and Health Effects, Vol. 4, Book 1, Ann Arbor

Science, p. 347-357.

21. NAVSEA. Chlorination Report, Malcolm Pirnie. July 14, 1997.
Cathodic Protection

19

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

UNDS Equipment Expert Meeting Minutes- Protection, Sacrificial Anodes. August 6, 1996.
Cathodic Protection

20

Fontana, Mars G., Corrosion Engineering, Third Edition, McGraw Hill, Inc., New York, 1986.

Jones, Denny A., Principles and Prevention of Corrosion, Macmillan Publishing Company, New

York, NY, 1992.

Uhlig, Herbert H. and Revie, R. Winston, Corrosion and Corrosion Control an Introduction to

Corrosion Science and Engineering, Third Edition, John Wiley & Sons, New York, 1985.

Van der Leeden, et. al. The Water Encyclopedia, 2nd Ed. Lewis Publishers: Chelsae, Michigan,

1990.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.

Jane’s Information Group, Jane’s Fighting Ships. Capt. Richard Sharpe, Ed. Sentinel House:

Surrey, United Kingdom, 1996.

General Specifications for Ships of the United States Navy (GENSPECS), Section 633, Cathodic

Protection. 1995.

Ciscon, David, M. Rosenblatt & Son, Inc., Vessel Transit Time, May 1, 1997,. Clarkson

Meredith, Versar, Inc., Soule, R.E., M. Rosenblatt & Son, Inc., Response to Inquiry on

ICCP Systems, May 8, 1997, Lee Sesler, Versar, Inc.

Aivalotis, LT Joyce, U.S. Coast Guard, Inquiry on Cathodic Protection of USCG Vessels, May

27, 1997, Lee Sesler, Versar, Inc.

UNDS Shipcheck of U.S. Army Watercraft, Fort Eustis, VA, January 1998.

M. Rosenblatt & Son, Inc., Environmental Loading Due To Cathodic Protection, June 13, 1997.

Malcolm Pirnie, Inc., Estimate of Zinc Concentrations Contributed by Hull Mounted Sacrificial

Anodes in Selected Naval Ports, June 2, 1997.

Bonner, Frederick A., Malcolm Pirnie, Inc. Written Correspondence on Chlorine Discharge from

Freshwater Layup, Submarine Heat Exchangers. April 9, 1997.
Table 1. Listing of Vessels, 

 Navy, MSC, Army, and USCG using Cathodic Protection

Class Description Quantity of Vessels Cathodic Protection 

System

 Navy Combatants

ATC River Raider Class Mini Armored Troop Carriers 20 Sacrificial Anodes

AT Armored Troop Carriers 21 Sacrificial Anodes

CM Landing Craft, Mechanized 151 Sacrificial Anodes

CU Landing Craft, Utility 40 Sacrificial Anodes

CV 59 Forrestal Class Aircraft Carrier 1 ICCP

CVN 65 Enterprise Class Aircraft Carrier 1 ICCP

CV 63 Kitty Hawk Class Aircraft Carrier 3 ICCP

CVN 68 Nimitz Class Aircraft Carrier 7 ICCP

CG 47 Ticonderoga Class Guided Missile Cruisers 27 ICCP

CGN 38 Virginia Class Guided Missile Cruiser 1 ICCP

CGN 36 California Class Guided Missile Cruiser 2 ICCP

DDG 993 Kidd Class Guided Missile Destroyers 4 ICCP

DDG 51 Arleigh Burke Class Guided Missile Destroyers 18 ICCP

DD 963 Spruance Class Destroyers 31 ICCP

FFG 7 Oliver Hazard Perry Guided Missile Frigates 1 ICCP

FFG 7 Oliver Hazard Perry Guided Missile Frigates 42 Sacrificial Anodes

LCC 19 Blue Ridge Class Amphibious Command Ships 2 ICCP

LCM 3 Mechanized Landing Craft 2 Sacrificial Anodes

LCM 6 Mechanized Landing Craft 60 Sacrificial Anodes

LCM 8 Mechanized Landing Craft 100 Sacrificial Anodes

LCU 1610 Utility Landing Craft (LCU 1600) 40 Sacrificial Anodes

LHD 1 Wasp Class Amphibious Transport Docks 4 ICCP

LHA 1 Tarawa Class Amphibious Assault Ships 5 ICCP

LPD 4 Austin Class Amphibious Transport Docks 3 ICCP

LPD 7 Amphibious Transport Docks 3 ICCP

LPD 14 Amphibious Transport Docks 2 ICCP

LPH 2 Iwo Jima Class Assault Ships 2 Sacrificial Anodes

LSD 36 Anchorage Class Dock Landing Ships 5 Sacrificial Anodes

LSD 41 Whidbey Island Class Dock Landing Ships 8 ICCP

LSD 49 Harpers Ferry Dock Landing Ships 3 ICCP

MCM 1 Avenger Class Mine Countermeasure Vessels 14 Sacrificial Anodes

MHC 51 Osprey Class Coastal Minehunter Vessels 12 Sacrificial Anodes

PB Mk III and Mk IV Patrol Boats 31 Sacrificial Anodes

PBR Mk II River Patrol Boats 25 Sacrificial Anodes

PC 1 Cyclone Class Coastal Defense Ships 13 ICCP

SSBN 726 Ohio Class Ballistic Missle Submarine 17 Sacrificial Anodes

SSN 637 Sturgeon Class Attack Submarine 13 Sacrificial Anodes

SSN 688 Los Angeles Class Attack Submarine 56 Sacrificial Anodes

SSN 671 Narwhal Class Submarines 1 Sacrificial Anodes

SSN 640 Benjamin Franklin Class Submarines 2 Sacrificial Anodes

Navy Auxiliary

AFDB 4 Large Auxiliary Floating Dry Dock 1 ICCP

AFDB 8 Large Auxiliary Floating Dry Dock 1 ICCP

AFDL 1 Small Auxiliary Floating Dry Docks 2 ICCP

AFDM 14 Medium Auxiliary Floating Dry Dock 1 ICCP

AFDM 3 Medium Auxiliary Floating Dry Docks 4 ICCP

AGF 3 Raleigh Class Miscellaneous Flagship 1 Sacrificial Anodes
Table 1. Listing of Vessels, 

 Navy, MSC, Army, and USCG using Cathodic Protection

Class Description Quantity of Vessels Cathodic Protection 

System

AGF 11 Austin Class Miscellaneous Flagship 1 Sacrificial Anodes

AGOR 21 Gyre Class Oceanographic Research Ships 1 Sacrificial Anodes

AGOR 23 T.G. Thompson Class Oceanographic Research Ships 2 Sacrificial Anodes

AO 177 Jumboised Cimarron Class Oilers 5 ICCP

AOE 6 Supply Class Fast Combat Support Ships 3 ICCP

AOE 1 Sacramento Class Fast Combat Support Ship 4 ICCP

ARD 2 Auxiliary Repair Dry Docks 1 Sacrificial Anodes

ARDM Medium Auxiliary Repair Dry Docks 3 ICCP

ARS 50 Safeguard Class Savage Ships 4 ICCP

AS 39 Emory S Land Class Submarine Tenders 3 Sacrificial Anodes

AS 33 Simon Lake Class Submarine Tenders 1 Sacrificial Anodes

TR Torpedo Retrievers 22 Sacrificial Anodes

YC Open Lighters (nsp) 254 Sacrificial Anodes

YD Floating Cranes (nsp) 63 Sacrificial Anodes

YDT Diving Tenders 3 Sacrificial Anodes

YFN Covered Lighters (nsp) 157 Sacrificial Anodes

YFNB Large Covered Lighters (nsp) 11 Sacrificial Anodes

YFNX Lighter - Special Purpose (nsp) 8 Sacrificial Anodes

YFP Floating Power Barges (nsp) 2 Sacrificial Anodes

YFRT Covered Lighters - Range Tender (self propelled) 2 Sacrificial Anodes

YFU Harbor Utility Craft ( YFU 83 & 91 ) 2 Sacrificial Anodes

YO 65 Fuel Oil Barges 3 Sacrificial Anodes

YOG 5 Gasoline Barges 2 Sacrificial Anodes

YOGN Gasoline Barges (nsp) 12 Sacrificial Anodes

YON Fuel Oil Barges (nsp) 48 Sacrificial Anodes

YOS Oil Storage Barges (nsp) 14 Sacrificial Anodes

YP Patrol Craft ( YP 654 & 676 ) 28 Sacrificial Anodes

YR Floating Workshops (nsp) 25 Sacrificial Anodes

YRB Repair and Berthing Barges (nsp) 4 Sacrificial Anodes

YRBM Repair, Berthing and Messing Barges (nsp) 39 Sacrificial Anodes

YRR Radiological Repair Barges (nsp) 9 Sacrificial Anodes

YRST Salvage Craft Tenders (nsp) 3 Sacrificial Anodes

YSD 11 Seaplane Wrecking Derrick (self propelled) 1 Sacrificial Anodes

YTB 752 Large Harbor Tug (self propelled) 1 Sacrificial Anodes

YTB 756 Large Harbor Tugs (self propelled) 3 Sacrificial Anodes

YTB 760 Large Harbor Tugs (self propelled) 68 Sacrificial Anodes

YTL 422 Small Harbor Tug (self propelled) 1 Sacrificial Anodes

YTT Torpedo Trials Craft 3 Sacrificial Anodes

Miscellaneous Boats and Craft ~5,000 Sacrificial Anodes

Military Sealift Command (MSC)

T-AE 26 Kilauea Class Ammunition Ships 5 ICCP

T-AE 26 Kilauea Class Ammunition Ships 3 Sacrificial Anodes

T-AFS 1 Mars Class Combat Stores Ships 6 ICCP

T-AFS 1 Mars Class Combat Stores Ships 2 Sacrificial Anodes

T-AG 194 Mission Class Navigation Research Ship 1 ICCP

T-AG 194 Mission Class Navigation Research Ship 1 Sacrificial Anodes

T-AGM 22 Compass Island Class Missle Instrumentation Ship 1 ICCP

T-AGOS 1 Stalwart Class Ocean Surviellance Ship 5 Sacrificial Anodes
Table 1. Listing of Vessels, 

 Navy, MSC, Army, and USCG using Cathodic Protection

Class Description Quantity of Vessels Cathodic Protection 

System

T-AGOS 19 Victorius Class Ocean Surviellance Ship 4 Sacrificial Anodes

T-AGS 26 Silas Bent and Wilkes Classes Surveying Ships 2 Sacrificial Anodes

T-AGS 45 Waters Class Surveying Ships 1 ICCP

T-AGS 51 John McDonnel Class Surveying Ships 2 ICCP

T-AGS 60 Pathfinder Class Surveying Ships 4 ICCP

T-AH 19 Mercy Class Hospital Ships 2 ICCP

T-AKR 295 Maesrk Class Fast Sealift Ships 2 ICCP

T-AKR 295 Maesrk Class Fast Sealift Ships 1 Sacrificial Anodes

T-AKR 287 Algol Class Vehicle Cargo Ships 6 ICCP

T-AKR 287 Algol Class Vehicle Cargo Ships 2 Sacrificial Anodes

T-AO 187 Henry J Kaiser Class Oilers 13 ICCP

T-ARC 7 Zeus Class Cable Repairing Ship 1 ICCP

T-ATF 166 Powhatan Class Fleet Ocean Tugs 5 ICCP

T-ATF 166 Powhatan Class Fleet Ocean Tugs 2 Sacrificial Anodes

U.S. Coast Guard 

WHEC 378 Hamilton and Hero Class High Endurance Cutters 12 Sacrificial Anodes

WMEC 230 Storis Class Medium Endurance Cutters 1 Sacrificial Anodes

WMEC 213 Diver Class Medium Endurance Cutters 1 Sacrificial Anodes

WMEC 270 A Famous Class Medium Endurance Cutters 4 Sacrificial Anodes

WMEC 270 B Famous Class Medium Endurance Cutters 9 Sacrificial Anodes

WMEC 210 A Reliance Class Medium Endurance Cutters 5 Sacrificial Anodes

WMEC 210 B Reliance Class Medium Endurance Cutters 11 Sacrificial Anodes

WAGB 290 Mackinaw Class Icebreakers 1 Sacrificial Anodes

WAGB 399 Polar Class Icebreakers 2 ICCP

WTGB 140 Bay Class Icebreaking Tugs 9 Sacrificial Anodes

WPB 110 A Island Class Patrol Craft 16 ICCP

WPB 110 B Island Class Patrol Craft 21 ICCP

WPB 110 C Island Class Patrol Craft 12 ICCP

WPB 82 C Point Class Patrol Craft 28 Sacrificial Anodes

WPB 82 D Point Class Patrol Craft 8 Sacrificial Anodes

WLB 225 Juniper Class Seagoing Buoy Tenders 2 Sacrificial Anodes

WLB 180 A Balsam Class Seagoing Buoy Tenders 8 Sacrificial Anodes

WLB 180 B Balsam Class Seagoing Buoy Tenders 2 Sacrificial Anodes

WLB 180 C Balsam Class Seagoing Buoy Tenders 13 Sacrificial Anodes

WLM 551 Keeper Class Coastal Buoy Tenders 2 Sacrificial Anodes

WLM 157 White Sumac Class Coastal Buoy Tenders 9 Sacrificial Anodes

WLR 115 River Buoy Tenders 1 Sacrificial Anodes

WLR 65 River Buoy Tenders 6 Sacrificial Anodes

WLR75 River Buoy Tenders 13 Sacrificial Anodes

WIX Eagle Class Sail Training Cutter 1 Sacrificial Anodes

WLIC 160 Pamlico Class Inland Construction Tenders 4 Sacrificial Anodes

WLIC 100 Cosmos Class Inland Construction Tenders 3 Sacrificial Anodes

WLIC 115 Inland Construction Tender 1 Sacrificial Anodes

WLIC 75 A Anvil Class Inland Construction Tenders 2 Sacrificial Anodes

WLIC 75 B Inland Construction Tenders 3 Sacrificial Anodes

WLIC 75 D Clamp Class Inland Construction Tenders 2 Sacrificial Anodes

WLI 100 A Inland Buoy Tender 1 Sacrificial Anodes

WLI 100 C Inland Buoy Tender 1 Sacrificial Anodes
Table 1. Listing of Vessels, 

 Navy, MSC, Army, and USCG using Cathodic Protection

Class Description Quantity of Vessels Cathodic Protection 

System

WLI 65303 Inland Buoy Tender 2 Sacrificial Anodes

WLI 65400 Inland Buoy Tender 2 Sacrificial Anodes

WYTL 65 A 65 ft. Class Harbor Tugs 3 Sacrificial Anodes

WYTL 65 B 65 ft. Class Harbor Tugs 3 Sacrificial Anodes

WYTL 65C 65 ft. Class Harbor Tugs 3 Sacrificial Anodes

WYTL 65 D 65 ft. Class Harbor Tugs 2 Sacrificial Anodes

 Army

BCDK Coversion Kit, Barge, Deck Cargo, Deck Enclosure 3 Sacrificial Anodes

BD Barges, Derrick 12 Sacrificial Anodes

BK Barges, Deck Cargo (nsp) 2 Sacrificial Anodes

BPL Pier, Barge Type, Self-Evaluating (nsp) 1 Sacrificial Anodes

FMS Floating Machine Shops 3 Sacrificial Anodes

J-Boat Picket Boats 6 Sacrificial Anodes

LARC-LX Lighter Amphibious Resupply Cargo (formerly BARC) 23 Sacrificial Anodes

LCM-8 Landing Craft Mechanized 104 Sacrificial Anodes

LCU Landing Craft Utility 48 Sacrificial Anodes

LSV Frank S. Besson Class Logistic Support Vessels 6 Sacrificial Anodes

LT Inland and Coastal Tugs 19 Sacrificial Anodes

LT Inland and Coastal Tugs 6 ICCP

Q-Boat Picket Boat 1 Sacrificial Anodes

ST Small Tugs 13 Sacrificial Anodes

T-Boat Boat, Passenger and Cargo 1 Sacrificial Anodes

Total 2167
Table 2. Vessels Estimated Annual Sacrificial Anode Cathodic Protection Discharges

Class Description

Quantity of 

Vessels w/ 

Zincs

Wetted Surface 

Area per Vessel 

(sq ft)

Wetted Surface 

Area of Class 

(sq ft)

Total 

Amount of 

Anodes by 

Class (lbs)

Days in 

Port per 

Vessel

Number of 

Transits per 

Vessel (e)

Days 

Operating 

within 12 

n.m.

Zinc Discharged 

within 12 n.m. 

(lbs)

Navy Combatants

ATC River Raider Class Mini Armored Troop Carriers 20 362 7,244 417 a 305 b 0 60 32

AT Armored Troop Carriers 21 362 7,606 437 a 305 b 0 60 33

CM Landing Craft, Mechanized 151 4,275 645,525 129,105 a 305 b 0 60 9,798

CU Landing Craft, Utility 40 3,860 154,400 30,880 a 305 b 0 60 2,344

FFG 7 Oliver Hazard Perry Guided Missile Frigates 42 19,850 833,700 166,152 c 167 13 0 5,477

LCM 3 Mechanized Landing Craft 2 990 1,980 114 a 305 0 60 9

LCM 6 Mechanized Landing Craft 60 990 59,400 3,416 a 305 0 60 259

LCM 8 Mechanized Landing Craft 100 1,603 160,300 9,217 a 305 0 60 700

LCU 1610 Utility Landing Craft (LCU 1600) 40 3,915 156,600 31,320 d 200 6 0 1,165

LPH 2 Iwo Jima Class Assault Ships 2 49,945 99,890 19,964 c 186 11 0 716

LSD 36 Anchorage Class Dock Landing Ships 5 45,405 227,025 51,060 c 215 13 0 2,121

MCM 1 Avenger Class Mine Countermeasure Vessels 14 8,410 117,740 9,982 c 232 28 0 481

MHC 51 Osprey Class Coastal Minehunter Vessels 12 6,418 77,016 9,936 c 232 28 0 479

PB Mk III and Mk IV Patrol Boats 31 897 27,796 1,598 a 305 b 0 60 121

PBR Mk II River Patrol Boats 25 261 6,531 376 a 305 b 0 60 29

Navy Auxiliary

AGF 3 Raleigh Class Miscellaneous Flagship 1 41,595 41,595 8,326 c 183 12 0 296

AGF 11 Austin Class Miscellaneous Flagship 1 51,830 51,830 8,326 c 183 12 0 296

AGOR 21 Gyre Class Research Ships 1 8,834 8,834 1,767 a 113 11 0 40

AGOR 23 Thom. G. Thompson Class Research Ships 2 13,960 27,920 5,584 a 113 11 0 127

ARD 2 Auxiliary Repair Dry Docks 1 46,994 46,994 5,405 c 305 b 60 0 372

AS 39 Emory S Land Class Submarine Tenders 3 59,630 178,890 41,400 c 293 6 0 2,228

AS 33 Simon Lake Class Submarine Tenders 1 59,630 59,630 13,800 c 229 6 0 585

TR Torpedo Retrievers 22 1,125 24,750 1,423 a 305 b 0 60 108

YC Open Lighters (nsp) 254 6,475 1,644,650 94,567 d 305 b 0 60 7,177

YD Floating Cranes (nsp) 63 12,875 811,125 162,225 d 305 b 0 60 12,312

YDT Diving Tenders 3 8,885 26,655 5,331 d 305 b 0 60 405

YFN Covered Lighters (nsp) 157 6,680 1,048,760 209,752 d 305 b 0 60 15,919

YFNB Large Covered Lighters (nsp) 11 15,955 175,505 35,101 d 305 b 0 60 2,664

YFNX Lighter - Special Purpose (nsp) 8 4,760 38,080 7,616 d 305 b 0 60 578

YFP Floating Power Barges (nsp) 2 15,590 31,180 6,236 d 305 b 0 60 473

YFRT Covered Lighters - Range Tender (self propelled) 2 5,490 10,980 2,196 d 305 b 0 60 167

YFU Harbor Utility Craft ( YFU 83 & 91) 2 3,915 7,830 1,566 d 305 b 0 60 119
Table 2. Vessels Estimated Annual Sacrificial Anode Cathodic Protection Discharges

Class Description

Quantity of 

Vessels w/ 

Zincs

Wetted Surface 

Area per Vessel 

(sq ft)

Wetted Surface 

Area of Class 

(sq ft)

Total 

Amount of 

Anodes by 

Class (lbs)

Days in 

Port per 

Vessel

Number of 

Transits per 

Vessel (e)

Days 

Operating 

within 12 

n.m.

Zinc Discharged 

within 12 n.m. 

(lbs)

YO 65 Fuel Oil Barges 3 10,205 30,615 6,123 d 305 b 0 60 465

YOG 5 Gasoline Barges 2 10,205 20,410 4,082 d 305 b 0 60 310

YOGN Gasoline Barges (nsp) 12 8,512 102,144 20,429 a 305 b 0 60 1,550

YON Fuel Oil Barges (nsp) 48 8,512 408,576 81,715 a 305 b 0 60 6,202

YOS Oil Storage Barges (nsp) 14 8,512 119,168 23,834 a 305 b 0 60 1,809

YP Patrol Craft (YP 654 & 676) 28 2,074 58,070 3,339 d 305 b 0 60 253

YR Floating Workshops (nsp) 25 7,350 183,750 36,750 d 305 b 0 60 2,789

YRB Repair and Berthing Barges (nsp) 4 4,320 17,280 3,456 d 305 b 0 60 262

YRBM Repair, Berthing and Messing Barges (nsp) 39 10,180 397,020 79,404 d 305 b 0 60 6,026

YRR Radiological Repair Barges (nsp) 9 6,405 57,645 11,529 d 305 b 0 60 875

YRST Salvage Craft Tenders (nsp) 3 10,965 32,895 6,579 d 305 b 0 60 499

YSD 11 Seaplane Wrecking Derrick (self propelled) 1 3,845 3,845 769 d 305 b 0 60 58

YTB 752 Large Harbor Tug (self propelled) 1 3,170 3,170 634 d 305 b 0 60 48

YTB 756 Large Harbor Tugs (self propelled) 3 3,265 9,795 1,959 d 305 b 0 60 149

YTB 760 Large Harbor Tugs (self propelled) 68 3,265 222,020 44,404 d 305 b 0 60 3,370

YTL 422 Small Harbor Tug (self propelled) 1 1,015 1,015 58 d 305 b 0 60 4

YTT 9 Torpedo Trials Craft 3 7,205 21,614 4,323 a 305 b 0 60 328

Miscellaneous Boats and Craft ~5,000 Unknown Unknown Unknown

Military Sealift Command

T-AE 26 Kilauea Class Ammunition Ships 3 54,240 162,720 32,544 d 26 4 0 182

T-AFS 1 Mars Class Combat Stores Ships 2 46,930 93,860 23,000 c 148 7 0 647

T-AG 194 Mission Class Navigation Research Ship 1 59,126 59,126 11,825 a 151 10 0 348

T-AGOS 1 Stalwart Class Ocean Surviellance Ship 5 10,987 54,935 10,987 a 70 4 0 148

T-AGOS 19 Victorius Class Ocean Surviellance Ship 4 14,679 58,716 11,743 a 107 5 0 239

T-AGS 26 Silas Bent and Wilkes Surveying Ships 2 13,913 27,826 5,565 a 44 6 0 52

T-AKR 295 Maesrk Class Fast Sealift Ships 1 107,028 107,028 21,406 a 59 9 0 272

T-AKR 287 Algol Class Vehicle Cargo Ships 2 111,650 223,300 44,660 a 109 3 0 902

T-ATF 166 Powhatan Class Fleet Ocean Tugs 2 11,398 22,796 4,559 a 127 16 0 121

U.S. Coast Guard

WHEC 378 Hamilton and Hero Class High Endurance Cutters 12 17,339 208,068 41,614 a 151 13 0 1,253

WMEC 230 Storis Class Medium Endurance Cutters 1 9,498 9,498 1,900 a 167 11 0 62

WMEC 213 Diver Class Medium Endurance Cutters 1 8,954 8,954 1,791 a 98 9 0 35

WMEC 270 A Famous Class Medium Endurance Cutters 4 10,976 43,904 8,781 a 137 6 0 228
Table 2. Vessels Estimated Annual Sacrificial Anode Cathodic Protection Discharges

Class Description

Quantity of 

Vessels w/ 

Zincs

Wetted Surface 

Area per Vessel 

(sq ft)

Wetted Surface 

Area of Class 

(sq ft)

Total 

Amount of 

Anodes by 

Class (lbs)

Days in 

Port per 

Vessel

Number of 

Transits per 

Vessel (e)

Days 

Operating 

within 12 

n.m.

Zinc Discharged 

within 12 n.m. 

(lbs)

WMEC 270 B Famous Class Medium Endurance Cutters 9 10,976 98,784 19,757 a 164 7 0 612

WMEC 210 A Reliance Class Medium Endurance Cutters 5 7,478 37,390 7,478 a 235 13 0 337

WMEC 210 B Reliance Class Medium Endurance Cutters 11 7,157 78,727 15,745 a 149 9 0 453

WAGB 290 Mackinaw Class Icebreakers 1 19,167 19,167 3,833 a 215 b 4 150 356

WTGB 140 Bay Class Icebreaking Tugs 9 4,869 43,821 8,764 a 215 b 1 150 807

WPB 82 C Point Class Patrol Craft 28 1,243 34,804 2,001 a 135 b 6 200 194

WPB 82 D Point Class Patrol Craft 8 1,243 9,944 572 a 135 b 6 200 55

WLB 225 Juniper Class Seagoing Buoy Tenders 2 10,357 20,714 4,143 a 190 18 100 306

WLB 180 A Balsam Class Seagoing Buoy Tenders 8 6,751 54,008 10,802 a 190 18 100 798

WLB 180 B Balsam Class Seagoing Buoy Tenders 2 6,751 13,502 2,700 a 120 5 100 157

WLB 180 C Balsam Class Seagoing Buoy Tenders 13 6,751 87,763 17,553 a 123 16 100 1,078

WLM 551 Keeper Class Coastal Buoy Tenders 2 6,408 12,816 2,563 a 123 b 16 200 249

WLM 157 White Sumac Class Coastal Buoy Tenders 9 4,648 41,832 8,366 a 123 b 16 200 811

WLR 115 River Buoy Tenders 1 3,415 3,415 196 a 160 b 0 205 20

WLR 65 River Buoy Tenders 6 1,583 9,498 546 a 160 b 0 205 55

WLR75 River Buoy Tenders 13 1,823 23,699 1,363 a 160 b 0 205 138

WIX Eagle Class Sail Training Cutter 1 12,264 12,264 2,453 a 188 7 150 217

WLIC 160 Pamlico Class Inland Construction Tenders 4 5,113 20,452 4,090 a 160 b 0 205 415

WLIC 100 Cosmos Class Inland Construction Tenders 3 2,432 7,296 420 a 160 b 0 205 43

WLIC 115 Inland Construction Tender 1 2,796 2,796 161 a 160 b 0 205 16

WLIC 75 A Anvil Class Inland Construction Tenders 2 1,735 3,470 200 a 160 b 0 205 20

WLIC 75 B Inland Construction Tenders 3 1,735 5,205 299 a 160 b 0 205 30

WLIC 75 D Clamp Class Inland Construction Tenders 2 1,735 3,470 200 a 160 b 0 205 20

WLI 100 A Inland Buoy Tender WLI 1 2,432 2,432 140 a 160 b 0 205 14

WLI 100 C Inland Buoy Tender WLI 1 2,068 2,068 119 a 160 b 0 205 12

WLI 65303 Inland Buoy Tender WLI 2 1,037 2,074 119 a 160 b 0 205 12

WLI 65400 Inland Buoy Tender WLI 2 1,142 2,284 131 a 160 b 0 205 13

WYTL 65 A 65 ft. Class Harbor Tugs 3 1,083 3,249 187 a 50 b 6 300 22

WYTL 65 B 65 ft. Class Harbor Tugs 3 1,083 3,249 187 a 50 b 6 300 22

WYTL 65 C 65 ft. Class Harbor Tugs 3 1,083 3,249 187 a 50 b 6 300 22

WYTL 65 D 65 ft. Class Harbor Tugs 2 1,083 2,166 125 a 50 b 6 300 15

 Army

BCDK Coversion Kit, Barge, Deck Cargo, Deck Enclosure 3 1,202 3,606 721 a 305 b 0 60 55

BD Barges, Derrick 12 1,627 19,524 6,072 c 305 b 0 60 461
Table 2. Vessels Estimated Annual Sacrificial Anode Cathodic Protection Discharges

Class Description

Quantity of 

Vessels w/ 

Zincs

Wetted Surface 

Area per Vessel 

(sq ft)

Wetted Surface 

Area of Class 

(sq ft)

Total 

Amount of 

Anodes by 

Class (lbs)

Days in 

Port per 

Vessel

Number of 

Transits per 

Vessel (e)

Days 

Operating 

within 12 

n.m.

Zinc Discharged 

within 12 n.m. 

(lbs)

BK Barges, Deck Cargo (nsp) 2 1,155 2,310 736 c 305 b 0 60 56

BPL Pier, Barge Type, Self-Evaluating (nsp) 1 4,955 4,955 991 a 305 b 0 60 75

FMS Floating Machine Shops 3 7,951 23,853 4,771 a 305 b 0 60 362

J-Boat Picket Boats 6 366 2,196 126 a 305 b 0 60 10

LARC-LX Lighter Amphibious Resupply Cargo(formerly BARC) 23 1,214 27,922 6,348 c 305 b 0 60 482

LCM-8 Landing Craft Mechanized 104 1,440 149,760 26,312 c 305 b 0 60 1,997

LCU Landing Craft Utility 48 2,095 100,560 45,264 c 305 b 0 60 3,435

LSV Frank S. Besson Class Logistic Support Vessels 6 17,816 106,896 17,802 c 183 b 6 60 988

LT Inland and Coastal Tugs 19 5,875 111,625 7,866 c 305 b 0 60 597

Q-Boat Picket Boat 1 806 806 161 a 305 b 0 60 12

ST Small Tugs 13 1,318 17,134 2,990 c 305 b 0 60 227

T-Boat Boat, Passenger and Cargo 1 1,335 1,335 77 a 305 b 0 60 6

TOTALS 1,805 10,825,814 1,859,992 113,201

Notes: 

(a) Denotes an estimate of amount of anodes on ship class based on a calculated wetted surface area.

(b) Denotes an estimate of days in port and number of transits.

(c) Denotes actual amount of anodes installed on ship class.

(d) Denotes an estimate of amount of anodes on ship class based on a known wetted surface area.

(e) Denotes round-trip transits

Vessels with a wetted surface area greater than 3,000 sq ft are assumed to have 23 pound of zinc anodes for each 115 sq ft of wetted surface area.

Vessels with a wetted surface area less than 3,000 sq ft are assumed to have 23 pounds of zinc anodes for each 400 sq ft of wetted surface area.
Table 3a. Chemical Composition, Zinc Anodes

(Galvanic Protectors)

Cadmium

(range)

Aluminum

(range)

Zinc

Percent Percent Percent

0.025-0.07 0.1-0.5 approx. 99.3

Table 3b. Chemical Composition, Aluminum Anodes

(Galvanic Protectors)

Indium

(range)

Zinc

(range)

Silicon

(range)

Aluminum

Percent Percent Percent Percent

0.014 - 0.020 4.0 - 6.5 0.08-0.20 approx. 95.2
Table 4. Submarines Estimated Annual Sacrificial Anode Cathodic Protection Discharge

Class Description Quantity of 

Submarines

Total Amount of 

Anodes by Class 

(lbs) (a)

Days in Port 

per Vessel

Number of 

Transits per 

Vessel (b)

Zinc Discharged within 

12nm (lbs)

SSBN 726 Ohio Class Ballistic Missle Submarine 17 34,408 183 6 1,175

SSN 637 Sturgeon Class Attack Submarine 13 26,312 183 6 899

SSN 688 Los Angeles Class Attack Submarine 56 119,416 183 6 4,079

SSN 671 Narwhal Class Submarines 1 2,024 183 6 69

SSN 640 Benjamin Franklin Class Submarines 2 4,048 183 6 138

Totals 89 186,208 6,360

Notes:

(a) Each submarine is assumed to have 88 anodes @ 23 pounds each to protect the prop and stern appendages only.

(b) Denotes round-trip transits
Table 5. Vessels Estimated Annual ICCP Discharges

Class Description

Quantity of 

Vessels 

w/ICCPs

Days within 

12 n.m. per 

Vessel

CPO 

Discharged 

within 12 n.m. 

(lbs)

Navy Combatant

CV 59 Forrestal Class Aircraft Carrier 1 143 350

CVN 65 Enterprise Class Aircraft Carrier 1 76 186

CV 63 Kitty Hawk Class Aircraft Carrier 3 137 1,007

CVN 68 Nimitz Class Aircraft Carrier 7 147 2,520

CG 47 Ticonderoga Class Guided Missile Cruisers 27 166 10,978

CGN 38 Virginia Class Guided Missile Cruiser 1 161 394

CGN 36 California Class Guided Missile Cruiser 2 143 701

DDG 993 Kidd Class Guided Missile Destroyers 4 175 1,715

DDG 51 Arleigh Burke Class Guided Missile Destroyers 18 101 4,453

DD 963 Spruance Class Destroyers 31 178 13,516

FFG 7 Oliver Hazard Perry Guided Missile Frigates 1 167 409

LCC 19 Blue Ridge Class Amphibious Command Ships 2 179 877

LHD 1 Wasp Class Amphibious Transport Docks 4 185 1,813

LHA 1 Tarawa Class Amphibious Assault Ships 5 173 2,119

LPD 4 Austin Class Amphibious Transport Docks 3 178 1,308

LPD 7 Amphibious Transport Docks 3 188 1,381

LPD 14 Amphibious Transport Docks 2 192 941

LSD 41 Whidbey Island Class Dock Landing Ships 8 170 3,331

LSD 49 Harpers Ferry Dock Landing Ships 3 215 1,580

PC 1 Cyclone Class Coastal Defense Ships 13 105 3,344

Navy Auxiliary

AFDB 4 Large Auxiliary Floating Dry Dock 1 365 e 894

AFDB 8 Large Auxiliary Floating Dry Dock 1 365 e 894

AFDL 1 Small Auxiliary Floating Dry Docks 2 365 e 1,788

AFDM 14 Medium Auxiliary Floating Dry Dock 1 365 e 894

AFDM 3 Medium Auxiliary Floating Dry Docks 4 365 e 3,576

AO 177 Jumboised Cimarron Class Oilers 5 188 2,302

AOE 6 Supply Class Fast Combat Support Ships 3 114 838

AOE 1 Sacramento Class Fast Combat Support Ship 4 183 1,793

ARDM Medium Auxiliary Repair Dry Docks 3 365 e 2,682

ARS 50 Safeguard Class Savage Ships 4 208 2,038

Military Sealift Command

T-AE 26 Kilauea Class Ammunition Ships 5 26 318

T-AFS 1 Mars Class Combat Stores Ships 6 148 2,175

T-AG 194 Mission Class Navigation Research Ship 1 151 370

T-AGM 22 Compass Island Class Missle Instrumentation Ship 1 133 326

T-AGS 45 Waters Class Surveying Ships 1 7 17

T-AGS 51 John McDonnel Class Surveying Ships 2 96 470

T-AGS 60 Pathfinder Class Surveying Ships 4 96 941

T-AH 19 Mercy Class Hospital Ships 2 184 901

T-AKR 295 Maesrk Class Fast Sealift Ships 2 59 289

T-AKR 287 Algol Class Vehicle Cargo Ships 6 109 1,602

T-AO 187 Henry J Kaiser Class Oilers 13 78 2,484

T-ARC 7 Zeus Class Cable Repairing Ship 1 8 20

T-ATF 166 Powhatan Class Fleet Ocean Tugs 5 127 1,555

U.S. Coast Guard

WAGB 399 Polar Class Icebreakers 2 148 725

WPB 110 A Island Class Patrol Craft 16 72 2,822

WPB 110 B Island Class Patrol Craft 21 137 7,047

WPB 110 C Island Class Patrol Craft 12 157 4,615

U.S. ARMY

LT Inland and Coastal Tugs 6 60 882

TOTALS 267 98,182

Estimates based on 100 % ICCP anode efficiency at a cuurent of 35 Amps producing 46.3 g/hr. of Chlorine.

(e) Denotes an estimate of days in port
Table 6a. Tidal Prism Model - Zinc From Sacrificial Cathodic Protection Anodes

Class Description

Quantity of 

Vessels w/ 

Zincs

Total 

Amount of 

Anodes by 

Class (kg)

Days in 

Port per 

Vessel

Number of 

Transits per 

Vessel (a)

Zinc 

Discharged in 

Port (kg) (b)

Zinc Conc. in 

Port (μg/L)

San Diego

FFG Oliver Hazard Perry Guided Missile Frigates 11 16,243 167 13 989

SSN Los Angeles Class Attack Submarines 9 8,261 183 6 389

SSN Sturgeon Class Attack Submarine 1 918 183 6 43

LSD Anchorage Class Dock Landing Ships 3 13,894 215 13 965

AGF Raleigh Class Miscellaneous Flagship 1 3,776 183 12 232

AS Emory S Land Class Submarine Tender 1 6,259 293 6 417

LPH Iwo Jima Class Assault Ship 1 4,527 186 11 269

Total 3,304 0.0876

Mayport

FFG Oliver Hazard Perry Guided Missile Frigates 10 14,766 167 13 899 1.35

Pearl Harbor

FFG Oliver Hazard Perry Guided Missile Frigates 2 2,953 167 13 180

SSN Los Angeles Class Attack Submarine 15 13,769 183 6 648

SSN Sturgeon Class Attack Submarine 4 3,672 183 6 173

SSN Benjamin Franklin Class Submarines 1 918 183 6 43

Total 1,043 0.306

(a) Denotes round-tip transits

(b) Based on a hourly zinc dissolution rates of 7.4E-6 lbs. of zinc/lb.anode (static) and 3.0E-5 lbs. of zinc/lb. anode (dynamic)
Table 6b. Tidal Prism Model - Aluminum and Mercury From Sacrificial Cathodic Protection Anodes

Class Description

Quantity of 

Vessels w/ 

Al Anodes 

(a)

Total 

Amount of 

Anodes by 

Class (kg)

Days in 

Port per 

Vessel

Number of 

Transits per 

Vessel (b)

Aluminum/ 

Mercury 

Discharged in 

Port (kg) (c)

Aluminum/ Mercury 

Conc. in Port 

(ng/L)

San Diego

SSN Los Angeles Class Attack Submarines 5 4,590 183 6 170 4.50 Al

0.0017 0.000045 Hg

Mayport

SSN Los Angeles Class Attack Submarines 0 0 0 Al

0 0 Hg

Pearl Harbor

SSN Los Angeles Class Attack Submarine 5 4,590 183 6 170 49.7 Al

0.0017 0.000497 Hg

(a) Assuming the maximum of 5 submarines with aluminum anodes are located Pearl Harbor and/or San Diego; there are no 

submarines homeported in Mayport. 

(b) Denotes round-tip transits

(c) Aluminum anode dissolution rates equals zinc anode dissolution dates divided by 3.4 (current capacity ratio)
Table 6c. Tidal Prism Model - CPO From Impressed Current Cathodic Protection Systems

Class Description

Quantity of 

Vessels w/ 

ICCP

Days in Port 

per Vessel

 CPO Discharged 

in Port (kg/yr)

CPO Conc. in 

Port (μg/L)

San Diego

CG 47 Ticonderoga Class Guided Missile Cruisers 8 166 1,476

CV 63 Kitty Hawk Class Aircraft Carrier 2 137 304

DD 963 Spruance Class Destroyers 6 178 1,187

DDG 51 Arleigh Burke Class Guided Missile Destroyers 5 101 561

LHA 1 Tarawa Class Amphibious Assault Ships 2 173 384

LHD 1 Wasp Class Amphibious Transport Docks 2 185 411

LPD 4 Austin Class Amphibious Transport Docks 5 178 989

LSD 41 Whidbey Island Class Dock Landing Ships 2 170 378

LSD 49 Harpers Ferry Dock Landing Ships 1 215 239

PC Cyclone Class Coastal Defense Ships 4 105 467

Total 6,395 0.1697

Mayport

CG 47 Ticonderoga Class Guided Missile Cruisers 5 166 922

CV 63 Kitty Hawk Class Aircraft Carrier 1 137 152

DD 963 Spruance Class Destroyers 5 178 989

DDG 51 Arleigh Burke Class Guided Missile Destroyers 2 101 224

Total 2,288 3.43

Pearl Harbor

AO 177 Jumboised Cimarron Class Oilers 2 188 418

ARS 50 Safeguard Class Savage Ships 2 208 462

CG 47 Ticonderoga Class Guided Missile Cruisers 3 166 553

DD 963 Spruance Class Destroyers 4 178 791

DDG 51 Arleigh Burke Class Guided Missile Destroyers 3 101 337

Total 2,561 0.751

Based on CPO generation rate of 46.3 g/hr. @ 35 amps
Table 7 - Mixing Zone Models

Sacrificial Anode - Zinc Concentration (ug/L) ICCP - CPO Concentration (ug/L)

Time of Exchange (hrs) Time of Exchange (hrs)

0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1

Distance 

From Hull(ft) 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1

24 47 71 94 118 142 165 189 213 236 0.1 43 86 129 172 216 259 302 345 388 431

4.7 9.3 14 19 23 28 33 37 42 47 0.5 8.5 17 26 34 43 51 60 68 77 85

2.3 4.6 6.9 9.2 11 14 16 18 21 23 1 4.2 8.5 13 17 21 25 30 34 38 42

1.1 2.2 3.3 4.4 5.6 6.7 7.8 8.9 10 11 2 2.1 4.1 6.2 8.3 10 12 14 17 19 21

0.72 1.4 2.2 2.9 3.6 4.3 5.0 5.8 6.5 7.2 3 1.4 2.7 4.1 5.4 6.8 8.1 9.5 11 12 14

0.52 1.0 1.6 2.1 2.6 3.1 3.7 4.2 4.7 5.2 4 1.0 2.0 3.0 4.0 5.0 6.0 6.9 7.9 8.9 10

0.41 0.81 1.2 1.6 2.0 2.4 2.8 3.3 3.7 4.1 5 0.78 1.6 2.3 3.1 3.9 4.7 5.4 6.2 7.0 7.8

0.33 0.66 0.99 1.3 1.6 2.0 2.3 2.6 3.0 3.3 6 0.64 1.3 1.9 2.5 3.2 3.8 4.5 5.1 5.7 6.4

0.28 0.55 0.83 1.1 1.4 1.7 1.9 2.2 2.5 2.8 7 0.53 1.1 1.6 2.1 2.7 3.2 3.7 4.3 4.8 5.3

0.23 0.47 0.70 0.94 1.2 1.4 1.6 1.9 2.1 2.3 8 0.46 0.92 1.4 1.8 2.3 2.8 3.2 3.7 4.1 4.6

0.20 0.41 0.61 0.81 1.0 1.2 1.4 1.6 1.8 2.0 9 0.40 0.80 1.2 1.6 2.0 2.4 2.8 3.2 3.6 4.0

0.18 0.36 0.54 0.71 0.89 1.1 1.2 1.4 1.6 1.8 10 0.35 0.71 1.1 1.4 1.8 2.1 2.5 2.8 3.2 3.5

0.11 0.21 0.32 0.42 0.53 0.63 0.74 0.85 0.95 1.1 15 0.22 0.43 0.65 0.87 1.1 1.3 1.5 1.7 1.9 2.2

0.071 0.14 0.21 0.29 0.36 0.43 0.50 0.57 0.64 0.71 20 0.15 0.30 0.45 0.60 0.75 0.90 1.0 1.2 1.3 1.5

0.052 0.10 0.16 0.21 0.26 0.31 0.36 0.42 0.47 0.52 25 0.11 0.22 0.33 0.45 0.56 0.67 0.78 0.89 1.0 1.1

0.040 0.080 0.12 0.16 0.20 0.24 0.28 0.32 0.36 0.40 30 0.087 0.17 0.26 0.35 0.43 0.52 0.61 0.69 0.78 0.87

0.031 0.063 0.094 0.13 0.16 0.19 0.22 0.25 0.28 0.31 35 0.070 0.14 0.21 0.28 0.35 0.42 0.49 0.56 0.63 0.70

0.026 0.051 0.077 0.10 0.13 0.15 0.18 0.20 0.23 0.26 40 0.057 0.11 0.17 0.23 0.29 0.34 0.40 0.46 0.52 0.57

0.021 0.042 0.064 0.085 0.11 0.13 0.15 0.17 0.19 0.21 45 0.048 0.10 0.14 0.19 0.24 0.29 0.34 0.39 0.43 0.48

0.018 0.036 0.054 0.072 0.090 0.11 0.13 0.14 0.16 0.18 50 0.041 0.082 0.12 0.16 0.21 0.25 0.29 0.33 0.37 0.41

0.009 0.018 0.027 0.036 0.046 0.055 0.064 0.073 0.082 0.091 75 0.022 0.043 0.065 0.087 0.11 0.13 0.15 0.17 0.20 0.22

0.006 0.011 0.017 0.022 0.028 0.033 0.039 0.044 0.050 0.055 100 0.013 0.027 0.040 0.054 0.067 0.081 0.094 0.11 0.12 0.13

Input For Calculations Input For Calculations

Ship Class FFG 7 Ship Class CG 47

Wetted Hull Area (sqft) 19,850 Wetted Hull Area (sqft) 37,840

Zinc Generation Rate (lb/lb-hr) 7.4E-06 CPO Generation Rate (g/hr) 46.3

CPO Generation Efficiency 100%
Table 8. Comparison of Constituent Environmental Concentrations and Water Quality Criteria (μg/L)

Constituent Tidal Prism Concentrations: San 

Diego; Mayport; Pearl Harbor 

Federal Chronic 

WQC

Most Stringent State Chronic 

WQC

CPO 0.17; 3.43; 0.75 - 7.5 (CT, HI, MS, NJ, VA, WA)

Zinc 0.09; 1.35; 0.31 81 76.6 (WA)

Aluminum 0.000005; 0; 0.049 None 1,500 (FL)

Mercury* 0.00000004; 0; 0005 0.025 0.025 (CT, FL, GA, MS, VA, WA)

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

NJ = New Jersey

MS = Mississippi

VA = Virginia

WA = Washington

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22, 

1992 and 60 FR 22230; May 4, 1995)

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the 

most stringent (dissolved or total) state water quality criteria.

* Bioaccumulator
Table 9. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X X

2.2 Releases to the Environment X X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X X X

3.2 Rate X X

3.3 Constituents X X

3.4 Concentrations X X

4.1 Mass Loadings X X

4.2 Environmental Concentrations X X X

4.3 Potential for Introducing NonIndigenous SpeciesX
Figure 1. Sacrificial Anode and Impressed Current Cathodic Protection
Figure 2. Electrochemical Cell
Figure 3. Impressed Current Cathodic Protection System
1. Observed Zinc Consumption Rate: Per 23-lb Anode Per Pound of Anode

 (aggregate of in-port and underway)

50% of 23 lb/3 years 3.83 (lb zinc/yr)/ 23 lb anode

= 3.83 lb zinc/yr = 0.167 lb zinc/yr/lb of anode

2. Fraction of Year Vessel is: In Port Underway

176 days/yr 189 days/yr

365 days/yr 365 days/yr

= 0.48 = 0.52

3. Annual Zinc Corrosion/Dissolution Rate:

 let x = in port corrosion/dissolution rate, 

 and 4x = underway corrosion/dissolution rate 0.48 (x) + 0.52 (4) (x) = 0.167 (lb zinc/yr)/lb of anode

 x = 0.065 (lb zinc/yr)/lb of anode

4x = 0.261 (lb zinc/yr)/lb of anode

note: the underway corrosion/dissolution rate is 4 times the in port rate as discussed in section 3.2.1

and reference 3 and 10.

4. Hourly zinc corrosion/dissolution rate: In-Port Underway

 (per lb anode)

0.065 (lb zinc/lb anode)/yr 0.261 (lb zinc/lb anode)/yr

 8760 hr/yr 8760 hr/yr

= 7.4 x 10-6 (lb zinc/lb anode)/hr = 3.0 x 10-5 (lb zinc/lb anode)/hr

5. Unit conversion:

Average density of zinc anodes (Table 2) = (1,862,000 lb) / (10,861,000 ft2) = 0.17 lb/ft2

In-Port: (7.4 x 10-6 (lb zinc/lb anode)/hr) ( 0.17 lb/ft2) = 1.3 x 10-6 (lb zinc/ft2)/hr

Underway (3.0 x 10-5 (lb zinc/lb anode)/hr) ( 0.17 lb/ft2) = 5.1 x 10-6 (lb zinc/ft2)/hr

Calculation Sheet 1. Calculation of Corrosion/Dissolution Rates from Sacrificial Anodes
Vertical tidal excursions for 1996 is based on the summation of the daily outgoing tides ( i.e., high-high

water to low-low water and high water to low water).

San Diego

• Surface Area = (10,532 acres) (4046.2 m2/acre) = 4.26 x 107 m

2

• Total annual vertical tidal excursion for 1996 = 884.5 m

 Average tidal excursion = (884.5 m/yr)/((365 days/yr)(2 tides/day) = 1.2 m

• Tidal prism volume for 1996 = (4.26 x 107 m

2

) (884.5 m) = 3.77 x 1010 m3

 = 3.77 x 1013 L

Mayport

• Surface Area = (169.8 acres) (4046.2 m2/acre) = 6.87 x 105 m2

• Total annual vertical tidal excursion for 1996 = 970.3 m

 Average tidal excursion = (970.3 m/yr)/((365 days/yr)(2 tides/day) = 1.3 m

• Tidal prism volume for 1996 = (6.87 x 105 m2) (970.3 m) = 6.67 x 108 m3

 = 6.67 x 1011 L

Pearl Harbor

• Surface Area = (3,031 acres) (4046.2 m2/acre) =1.23 x 107 m2

• Total annual vertical tidal excursion for 1996 = 278.2 m

 Average tidal excursion = (278.2 m/yr)/((365 days/yr)(2 tides/day) = 0.38 m

• Tidal prism volume for 1996 = (1.23 x 107 m2) (278.2 m) = 3.41 x 109 m3

 = 3.41 x 1012 L

Calculation Sheet 2. Calculation of Tidal Prism Volumes for San Diego, CA; Mayport,

FL; and Pearl Harbor, HI
1. Concentration = (Mass of Zinc) / (Volume)

2. Volume modeled as a half-immersed cylinder:

 

R1

R1 + d

Length

 Ship Class: FFG 7

 Length = 415 ft

 Underwater Wetted Area = 19,850 ft2 = 1⁄2(2)(π)(R1)(length)

 ==> R1 = 15.225 ft(1)

 Volume(model) = V2 - V1

 V1 = 1⁄2π(R1)

2

(length) = 151,110 ft3 

 V2 = 1⁄2π(R1 + d)2(length)

 d = variable (1 ft for this sample calculation)

 Volume = V2 - V1 = [1⁄2π(15.225 ft + 1 ft)2(415 ft)] - (151,110 ft3)

 = 20,500 ft3

3. Mass of zinc:

 Mass = (generation rate)(mass of anode installed)(time between water exchanges)

 Generation rate = 7.4 x 10-6 (lb zinc/lb anode-hr)

 Mass of installed anodes = (172 anodes)(23 lb/anode) = 3,956 lb

 Time between water exchanges = variable (1 hr for this sample calculation)

 Mass of zinc generated = (7.4 x 10-6 (lb zinc/lb anode-hr))(3,956 lb)(1 hr)

 = 0.029 lb zinc

4. Concentration:

 Concentration = (Mass of Zinc)/(Volume)(required conversion factors)

 = (0.029 lb zinc)(454 g/lb)(106mg/g)/[(20,500 ft3)(28.32 L/ft3)]

 = 22.7 μg/L ≅ 23 μg/L

notes:

(1) Additional significant figures recommended in this step due to subsequent squaring operation.

Calculation Sheet 3. Zinc Concentration (Mixing Zone Model) Sample Calculations
1. Concentration = (Mass of CPO) / (Volume)

2. Volume modeled as a half-immersed cylinder:

 

R1

R1 + d

Length

 Ship Class: CG 47

 Length = 533 ft

 Underwater Wetted Area = 37,840 ft2 = 1⁄2(2)(π)(R1)(length)

 ==> R1 = 22.598 ft(1)

 Volume(model) = V2 - V1

 V1 = 1⁄2π(R1)

2

(length) = 427,558 ft3 

 V2 = 1⁄2π(R1 + d)2(length)

 d = variable (1 ft for this sample calculation)

 Volume = V2 - V1 = [1⁄2π(22.598 ft + 1 ft)2(533 ft)] - (427,558 ft3)

 = 38,677 ft3

3. Mass of CPO:

 Mass = (generation rate)(efficiency)(time between water exchanges)

 Generation rate = 46.g/hr

 Efficiency = 100%

 Time between water exchanges = variable (1 hr for this sample calculation)

 Mass of CPO generated = (46.3 g/hr)(100%)(1 hr)

 = 46.3 g

4. Concentration:

 Concentration = (Mass of CPO)/(Volume)(required conversion factors)

 = (46.3 g CPO)(106mg/g)/[(38,677 ft3)(28.32 L/ft3)]

 = 42.3 μg/L ≅ 42 μg/L

notes:

(1) Additional significant figures recommended in this step due to subsequent squaring operation.

Calculation Sheet 4. CPO Concentration (Mixing Zone Model) Sample Calculations
Chain Locker Effluent

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Chain Locker Effluent
Chain Locker Effluent

2

2.0 DISCHARGE DESCRIPTION

This section describes the chain locker effluent and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Surface vessels of the Armed Forces have one to three anchors, depending on vessel

class.1 Each surface vessel’s anchor is attached to at least 810 feet (135 fathoms) of steel chain

that is stored below decks in the chain locker when not in use. The chain is constructed in 90-foot

(15-fathom) lengths, called “shots,” which are connected together by detachable links. A diagram

of a typical detachable link is provided in Figure 1. The inside of each detachable link is greased

to prevent binding and corrosion, and to permit easy disassembly of the detachable parts. The

chain locker is an enclosed compartment used only to store the anchor chain.2 The bottom of the

locker has a grating on which the chain is stowed. Below the grating is a sump. The chain locker

sump contains multiple zinc sacrificial anodes to prevent corrosion. The anodes are physically

connected (e.g. by bolts or welding) to the steel surface of the chain locker sump. The zinc

anode is preferentially corroded or “sacrificed” instead of the chain locker sump’s steel surface.

The chain moves through the chain pipe and the hawse pipe as the anchor is raised or

lowered. The chain pipe connects the chain locker to the deck and the hawse pipe runs from the

deck through the hull of the ship. When recovering the anchor, the anchor and chain are washed

off with a fire hose to remove mud, marine organisms, and other debris picked up during

anchoring. Seawater from the fire hose is directed either through the hawse pipe or directly over

the side onto the chain while recovering the anchor.

The top of the chain pipe has a canvas sleeve to keep water from entering the chain locker

through the chain pipe. Under rare circumstances, like heavy weather, rain or green water

(seawater that comes over the bow during heavy weather) gets under the chain pipe canvas cover

and into the chain locker. A diagram of a typical chain locker is provided in Figure 2.

Any fluid that accumulates in the chain locker sump is removed by either a drainage

eductor for discharge directly overboard or by draining the chain locker effluent into the bilge.

As the fluid in the chain locker sump is being drained for overboard discharge, the locker is

sprayed with firemain water to flush out sediment, mud, or silt. An eductor is a pumping device

that uses a high velocity jet of seawater from the firemain system to create a suction to remove

the accumulated liquids and solids. The seawater supply from the firemain system is referred to

as motive water for the eductor. OPNAVINST 5090.1B, Section 19-10 requires chain lockers of

Navy vessels to be washed down outside of 12 n.m. to prevent the transfer of non-indigenous

species and to flush out any sediment, mud, or silt.2 Chain locker effluent which is drained into

the bilge becomes bilgewater and is covered by the Surface Vessel Bilgewater/OWS Discharge

NOD report.

2.2 Releases to the Environment
Chain Locker Effluent

3

Chain locker effluent has the potential to contain living plants and animals, including

microorganisms and pathogens, that are native to the location where the water was brought

aboard during anchor retrieval. Chain locker effluent can also contain paint, rust, grease, and

zinc. The chain locker and eductor operations are performed using water from the firemain.

Therefore, the chain locker effluent can contain any constituents present in firemain water (see

Firemain NOD report).

2.3 Vessels Producing the Discharge

Chain locker discharges occur in surface ships equipped with a wet firemain, including

vessels belonging to the Navy, U.S. Coast Guard, Military Sealift Command, Army, and Air

Force.3 Submarine chain lockers are always submerged, open to the sea, and do not collect

effluent to produce this discharge.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

The Navy has an instruction for chain locker effluent discharge.2 This instruction states

that following anchor retrieval, chain lockers shall be washed down outside 12 miles from land to

flush out any sediment, mud, and silt. This guideline also helps prevent the transfer of unwanted

pathogens and marine organisms present in chain locker effluent.

3.2 Discharge Rate

Rated capacities of the eductors used to pump out chain locker sumps range between 50

and 150 gallons per minute. The chain locker effluent is mixed directly with the motive water

from the firemain system before going overboard. The eductor uses 1/2 to 1 gallon of motive

water for every gallon of effluent. Therefore, the total discharge ranges between 75 and 300

gallons per minute, of which 25 to 150 gallons per minute is motive water. The amount of

effluent discharged yearly cannot be measured because the discharge is infrequent and little

effluent is discharged.

3.3 Constituents

The small amount of water that is washed into the chain locker drains through the bottom

grating and into the sump where it contacts paint chips, rust, grease, and sacrificial zinc anodes.

This water has the potential to contain marine organisms.
Chain Locker Effluent

4

The chain locker is painted using epoxy polyamide, epoxy, and zinc primer.1,4,5,6

The detachable links and other anchor chain components are periodically lubricated with

Termalene #2, a water-resistant grease (Commercial Item Description (CID) A-A-50433).

Termalene #2 is a compound that includes mineral oil, an aluminum complex, a calcium-based

rust inhibitor, an antioxidant, and dye.7 The grease was tested for resistance to washout.8,9 This

test measures the water washout characteristics of lubricating greases under elevated

temperatures and mechanical operating conditions. Termalene #2 experienced “nil” washout

when tested.9 Because the grease is not exposed outside the link and due to the wash-resistant

nature of the grease, it is unlikely grease would be released to the environment.

The zinc anodes in the chain locker can be in contact with seawater for extended periods

of time. Zinc can leach continuously into the chain locker sump. The water that collects in the

chain locker is a combination of seawater and water from the firemain. Also, firemain water is

used as motive water when chain locker effluent is discharged. Therefore, the water could

contain the constituents present in the firemain water. A more complete discussion of these

constituents is found in the Firemain Systems NOD report.

The chain locker effluent might contain the priority pollutants bis(2-ethylhexyl) phthalate,

copper, iron, nickel, and zinc. This effluent does not contain any bioaccumulators.

3.4 Concentrations

The concentrations of constituents present in the chain locker cannot be easily measured.

Chain lockers are kept dry on most vessels to reduce maintenance. Zinc anodes are present in the

bottom of the chain locker. Because the chain locker is often dry, it is unlikely that these anodes

significantly affect the concentration of zinc in the effluent. The average measured

concentrations of firemain water constituents that exceed the Federal and/or most stringent water

quality criteria are presented in Table 1.10 Firemain is used as the motive water for drainage

eductors.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. Mass loadings are

discussed in Section 4.1 and the concentrations of discharge constituents after release to the

environment are discussed in Section 4.2. In Section 4.3, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

Mass loadings were not calculated because constituent concentrations were not estimated.

Chain locker effluent is not anticipated to result in significant loads within 12 n.m. because of the
Chain Locker Effluent

5

infrequency of discharge and because of the management practices in place which pump this

discharge overboard when the vessel is beyond 12 n.m. of shore. Chain locker effluent is

discharged infrequently because only small volumes of water accumulate in the chain locker

sump over time. This determination was made after inspections of chain lockers aboard several

ships.10,11

4.2 Environmental Concentrations

Chain locker effluent is expected to contain zinc, rust, paint, grease, and any constituents

from the firemain water. Because of the intermittent nature of this discharge, acute toxicities are

the primary concern. There is no concentration data available for chain locker effluent. Table 1

shows the concentration of constituents of firemain water that total nitrogen, bis(2-ethylhexyl)

phthalate, copper, iron, and nickel, exceed the Federal and/or the most stringent state acute water

quality criteria.

4.3 Potential for Introduction of Non-Indigenous Species

Inspections of chain lockers aboard several ships revealed that only small amounts of

water actually accumulate within the chain locker. Therefore, there is little potential for

introducing non-indigenous species into the chain locker. The process of washing down the

anchor as it is taken aboard and discharging the effluent beyond 12 n.m. further reduces the

possibility of transferring species via the chain locker.2

5.0 CONCLUSIONS

The small volume of chain locker effluent results in small mass loadings and provides

little opportunity for the transfer of non-indigenous species. The discharge volume is expected to

be small even if the discharge was not controlled. Therefore, this discharge has a low potential

for causing adverse environmental effects.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 2

shows the source of the data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Anchor Chain Washdown and Chain Locker

Effluent. July 30, 1996.

2. OPNAVINST 5090.1B, Environmental and Natural Resources Program Manual,

November 1 1994.
Chain Locker Effluent

6

3. UNDS Round 2 Equipment Expert Meeting Minutes. March 11, 1997.

4. Military Specification MIL-P-24441, Epoxy polyamide. July 1991.

5. Performance Specification MIL-PRF-23236, Epoxy. April 1990.

6. Naval Ships’ Technical Manual (NSTM). Chapter 631, Paragraph 8.23.2.1. Preservation

of Ships in Service. December 1996.

7. Bel Ray Company, Inc., Material Safety Data Sheet for Termalene #2. 1996.

8. The American Society for Testing and Materials (ASTM) test method D-1264. June

1996.

9. Bel Ray Company, Inc., Product Data Sheet for Termalene #2. 1993.

10. UNDS Phase 1 Sampling Data Report. Volumes 1-13, October 1997.

11. Navy Fleet Technical Support Center Pacific (FTSCPAC) Inspection Report Regarding

Elevator Pit and Anchor Chain Locker Inspection Findings on Six Navy Ships, March 3,

1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.
Chain Locker Effluent

7

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Van der Leeden, et al. The Water Encyclopedia, 2nd Ed. Lewis Publishers: Chelsea, Michigan,

1990.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. 23 March 1995.
Chain Locker Effluent

8

Figure 1. Schematic Diagram of a Typical Detachable Chain Link
Chain Locker Effluent

9

Figure 2. Schematic Diagram of a Typical Chain Locker
Chain Locker Effluent

10

Table 1. Concentrations of Constituents of Wet Firemain Discharge

that Exceed Water Quality Criteria

Constituents Log-normal

Mean

Effluent

Minimum

Concentration

Effluent

Maximum

Concentration

Effluent

Federal Acute

WQC

Most Stringent

State Acute WQC

Classicals (μg/L)

Total Nitrogen 500 None 200 (HI)A

Organics (μg/L)

Bis(2-ethylhexyl)

phthalate

22 BDL 428 None 5.92 (GA)

Metals (μg/L)

Copper

 Dissolved 24.9 BDL 150 2.4 2.4 (CT, MS)

 Total 62.4 34.2 143 2.9 2.5 (WA)

Iron

 Total 370 95.4 911 None 300 (FL)

Nickel

 Dissolved 13.8 BDL 38.9 74 74 (CA, CT)

 Total 15.2 BDL 52.1 74.6 8.3 (FL, GA)

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

CA = California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington

Table 2. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and Operation X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents PMS Cards (a) X

3.4 Concentrations unknown

4.1 Mass Loadings unknown

4.2 Environmental Concentrations unknown

4.3 Potential for Introducing NonIndigenous Species

X

(a) PMS - Navy planned maintenance system
Clean Ballast

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Clean Ballast
Clean Ballast

2

2.0 DISCHARGE DESCRIPTION

This section describes the clean ballast discharge and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Ballast water is carried by many types of vessels and is held in a variety of tanks. The

relative complexity of ballast operations depends on the size, configuration, and requirements of

the vessel and on the complexity of its pumping and piping systems.

Clean ballast water is seawater which is introduced into dedicated ballast tanks to adjust a

vessel’s draft, buoyancy, trim and list, and to improve stability under various operating

conditions. For example, ballast water is used on various vessel classes to replace the weight of

off-loaded cargo or expended fuel oil. Generally, seawater is directed to the ballast tanks from

the firemain, by flooding, and/or from dedicated ballast pumps. Ballast intake systems are

usually covered with a grate; suction strainers can be used to protect the pumping system from

debris. Ballast water is discharged through valves by gravity or pressurized air, or is pumped out

by eductors. Clean ballast tanks are dedicated to ballasting operations and their contents are not

mixed with fuel or oil.

Amphibious assault ships also flood clean ballast compartments during landing craft

operations to lower the ship’s stern, allowing the well deck to be accessed. This ballast water is

subsequently discharged at the end of the operation. Figure 1 depicts a typical amphibious ship

ballast and deballast tank system.

U.S. Navy submarines have main and variable ballast systems. The main ballast system

controls the submarine’s overall buoyancy while the variable ballast system controls the

submarine’s trim and list, and adjusts for variations in the submarine’s buoyancy while operating

submerged.

2.2 Releases to the Environment

Ballast water has the potential to contain plants and animals, including microorganisms

and pathogens, that are native to the location where the water was brought aboard. When the

ballast water is transported and discharged into another port or coastal area, the surviving

organisms have the potential to impact the local ecosystem. Ballast water also has the potential

to contain metals and chemical constituents from contact with piping systems and ballast tank

coatings. Releases to the environment occur when ballast water is discharged.

2.3 Vessels Producing the Discharge

Ballast water collection and discharge practices depend on vessel class and mission

characteristics. Most surface vessels in the Navy have clean ballast systems, including the
Clean Ballast

3

following vessel classes: amphibious assault ships (LHD, LHA, LPH), aircraft carriers

(CV/CVN), amphibious transport docks (LPD), frigates (FFG), dock landing ships (LSD), oilers

(AOE), and amphibious command ships (LCC). All U.S. Navy submarines (SSNs and SSBNs)

have main and variable ballast systems.

U.S. Coast Guard (USCG) vessels that have designated seawater ballast tanks include the

following classes: medium endurance cutters (WMEC), sea going buoy tenders (WLB), and ice

breakers (WAGB).

Most Military Sealift Command (MSC) have clean ballast systems, including the

following vessel classes: fleet-support auxiliary ships (T-AFS, T-AE, and T-AO), point-to-point

supply ships (T-AKR) and other ships (T-AH, T-AGS, T-AGOS, T-AGOR, T-AG, T-AGM, and

T-ATF).1

Army ships designed for intra-theater cargo transport (LCU-2000 and LSV) take on and

discharge clean ballast when loading and unloading cargo and equipment. Vessels of the Air

Force also discharge ballast water within 12 nautical miles (n.m.) of shore.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

The mode and location of ballast water discharge differs for Navy, USCG, MSC, Army,

and Air Force vessels, and also varies among individual ship classes depending on the mission or

design of the vessel. Discharge of ballast water is intermittent for vessels of each service.

Discharges can occur in port or at sea depending upon service policies and the individual vessel’s

operational requirements. Ballast water is normally released at sea (outside of 12 n.m.) or in the

same general vicinity from which it was taken aboard.

In order to adopt the intent of guidelines established by the International Maritime

Organization (IMO), the Navy has instituted a “double-exchange” policy for surface vessels.2

All Navy surface vessels completely offload ballast water originating in a foreign port outside of

12 n.m. from shore and take on and discharge ‘clean sea water’ two times prior to entry within 12

n.m. of shore. The seawater then can be discharged within 12 n.m. of shore whenever ballast is

no longer needed.

All submarines submerge by filling externally mounted main ballast tanks (MBTs) and

surface by emptying them. Discharges from MBTs happen mainly during surfacing when

seawater in MBTs is displaced overboard by air forced into the tanks. The majority of
Clean Ballast

4

submarines submerge and surface outside of 12 n.m. of shore, however, submarines on occasion

do surface and submerge within 12 n.m. of shore at selected ports where ocean depth and vessel

traffic permit this practice. While transiting on the surface from port, variable ballast water can

be discharged to make small adjustments to the ship’s trim. Once the submarine submerges, the

variable ballast system is used as necessary to maintain trim and stability. In port, both main and

variable ballast can occasionally be taken on or discharged to support maintenance activities or to

compensate for weight changes. Any ballast water taken on by the MBTs in port is discharged

prior to leaving port. While visiting foreign ports, submarines avoid taking water into the

variable ballast system. If additional variable ballast water is required, submarines take on

freshwater to prevent fouling of systems and equipment.

Amphibious ships take on ballast water in coastal waters (within 12 n.m.) during landing

craft operations and discharge it at the conclusion of those operations in the same general

location.

USCG vessels do not discharge ballast water collected near one coastal area into another

coastal area. Coast Guard vessels are required to exchange their ballast water twice beyond 12

n.m. of shore, if the water originated from within 12 n.m.3, 4

MSC vessels may discharge clean ballast both at sea and in port. The location of the

discharge varies by vessel category. Fleet-support auxiliary ships typically load ballast at sea

when discharging cargo and unload ballast near shore when taking on cargo. Point-to-point

supply ships typically ballast to replace the weight of consumed fuel, not to compensate for off

loaded cargo, and deballast occurs after a voyage, usually in port. The remaining ships of the

MSC fleet typically ballast to bring the ship to an appropriate draft and trim for mission

requirements. Some of these ships may hold ballast for long periods and others may use

freshwater ballast only.1 Although an official MSC policy has not yet been approved, many

MSC vessels currently abide by IMO guidelines, which recommend exchanging ballast water in

waters 2,000 meters or more in depth before entering coastal zones.5

Navy, USCG, and IMO policies for surface vessels are summarized in Table 1.

3.2 Rate

The volume of seawater discharged during deballasting operations varies by vessel class

and activity. Typical ballasting operations on surface ships only use a portion of the total ballast

capacity. For example, the average maximum ballast carried by a T-AO 187 Class ship has been

reported to be around 50% of capacity, although the actual quantity of ballast varies significantly

depending on the quantity of cargo carried.1

Total capacity of individual ballast systems varies significantly by vessel class. The LSD

41 Class and T-AO 187 Class ships have ballast tanks with a capacity of three million gallons.

T-AKR 287 Class ships have a total ballast capacity of approximately 1.2 million gallons, while

the MSC oceanographic research ship, USNS Vanguard (T-AG 194), carries approximately 1.7

million gallons of freshwater ballast that is only emptied in dry dock during tank inspections.1,6
Clean Ballast

5

Other ship capacities for Navy and USCG vessels are as shown in Table 2.

Deballasting flow rates also vary significantly by vessel class. Deballasting methods

include gravity fed systems, eductor systems, or compressed air pumps with associated drain

valves. Typical air compressors that pressurize and empty ballast tanks on board amphibious

ships are rated for 2,000 standard cubic feet per minute (scfm) air flow which is sufficient to

displace an equivalent of 14,960 gallons per minute (gpm) of ballast water. Main ballast tanks

on submarines are typically evacuated within 30 minutes using pressurized air.7

3.3 Constituents

Constituents of clean ballast may include material from piping and piping components,

coatings, and additives.

Rust inhibitors containing aliphatic petroleum distillates are commonly applied to some

MSC ballast tanks. Additional constituents may include flocculant chemicals, composed of 95%

water and 5% salts and polymers.8 Flocculant chemicals are introduced in ballast tanks of some

MSC vessels to facilitate the discharge of suspended silts during deballasting operations.

Sediments frequently accumulate on the bottom and on many horizontal surfaces of ballast tanks

and may be discharged during deballasting operations. Lead-block ballast are also present in the

ballast tanks on some MSC vessels.

Metals and chemical constituents can be introduced to ballast water through contact with

piping systems and ballast tank coatings. Constituent loadings are expected to increase with

increased residence time of water in the clean ballast systems. The composition of piping and

components that contact ballast water includes iron, copper, nickel, bronze, titanium, chromium,

and composites. These composites are a linen reinforced graphite phenolic compound and

reinforced epoxy matrix. Fitting and valve materials include aluminum, copper, nickel, and

silver-brazed materials. Synthetic and cloth-rubber gaskets, nitrile seals, and ethylene propylene

rubber O-ring seals may also be wetted parts of the ballast system.9,10

The interiors of tanks of Navy vessels are typically coated with epoxy coatings, and the

tanks can contain zinc or aluminum anodes for cathodic protection.11,12 Ballast tank coating

specifications list the following constituents: polyamide, magnesium silicate, titanium dioxide, a

solvent, naphtha, and epoxy resin. Specifications also dictate the maximum allowable

concentrations of solvents in epoxy coatings.

Firemain systems are used to fill many clean ballast tanks. Although concentrations in

firemain discharge cannot be directly correlated with constituent concentrations in clean ballast

water, analytical data obtained from sampling of shipboard firemain systems could serve as an

indicator of potential constituents introduced to clean ballast water. Based on the make up of

clean ballast systems and the analytical results of firemain discharge sampling, the following

priority pollutants could be present within the discharge: copper, nickel, and zinc. No

bioaccumulators are known or suspected to be present in clean ballast discharge.
Clean Ballast

6

3.4 Concentrations

Although suspected constituents in clean ballast discharge have been identified,

constituent concentrations were not estimated.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. Mass loadings are

discussed in Section 4.1 and the concentrations of discharge constituents after release to the

environment are discussed in Section 4.2. In Section 4.3, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

Using known tank volumes and numbers of vessels in specific classes, an estimate of the

total ballast capacity is presented in Table 2. Most surface vessels are required to conduct double

exchanges outside of 12 n.m. of shore unless the discharge of the clean ballast is located in the

same geographical region as the intake, or operational conditions prevent the double flush from

being performed. Additional ballast exchanges occur within 12 n.m. Although total ballast

capacity estimates have been made, mass loading of chemical constituents were not estimated

due to the uncertainty in the frequency of ballasting operations and the lack of chemical

constituent data.

4.2 Environmental Concentrations

Although water quality criteria are available for suspected constituents, no analyses have

been completed and constituent concentrations are not available. A comparison of

concentrations with water quality criteria was not made.

4.3 Potential for Introducing Non-indigenous Species

Discharged clean ballast water from vessels of the Armed Forces has potential for

introducing non-indigenous species into receiving waters. This can be inferred from studies of

commercial vessels.

Studies of foreign ballast water commonly introduced into the Chesapeake Bay found that

more than 90% of the commercial vessels carried live organisms. Forty percent of the sampled

vessels had organisms within their ballast tanks including dinoflagellates and diatoms. Such

organisms are suspended in both water and sediments within ballast tanks. Organisms also may

attach to tank walls and be dislodged during deballasting.13 One study characterized a variety of

non-indigenous species in 159 cargo vessels arriving in Coos Bay, Oregon, from 25 different

Japanese ports. The study found 367 distinctly identifiable taxa, representing 16 animal phyla, 3

protist phyla, and 3 plant divisions. Organisms present in most vessels included copepods (99%
Clean Ballast

7

of vessels), polycheate worms (89%), barnacles (83%), clams and mussels (71%), flatworms

(65%), crabs and shrimp (48%), and chaetognaths (47%).13

The preliminary conclusion of a Smithsonian Environmental Research Center (SERC)

study of three Navy surface ships’ ballast water during transit of the Atlantic is that the doubleexchange of ballast water can be a “very effective” method of preventing the introduction of nonindigenous species. The SERC study performed a double-exchange of clean ballast water

containing a known number/concentration of microbials and found that 95% to 100% of the

microbials were removed.14 The SERC study noted that a “large number” of the microbials

would not have survived the transit even if the double exchange of ballast water had not been

performed. Therefore, the percentage reduction of the number or type of non-indigenous species

transported in the ballast water of Navy surface vessels achieved by double-exchange has not

been determined.

Although the presence of non-indigenous species has been verified by previous studies of

commercial vessels, exact densities of individual species introduced through deballasting

operations of vessels of the Armed Forces have not been evaluated.

5.0 CONCLUSION

Clean ballast discharges have a potential to cause an adverse environmental effect

because clean ballast water has the potential for transferring non-indigenous species between

ports.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information, equipment specifications, and research concerning non-indigenous species was

used. Table 3 shows the sources of data used to develop this NOD report.

Specific References

1. Weersing, Penny, Point Paper - Supplemental Information about Ballast Water - MSC

Ships. 31 October 1996.

2. Department of the Navy, Office of the Chief of Naval Operations. Summary Matrix of

OPNAVINST 5090.1B, Environmental and Natural Resources Program Manual, Chapter

19-10 (Ship Ballast Water and Anchor System Sediment Control Requirements). 1

November 1994.

3. Directive Order. COMLANTAREA COGARD, Portsmouth, VA to LANT CUTTER

FLT. Ballast Water Exchange Program, 14 August 1996.
Clean Ballast

8

4. Directive Order. COMPACAREA COGARD, Alameda, CA. PACAREA Aquatic

Prevention Program, 12 November 1996.

5. Weersing, Penny, Attachment 4, Point Paper - Supplemental Information about Ballast

Water - MSC Ships. Summary Matrix of OPNAVINST 5090.1B. 31 October 1996.

6. UNDS Equipment Expert Meeting Minutes - Clean Ballast. 18 September 1996.

7. Letter from Commander Submarine Force, U. S. Atlantic Fleet to Commander, Naval Sea

Systems Command (00T); Ser N451A/4270 dated 13 Dec 1996; COMSUBLANT

Response to UNDS Data Call; 688 Class and 726 Class Submarine Discharge Data

Package.

8. Ashland Chemical Company. Material Safety Data Sheets - Magnakote Rust

Preventative and Mud Conditioner. 8 February 1995 and 10 February 1995.

9. Mil. Spec. MIL-P-83461, “Packings, Preformed, Petroleum Hydraulic Fluid Resistant,

Improved Performance at 275oF (135oC)”.

10. Mil. Spec. MIL-G-22050, “Gasket and Packing Material, Rubber for Use With”.

11. Mil. Spec. MIL-P-24441, “Paint, Epoxy-Polyamide, General Specification For”.

12. Mil. Spec. MIL-PRF-23236, “Paint Coating Systems, Fuel and Salt Water Ballast Tank”.

13. Chesapeake Bay Commission. The Introduction of Nonindigenous Species to the

Chesapeake Bay Via Ballast Water - Strategies to Decrease the Risks of Future

Introductions through Ballast Water Management. 5 January 1995.

14. Ruiz, Greg. Non-Indigenous Species Presentation - Notes by Dan G. Mosher, Malcolm

Pirnie, Inc. 18 September 1996.

15. International Maritime Organization (IMO). Guidelines for Preventing the Introduction

of Unwanted Aquatic Organisms and Pathogens from Ships’ Ballast Water and Sediment

Discharges, 10 May 1995

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.
Clean Ballast

9

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

National Research Council. Stemming the Tide, Controlling Introductions of Nonindigenous

Species by Ship’s Ballast Water. National Academy Press, 1996.

Aivalotis, LT Joyce. UNDS Info, 18 February 1997, Doug Hamm, Malcolm Pirnie, Inc.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9CVN-CD-SIB-020, CVN

70 Vol. 2, Pt. 1, Bk 1, Chapter 11, Drainage and Ballasting Systems, Section 3, Sea Water

Ballasting System.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9LHA-AA-SIB-020, LHA

1, Section 7-41, Ballast/Deballast System.
Clean Ballast

10

Naval Sea Systems Command (NAVSEA). Ship Information Book, 0905LP-123-6010, LCC 19,

Section 2, Chapter 1, Fuel Oil Tank Stripping and Clean Ballast Systems.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9LHD-AA-SIB-060, LHD

1, Chapter 14, Ballast/Deballast System.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9LPD-AD-SIB-020, LPD

4, Vol. 2, Pt. 1, Table 7-2, Approximate Time to Ballast & Deballast Tanks.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9LSD-BH-SIB-100, LSD

41, Vol. 7, Ballasting/Deballasting.

Columbia/HCA Healthcare Corporation. Epidemic Cholera in the New World:

Translating Field Epidemiology into New Prevention Strategies. 2 October 1996.

Krotoff, Oleg, Ashland Chemical. Conversation with Oleg Krotoff, Env. Engineer, Ashland

Chemical, 13 May 1997, Doug Hamm, Malcolm Pirnie, Inc.

UNDS Equipment Expert Meeting Round Two - Clean Ballast. 15 April 1997.

Weersing, Penny, MSC. UNDS: Clean Ballast, 15 May 1997, Doug Hamm, Malcolm Pirnie, Inc.

UNDS Equipment Expert Meeting - Clean Ballast. 18 September 1996, M. Rosenblatt &

Son, Inc.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Clean Ballast

11

Figure 1. Typical Amphibious Ship Ballast and Deballast Tank Piping Composite
Clean Ballast

12

Table 1. Summary of IMO, USCG, and Navy Exchange Policies for Clean Ballast Water

From Surface Vessels

NAVY2 USCG3,4 IMO15

Requires potentially polluted ballast

water to be offloaded outside of 12

n.m. from shore and clean sea water

taken on and discharged twice prior

to entry within 12 n.m. from shore.

Requires potentially polluted ballast

water to be offloaded outside of 12

n.m. from shore and clean sea water

taken on and discharged twice prior

to entry within 12 n.m. form shore.

Recommends ballast water

exchange to take place in areas with

a depth of 2000 meters or more to

minimize the introduction of nonindigenous invasive species.

Requires entering records of ballast

water exchanges and their

geographical location in ship’s

engineering log.

Requires entering records of ballast

water exchanges and their

geographical location in ship’s

engineering log.

Recommends record keeping of

ballast water exchange, sediment

removal, procedures used, and

appointment of responsible officer

on board ships to ensure procedures

are followed and records

maintained.

Table 2. Estimate of Total Ballast Capacity*

Vessel Class Service Ballast Capacity (Gallons) # Vessels Total Capacity (Gallons)

T-AO 187 MSC 3,000,000 12 36,000,000

T-AKR 287 MSC 1,200,000 8 9,600,000

T-AG 194 MSC 1,700,000 1 1,700,000

WMEC 270 A&B USCG 42,250 13 549,250

WLB 225 USCG 92,300 2 184,600

WAGB 399 USCG 115,300 2 230,600

LHA 1 Navy 3,445,867 5 17,229,335

CVN 68 Navy 278,533 7 1,949,731

LCC 19 Navy 593,383 2 1,186,766

LPD 4 Navy 3,700,000 8 29,600,000

LSD 41 Navy 3,090,000 8 24,720,000

LHD 1 Navy 4,000,000 4 16,000,000

AOE 6 Navy 209,941 3 629,823

SSBN 726 Navy 668,904 17 11,371,368

SSN 688 Navy 229,225 56 12,836,600

LSV Army 403,000 6 2,418,000

LCU-2000 Army 111,369 35 3,897,915

Total: 170,103,988

Estimate is based upon the largest vessels of the Navy, USCG, MSC, and Army that use clean

ballast. Ballast volumes of vessels of the Air Force are not included.
Clean Ballast

13

Table 3. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents X

3.4 Concentrations N/A

4.1 Mass Loadings N/A

4.2 Environmental Concentrations N/A

4.3 Potential for Introducing NonIndigenous SpeciesX X
Compensated Fuel Ballast

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Compensated Fuel Ballast
Compensated Fuel Ballast

2

2.0 DISCHARGE DESCRIPTION

This section describes compensated fuel ballast discharge and includes information on:

the equipment that is used and its operation (Section 2.1), general description of the constituents

of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Compensated ballast tanks are used for fuel storage and to maintain stability on some

classes of Navy vessels. As fuel is consumed while underway, water is taken in by the vessel to

maintain a nearly constant total fluid weight in the vessel. Compensated fuel ballast tanks are

maintained full of either fuel, seawater, or a combination of both. When both fuel and seawater

are present in the same tank, the fuel floats on top of the seawater because the fuel is less dense.

These tanks are only completely emptied of all fluid (seawater and fuel) during in-tank

maintenance or modification work that is not part of the ships’ normal operation.

In vessels that use compensated fuel ballast systems, several compensated fuel ballast

tanks are connected in series to form a tank group. The first tank of the group is called the

“receiving tank.” Fuel enters and exits the tank group via the receiving tank. The last tank of the

group is called the “overflow/expansion tank.” Seawater enters and exits the tank group via the

overflow/expansion tank from the ship’s firemain. Compensating water is introduced into the

overboard discharge pipe of the overflow/expansion tank through a level control valve. This

valve maintains a constant pressure within the compensated fuel tanks. The compensated

ballast/fuel storage tanks are in between the receiving and the overflow/expansion tanks. All the

tanks in the group are connected by sluice pipes. Each tank in the group has an upper and lower

sluice pipe. The lower sluice pipe in the first tank of the group is connected to the upper sluice

pipe of the next tank in the series. The upper sluice pipe in the receiving tank connects to the

ship’s fill and transfer fuel piping and allows fuel to enter and leave the tank group. The lower

sluice pipe of the overflow/expansion tank allows seawater to enter and leave the tank group.

Figure 1 shows a schematic diagram of the tank group interconnection pipes.

Each Navy surface vessel using a compensated fuel ballast system has six tank groups in

adjacent tank group pairs; two tank groups forward, two tank groups midship, and two tank

groups aft. Figure 2 shows the general layout of the six tank groups. For each adjacent tank

group pair, there is one port tank group and one starboard tank group. Each tank group consists

of three to six tanks connected in a series: a receiving tank, one to four storage tanks, and an

overflow/expansion tank. The overboard discharge from each adjacent port and starboard tank

group are cross-connected resulting in a port-starboard pair of overboard discharges forward,

midship, and aft. Figure 3 illustrates a typical fuel oil tank layout for pair of port and starboard

tank groups with cross-connected overflow piping on a surface vessel.

During a fueling operation, fuel enters the receiving tank via the inlet sluice pipe and

pushes seawater through the rest of the tanks in the group via the sluice pipes. By simple

displacement, an equal amount of seawater is discharged overboard from the overflow/expansion

tank. Each tank in the group fills in sequence since fuel cannot get into the next tank in the series
Compensated Fuel Ballast

3

until the fuel level reaches the lower sluice pipe of the tank being filled. When the fuel level

reaches the lower sluice pipe in a tank the fuel starts to flow into the next tank in the series via

the sluice pipe. Operating procedures dictate that the fueling process be stopped prior to fuel

entering the overflow/expansion tank.1 The overflow/expansion tank is intended to hold only

seawater, acting as a buffer between the fuel storage tanks and the overboard discharge. This

tank is used to prevent the accidental discharge of fuel overboard due to overfilling of the tank

group, or due to the thermal expansion of the fuel when ambient temperatures increase.

Fuel is transferred via purifiers to uncompensated fuel service tanks prior to use by ship’s

propulsion and electrical generating plants. Only fuel from the service tanks is used to power the

ship’s propulsion and electrical generating plants, fuel is not taken directly from the compensated

fuel ballast tanks to the engines. Therefore, compensating water is not taken on when the ship’s

engines are operating in port.

Non-conventional submarines have a compensated fuel ballast system to provide fuel for

the emergency diesel generator. This compensated fuel ballast system consists of a Normal Fuel

Oil (NFO) tank and a seawater expansion tank. Compensating water is not discharged to the

surrounding water under any normal operating condition. When fueling, the displaced seawater

is removed from the NFO tank via the seawater compensating line and is transferred via a hose

connection to a port collection facility for treatment and disposal.2 While operating at sea,

compensating seawater is not discharged from the NFO tank because an air charge in the

expansion tank compresses to account for volumetric changes due to hull compression during

changes in ship depth or as a result of tank liquid temperature changes.

Mixing of the fuel into seawater discharged from the overflow/expansion tank is believed

to occur via the following mechanisms:

• Fuel and water can be mixed by turbulence in the tank during rapid introduction of

fuel or water, or the rolling motion of the ship. The turbulence is caused by fluid flow

around internal tank structure and by interfacial shear between the fuel and the water

layers.

• Internal tank structure can cause incorrect fuel level readings and inadvertent

discharge of fuel with the compensated ballast water by trapping pockets of fuel and

seawater.

• Soluble fuel constituents can be dissolved in seawater.

Some of the design and operational practices used by the Navy to mitigate fuel discharges

from compensating ballast systems include:

• Engineering Operating Sequencing Systems (EOSS) fuel filling procedure “Standard

Refueling, Fuel Oil” (SRFO) and the Class Advisories (temporary operating

instructions and notices) for destroyers and conventional cruisers recommend that fuel

storage tanks be refueled to no greater than 85 percent of capacity in port.1-4 This
Compensated Fuel Ballast

4

prevents the fuel/seawater interface from entering the overflow/expansion tank and

overboard discharge pipe.

• EOSS fuel filling procedure SRFO and the Class Advisories for the same vessels

direct that the in-port flow limiting valves in the supply to each tank group be closed

during in-port refueling only (open while refueling at sea). The flow limiting valves

restrict the fill rate to each tank group to approximately 400 gallons per minute (gpm)

versus 1000 gpm while at sea. This reduces fuel/seawater mixing in the tank.1-4

• EOSS fuel filling procedure SRFO requires individuals to stand watch to halt

refueling in the event of overboard spills, while others are required to monitor fuel

levels in each tank during the refueling operation.1

2.2 Releases to the Environment

As discussed in Section 2.1 compensated ballast discharge occurs through the

overflow/expansion tank during refueling operations. Compensated ballast discharge consists

primarily of seawater containing some fuel constituents. Leaching and corrosion of fuel

containment systems are expected to result in the presence of metals.

2.3 Vessels Producing the Discharge

The Navy is the only branch of the Armed Forces whose vessels utilize compensated fuel

ballast systems. Compensated fuel ballast systems are used only on CG 47 Class cruisers; DD

963 Class, DDG 993 Class, and DDG 51 Class destroyers; and all non-conventional submarine

classes.2 A total of 75 U.S. based surface vessels generate this discharge. Submarine

compensated fuel ballast systems do not discharge to the surrounding water whether in port or at

sea. USCG, MSC, Army, Air Force, and Marine Corps vessels do not utilize compensated fuel

ballast systems and do not generate this discharge.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

In-port refueling of surface ships is the only circumstance during which compensated

ballast discharge occurs within 12 nautical miles (n.m.). At-sea refueling operations take place

outside of 12 n.m. based on standard operating practice.

3.2 Rate
Compensated Fuel Ballast

5

During in-port refuelings of surface vessels, compensated ballast is discharged at a rate of

up to 400 gpm per tank group (2,400 gpm maximum per ship). Based on actual refueling data

obtained from Navy personnel, each ship takes on about 200,000 gallons per refueling in port and

the refuelings occur on average two times per year per ship.5

3.3 Constituents

The Navy has conducted several studies of compensated ballast in the past. These

included:

• in-port refueling test of the USS Nicholson (DD 982);6

• at-sea refueling testing of the USS Spruance (DD 963);7

• in-port and at-sea testing of the USS John Hancock (DD 981);8 and

• in-port testing of the USS Arleigh Burke (DDG 51).9,10

These previous studies have typically measured the oil concentration of the discharge.

On the DDG 51, in-line oil content monitors were used in conjunction with standard laboratory

analyses to determine the oil concentration in the discharged ballast water. Table 1 summarizes

the data for oil concentration in compensated ballast water from the previous Navy studies. The

concentration of oil in water varied from below detection levels to 370 milligrams per liter

(mg/L).

To further support this NOD report, a sampling effort was conducted. Five samples of

compensated ballast discharge, and an additional quality assurance/quality control sample, were

taken through the course of an in-port refueling operation from the discharge of a single midship

tank group of the USS Arleigh Burke, (DDG 51) on January 27, 1997.11 Based on previous Navy

operational and design experience, midship tank groups on DDG 51 Class vessels are expected to

contain the greatest concentration of fuel oil constituents in the ballast water. The samples were

analyzed for volatile and semivolatile organics, selected classical pollutants, metals, and mercury

using EPA series 1600 protocols. Table 2 presents a summary of the validated analytical data

for all detected analytes from the sampling effort that occurred on January 27, 1997. The

following priority pollutants were present in measurable amounts: copper, nickel, silver,

thallium, zinc, benzene, phenol, and toluene;12 the only bioaccumulator found was mercury.13

Also, during the UNDS sampling effort, 8 additional samples were taken and analyzed for TPH

by the modified 418-2 method, with results ranging from 11.9 to 108.2 mg/L.14

3.4 Concentrations

As mentioned in Section 3.3, Table 2 presents the validated analytical data from the

UNDS sampling effort. The table includes metals, volatile organics, semivolatile organics,

classicals, and mercury. The table shows the constituents, the log-normal mean, the frequency of

detection for each constituent, the minimum and maximum concentrations, and the mass

loadings of each constituent. For the purposes of calculating the log-normal mean, a value of

one-half the detection limit was used for non-detected results.
Compensated Fuel Ballast

6

In addition to the oil concentration data collected in previous sampling as described in

Table 1, two separate sets of analyses were developed from the UNDS sampling effort to support

this NOD report. The samples were analyzed for Hexane Extractable Materials (HEM) and

Silica Gel Treated (SGT) -HEM. The HEM values correspond to oil and grease and the SGTHEM values correspond to total petroleum hydrocarbon (TPH) which is a subset of oil and

grease. The results varied from 8 to 36.5 mg/L for HEM and from 6 to 12.5 mg/L for SGTHEM.11

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Based on ship transit data, Navy surface ships with compensated ballast systems are at

their homeport (within 12 n.m.) between 101 and 178 days per year, and at sea for the balance of

the year.15 A per-ship total annual discharge of 400,000 gallons per year was calculated based

upon the following averages obtained from Navy refueling data:5

• 200,000 gallons median discharge per in port refueling; and

• 2 refuelings in port per year.

As mentioned in Section 2.3, 75 surface vessels are homeported in the U.S. and generate

compensated ballast within 12 n.m. of the U.S.16 The majority of these ships’ in-port refuelings

occur at their homeport. Flow per ship class can be roughly approximated as the product of the

number of vessels in a class and 400,000 gallons discharged per ship per year as presented in

Table 3. The 75 U.S. based surface vessels discharge 30.0 million gallons within the 12 n.m.

zone.

Total mass loading, for in-port discharges, was estimated by multiplying the log-normal

mean concentration by the total compensated ballast discharge volume of 30.0 million gallons

per year. The generalized equation is shown below:

Mass Loading (lbs/yr) =

(Concentration (μg/L))(Volume (gal/yr))(3.785 L/gal)(2.2 lbs/kg)(10-9 kg/μg)

Based on the SGT-HEM log-normal mean concentration of 4.65 mg/L the TPH loading

could be 1,160 pounds per year (lbs/yr). Based on the HEM log-normal mean concentration of

12.73 mg/L, the total estimated oil & grease loading from in-port discharges could be expected to
Compensated Fuel Ballast

7

be 3,180 lbs/yr.

Using the metal log-normal mean concentrations as listed in Table 2; the mass loadings

are estimated to be 13.3 lbs/yr for copper; 47.4 lbs/yr for nickel; 2 lbs/yr for thallium; 1,063

lbs/yr for zinc; 0.77 lbs/yr for silver; and 0.00015 lbs/yr for mercury. Using the organic lognormal concentration in Table 2, the mass loading was estimated to be 10.3 lbs/yr for 2-Propenal;

and 22 lbs/yr for benzene. Using the log-normal concentration in Table 2, the mass loading was

estimated to be 65 lbs/yr for ammonia, 97 lbs/yr for nitrogen, and 15 lbs/yr for phosphorous.

These mass loadings are summarized in Table 4. The ratio of the number of vessels in each U.S.

homeport to the total of 75 compensated ballast vessels allows the loadings to be proportioned as

shown in Table 5.

4.2 Environmental Concentrations

Screening for acute toxicity was accomplished by comparing the log-normal mean

resulting from the UNDS sampling to Federal or the most stringent state water quality criteria for

these constituents. These data are provided in Table 6. Individual sample concentrations exceed

Florida criteria for oil, as indicated by SGT-HEM, but the log-normal mean does not; however,

this discharge has demonstrated that potential for causing a sheen when procedural controls are

not used.6,8 Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge

sufficient to cause a sheen on receiving waters. The Federal discharge standard is 15 mg/L based

on International Convention for the Prevention of Pollution from Ships (MARPOL 73/78).

MARPOL 73/78 as implemented by the Act to Prevent Pollution from Ships (APPS).

The log-normal mean concentrations for copper, nickel, silver, and zinc samples exceed

both Federal and most stringent state water quality criteria (WQC). The most stringent state

criteria are exceeded by the log-normal mean concentration for 2-Propenal, ammonia, benzene,

HEM, total nitrogen, phosphorous, and thallium. Mercury, a persistent bioaccumulator, was

present in three of the four samples, although it did not exceed WQC.

4.3 Potential for Introducing Non-Indigenous Species

Water taken into the fuel tanks during refueling could contain non-indigenous species,

but it is unlikely that the organisms will be transferred between ports for the following reasons:

1) Water is not taken into the compensated fuel ballast tanks during refueling operations –

water is only discharged during this operation. Water is only taken into the compensated

fuel ballast tanks during fuel transfer operations (either between compensated fuel ballast

tank groups or from a compensated fuel ballast tank to a fuel service tank). Water could

be taken into the compensated fuel ballast tanks prior to a refueling operation because

ship’s personnel are trying to maximize the fuel storage on board by transferring fuel

from the compensated ballast tanks to top off the fuel service tanks. This process is

normally done at-sea prior to entering to a port facility. This process also prevents silt

and debris from shallow harbors from being introduced into the tanks.
Compensated Fuel Ballast

8

2) If the ship has been generating its own electrical power for an extended period while

in-port then the fuel transfer may take place in the harbor prior to the refueling in order to

maximize the fuel stored on-board the vessel. However, the refueling that takes place

immediately after the fuel transfer will discharge the compensating water back into the

same harbor.

3) Compensating water from the fuel storage tanks is frequently flushed while the ship is

at sea due to frequent refuelings. Navy surface ships with compensated ballast systems

normally refuel every three to four days while out at sea to prevent fuel levels from

dropping below 70% capacity. Based on ship transit data, these ships are at sea between

187 and 264 days per year.11 Using the minimum number of days at sea (187), and

assuming that the ship is refueled at-sea every 4 days, results in an estimate of

approximately 46 at-sea refuelings per year compared to two in-port refuelings per year.

Therefore, there is little chance for compensating water that may have been taken on in

one port to be discharged in another port.

5.0 CONCLUSIONS

Uncontrolled, compensated ballast discharge has the potential to cause an adverse

environmental effect because significant amounts of oil are discharged during a short duration at

concentrations that exceed discharge standards and water quality criteria. This discharge has

been reported to cause an oil sheen when procedural controls are not applied.6,8

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information and assumptions were used to estimate the rate of discharge. Based on this estimate

and on the reported concentrations of the constituents, the concentrations of the constituents in

the environment resulting from this discharge were compared with relevant water quality criteria.

Table 7 shows the sources of data used to develop this NOD report.

Specific References

1. Naval Sea Systems Command, Engineering Operating Sequencing System (EOSS),

Operational Procedure Fuel Oil Refueling, Code SRFO/0319/032596.

2. UNDS Equipment Expert Meeting Minutes - Compensated Fuel Ballast. July 24, 1996.

3. Naval Sea Systems Command, DD 963 - DDG 993 Class Advisory NR 04-94, Inport

Refueling / Operational Procedures, 2 May 1994.

4. Naval Sea Systems Command, DDG 51 Class Advisory NR 22-95, Fuel Tank Level

Indicator Alignment Procedures, 21 December 1995.
Compensated Fuel Ballast

9

5. Report of Travel, Compensated Fuel Ballast System NCCOSC-NRaD, San Diego, 12

March 1997.

6. Oil Concentrations in Ballast Water During In-Port Refueling of USS Nicholson (DD

982). DTNSRDC Report TM-28-81-145 (December 1981).

7. Oil Concentrations in Ballast Water During At-Sea Refueling of USS Nicholson (DD

982). DTNSRDC Report TM-28-82-158 (December 1982).

8. Evaluation of DD-963 Class Fuel/Ballast Expansion Tank Modifications Aboard USS

JOHN HANCOCK (DD 981). DTNSRDC Report TM-28-83-171 (May 1984).

9. SEA 05Y32 Preliminary Trip Report/Test Brief. DDG 51 In-Port Refueling Test, August

12-14, 1992.

10. SEA 05Y32 DDG 51 Post-PSA In-Port Fueling Test. August 4, 1992.

11. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

12. Committee Print Number 95-30 of the Committee on Public Works and Transportation of

the House of Representatives, Table 1.

13. The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.

14. Compensated Ballast Sample Analysis Results from DDG 51 In-port Refueling, 27

January 97, Commanding Officer, Naval Surface Warfare Center, Carderock Division,

Philadelphia Site, Philadelphia, PA, letter 9593, Ser 631/63 of 14 February 1997.

15. UNDS Ship Database, August 1, 1997.

16. The United States Navy, List of Homeports, Homeports and the Ships Assigned,

Effective May 22, 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.
Compensated Fuel Ballast

10

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).
Compensated Fuel Ballast

11

Figure 1. Fuel Tank Group 3 and 4 (Typical) Compensated Seawater Ballast
Compensated Fuel Ballast

12

 Figure 2. Compensated Fuel Ballast Tank Layout
Compensated Fuel Ballast

13

Figure 3. Typical Port and Starboard Tank Groups with Cross-connected Overflow
Compensated Fuel Ballast

14

Table 1. Oil Concentrations in Compensated Ballast Waters (mg/L)

Previous Navy Studies

USS Nicholson

DD 9826

(in-port)

USS Spruance

DD 9637

(at-sea)

USS John Hancock

DD 9818

(in-port)

USS Arleigh Burke

DDG 5110,11

(in-port)

2 to 149 < 60 <1 to 370 0.0 to 10.35 (lab)

mg/L - milligrams of oil per liter of fluid

(lab) - laboratory analysis results for physical samples taken during testing
Compensated Fuel Ballast

15

Table 2. Summary of Detected Analytes for Compensated Ballast Discharge

Constituent Log Normal Frequency of Minimum Maximum Mass Loading

Mean Detection Concentration Concentration (lbs/yr)

Classicals (mg/L)

ALKALINITY 46.72 4 of 4 45 49 11,671

AMMONIA AS NITROGEN 0.26 4 of 4 0.19 0.3 65

BIOCHEMICAL OXYGEN

DEMAND

6.82 1 of 4 BDL 12 1,704

CHEMICAL OXYGEN DEMAND

(COD)

429.25 4 of 4 380 490 107,231

CHLORIDE 16042.18 4 of 4 15400 16800 4,007,497

HEXANE EXTRACTABLE

MATERIAL

12.73 4 of 4 8 36.5 3,180

SGT-HEM 4.65 2 of 4 BDL 12.5 1,162

SULFATE 2005.74 4 of 4 1900 2120 501,054

TOTAL DISSOLVED SOLIDS 27760.50 4 of 4 27000 29300 6,934,851

TOTAL KJELDAHL NITROGEN 0.39 4 of 4 0.28 0.58 97

TOTAL ORGANIC CARBON

(TOC)

28.98 4 of 4 21 40 7,239

TOTAL PHOSPHOROUS 0.06 3 of 4 BDL 0.34 15

TOTAL SULFIDE (IODOMETRIC) 3.94 4 of 4 3 5 984

TOTAL SUSPENDED SOLIDS 9.62 4 of 4 4 18 2,403

VOLATILE RESIDUE 2506.27 4 of 4 1910 3160 626,091

Hydrazine (mg/L)

HYDRAZINE 0.08 4 of 4 0.0705 0.089 20

Mercury (ng/L)

MERCURY 0.60 3 of 4 BDL 0.835 0.0001

Metals (μg/L)

ALUMINUM Dissolved 52.03 2 of 4 BDL 120 13

Total 37.00 1 of 4 BDL 135.5 9

BARIUM Dissolved 11.44 4 of 4 10.35 12 3

Total 11.24 4 of 4 10.25 11.8 3

BORON Dissolved 3098.77 4 of 4 2990 3220 774

Total 3060.48 4 of 4 2990 3175 765

CALCIUM Dissolved 256841.05 4 of 4 203000 292000 64,161

Total 291451.71 4 of 4 286000 299000 72,808

COPPER Total 53.37 4 of 4 43.7 86 13

IRON Dissolved 99.76 4 of 4 37.45 159 25

Total 130.50 4 of 4 74.95 202 33

MAGNESIUM Dissolved 907229.15 4 of 4 881000 923500 226,635

Total 938389.79 4 of 4 907000 1024500 234,419

MANGANESE Dissolved 12.13 4 of 4 11.15 13.7 3

Total 12.13 4 of 4 10.7 13.7 3

NICKEL Dissolved 184.65 4 of 4 137 263.5 46

Total 189.72 4 of 4 144 267.5 47

SILVER Dissolved 3.07 1 of 4 BDL 5.68 1

SODIUM Dissolved 8225693.86 4 of 4 8040000 8450000 2,054,861

Total 8039337.04 4 of 4 7740000 8550000 2,008,307
Compensated Fuel Ballast

16

THALLIUM Dissolved 5.61 1 of 4 BDL 10.8 1

Total 7.40 1 of 4 BDL 24 2

ZINC Dissolved 1220.18 4 of 4 173 4330 305

Total 4256.14 4 of 4 3840 4845 1,063

Organics (μg/L)

2,3-DICHLOROANILINE 6.09 1 of 4 BDL 11 2

2,4-DIMETHYLPHENOL 312.10 4 of 4 180 430 78

2-METHYLBENZOTHIOAZOLE 8.07 1 of 4 BDL 34 2

2-METHYLNAPHTHALENE 61.34 4 of 4 58 63 15

2-PROPANONE 41.18 2 of 4 BDL 73 10

2-PROPENAL 42.20 1 of 4 BDL 203 11

4-CHLORO-2-NITROANILINE 12.04 1 of 4 BDL 21 3

ACETOPHENONE 21.99 4 of 4 21 23 5

ANILINE 6.58 1 of 4 BDL 15 2

BENZENE 89.99 4 of 4 31 153 22

BENZOIC ACID 75.62 3 of 4 BDL 146 19

BENZYL ALCOHOL 12.16 3 of 4 BDL 24 3

BIPHENYL 9.76 4 of 4 7.5 11 2

ETHYLBENZENE 38.59 4 of 4 20.5 59 10

HEXANOIC ACID 16.93 4 of 4 7.5 28 4

ISOSAFROLE 6.69 1 of 4 BDL 16 2

LONGIFOLENE 54.02 1 of 4 BDL 545 13

M-XYLENE 58.13 4 of 4 41.5 73 15

N-DECANE 7.28 1 of 4 BDL 22.5 2

N-DOCOSANE 7.11 1 of 4 BDL 20.5 2

N-DODECANE 10.01 2 of 4 BDL 36.5 3

N-EICOSANE 20.35 4 of 4 14 51 5

N-HEXADECANE 39.36 4 of 4 26 99.5 10

N-OCTADECANE 24.98 4 of 4 16 64 6

N-TETRADECANE 21.19 4 of 4 14 60 5

NAPHTHALENE 19.54 3 of 4 BDL 47 5

O+P XYLENE 100.66 4 of 4 71 127 25

O-CRESOL 181.10 4 of 4 84.5 296 45

O-TOLUIDINE 40.24 4 of 4 8 95 10

P-CRESOL 110.73 4 of 4 46.5 192 28

P-CYMENE 5.53 1 of 4 BDL 10 1

PHENOL 69.70 4 of 4 59 83 17

THIOACETAMIDE 19.75 1 of 4 BDL 152 5

TOLUENE 164.46 4 of 4 63.5 269 41

TOLUENE,2,4,-DIAMINO- 72.44 1 of 4 BDL 227 18

Log normal means were calculated using measured analyte concentrations. When a sample set contained one or

more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations

equivalent to one-half of the detection levels were used to calculate the mean. For example, if a "non-detect" sample

was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log normal mean

calculation.
Compensated Fuel Ballast

17

Table 3. Estimated Total U.S. In-port Discharge of Compensated Ballast

(millions of gallons/year Fleetwide)

Ship Class Number of Ships Total In-port Discharge

CG 47 25 10.0

DD 963 28 11.2

DD 993 4 1.6

DDG 51 18 7.2

Table 4. Estimated Annual Mass Loadings of Constituents

Constituent Log Normal Frequency of Minimum Maximum Mass Loading

Mean Detection Concentration Concentration (lbs/yr)

Classicals (mg/L)

Ammonia As

Nitrogen

0.26 4 of 4 0.19 0.3 65

Hexane

Extractable

Material

12.73 4 of 4 8 36.5 3,180

Nitrate/

Nitrite

- - - - -

Total Kjeldahl

Nitrogen

0.39 4 of 4 0.28 0.58 97

Total Nitrogena0.39 4 of 4 0.28 0.58 97

Total

Phosphorous

0.06 3 of 4 BDL 0.34 15

Mercury (ng/L)

Mercury* 0.6 3 of 4 BDL 0.835 0.00015

Metals (μg/L)

Copper Total 53.37 4 of 4 43.7 86 13

Nickel Dissolved 184.65 4 of 4 137 263.5 46

Total 189.72 4 of 4 144 267.5 47

Silver Dissolved 3.07 1 of 4 BDL 5.68 0.77

Thallium Total 7.40 1 of 4 BDL 24 2

Zinc Dissolved 1220.18 4 of 4 173 4330 305

Total 4256.14 4 of 4 3840 4845 1,063

Organics (μg/L)

2-Propenal 42.2 1 of 4 BDL 203 10

Benzene 89.99 4 of 4 31 153 22

* - Mercury was not found in excess of WQC; mass loading is shown only because it is a bioaccumulator.

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Compensated Fuel Ballast

18

Table 5. Estimated Mass Loadings by Homeport (lbs/yr)

Total Everett Mayport Norfolk Pascagoula Pearl Harbor San Diego

Ships 75 4 13 27 2 10 19

Loading Ranges

HEM 3180 170 551 1145 85 424 805

SGT-HEM 1160 62 201 417 31 155 294

Copper 13.3 0.7 2.3 4.75 0.35 1.8 3.4

Nickel 47.4 2.5 8.25 17.1 1.25 6.3 12

Zinc 1063 56.7 184.25 382.7 28.35 141.7 269.3

Thallium 2 0.11 0.35 0.72 0.05 0.27 0.51

Silver 0.77 0.04 0.135 0.285 0.02 0.1 0.19

2-Propenal 10.3 0.55 1.8 3.7 0.28 1.4 2.6

Ammonia 65 3.5 11.3 23.4 1.75 8.7 16.5

Benzene 22 1.2 3.8 7.9 0.6 2.9 5.6

Nitrogen 97 1.7 17 35 0.84 13 25

Phosphorous 15 0.8 2.6 5.4 0.4 2.0 3.8
Compensated Fuel Ballast

19

Table 6. Mean Concentrations of Constituents Exceeding Water Quality Criteria

Constituent Log Normal

Mean

Minimum

Concentration

Maximum

Concentration

Federal Acute

WQC

Most Stringent

State Acute WQC

Classicals (mg/L)

Ammonia As

Nitrogen

0.26 0.19 0.3 None 0.006 (HI)A

Nitrate/Nitrite - - -

Total Kjeldahl

Nitrogen

0.39 0.28 0.58 None -

Total NitrogenB0.39 0.28 0.58 None 0.2 (HI)A

Hexane Extractable

Material

12.73 8 36.5 visible sheena/

15b

5 (FL)

Total Phosphorous 0.06 BDL 0.34 None 0.025 (HI)A

Mercury (ng/L)

Mercury* 0.6 BDL 0.835 1800 25 (FL, GA)

Metals (μg/L)

Copper Total 53.37 43.7 86 2.9 2.5 (WA)

Nickel Dissolved 184.65 137 263.5 74 74 (CA, CT)

Total 189.72 144 267.5 74.6 8.3 (FL, GA)

Silver Dissolved 3.07 BDL 5.68 1.9 1.9 (CA, MS)

Thallium Total 7.40 BDL 24 None 6.3 (FL)

Zinc Dissolved 1220 173 4330 90 90 (CA, CT, MS)

Total 4256 3840 4845 95.1 84.6 (WA)

Organics (μg/L)

2-Propenal 42.2 BDL 203 None 18 (HI)

Benzene 89.99 31 153 None 71.28 (FL)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

* - Mercury was not found in excess of WQC; concentration is shown only because it is a bioaccumulator.

CA = California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington

a Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen

on receiving waters.

b

International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as

implemented by the Act to Prevent Pollution from Ships (APPS)
Compensated Fuel Ballast

20

Table 7. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

Data call responses X

2.2 Releases to the Environment Data call responses X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality Data call responses X

3.2 Rate Data call responses X

3.3 Constituents Data call responses X X

3.4 Concentrations Data call responses X X

4.1 Mass Loadings X

4.2 Environmental Concentrations X X

4.3 Potential for Introducing NonIndigenous SpeciesX
Controllable Pitch Propeller Hydraulic Oil

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as candidates for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Controllable Pitch Propeller Hydraulic Oil
Controllable Pitch Propeller Hydraulic Oil

2

2.0 DISCHARGE DESCRIPTION

This section describes the controllable pitch propeller (CPP) hydraulic oil discharge and

includes information on: the equipment that is used and its operation (Section 2.1), general

description of the constituents of the discharge (Section 2.2), and the vessels that produce this

discharge (Section 2.3).

2.1 Equipment Description and Operation

CPPs are used to control vessel speed and direction without changing the speed or

direction of the vessel’s main propulsion plant shafting. With CPPs, the angle of the propeller

blades (pitch) is variable, which affects the “bite” that the blade has on the water. This allows

the amount of water displaced in the forward or reverse directions to be varied, which changes

the forward and reverse speed of the vessel.

The pitch of the CPP blades is controlled hydraulically through a system consisting of a

pump, piston, crosshead, and blade crank rings. The piston, crosshead, and crank rings are

located in the propeller hub. High pressure hydraulic oil, acting on either side of the piston,

moves the piston axially within the propeller hub. The piston is attached to a piston rod that

connects to the crosshead that moves axially with the piston. Sliding blocks fit in machined slots

on the crosshead and these sliding blocks fit over eccentrically-located pins mounted on the crank

pin rings. As the crosshead moves forward and backwards within the hub, the sliding blocks

move in an arc that also moves the eccentric pin and rotates the crank pin rings to which the CPP

blades are bolted.1

High-pressure hydraulic control oil is provided to each propeller by a hydraulic oil

pressure module (HOPM). While operating, the HOPM supplies oil pressure at 400 pounds per

square inch (psi) to control the CPP. While a vessel is pierside, the HOPM is idle and the

pressure to the CPP consists of approximately 6 to 8 psi provided by 16 to 21 feet of hydraulic

head, depending on the vessel class, from a 40- to 65-gallon reservoir that supplies head to a

larger sump tank (600 to 800 gallons) for the CPP system. Several rubber O-ring seals, along

with the finely machined surfaces of the blade port cover, the bearing ring, and the crank pin

ring, keep the hydraulic oil inside the CPP hub and away from the water.

Figures 1 through 3 show cross sections and a top view of a CPP. Figure 4 is a block

diagram of a CPP system.

2.2 Releases to the Environment

The hydraulic oil can be released under three conditions from a CPP and CPP

maintenance tools: leaks past CPP seals; releases during underwater CPP repair and

maintenance activities; and release of power head tool hydraulic oil during CPP blade

replacement. Small quantities of oil can leak past the CPP seals if they are old, worn, or

defective.
Controllable Pitch Propeller Hydraulic Oil

3

Oil can also be released to the environment during the underwater maintenance of CPP

propeller blades or seals.2 Underwater maintenance is performed to: 1) replace seals or center

blade post sleeves; or 2) replace one or more propeller blades. The procedures for performing

underwater replacements are detailed in reference (2). The detailed information in the following

subsections applies to Navy vessels. Data on Military Sealift Command (MSC) underwater

replacements are unavailable, and the U.S. Coast Guard (USCG) performs replacements only in

dry dock.3,4

Blade Port Cover Removal. Approximately five to seven of the estimated thirty

underwater replacements per year fleetwide are to remove blade port covers for maintenance and

can cause some hydraulic oil to be released from the CPP hub.5 The CPP hub seals or center post

sleeve are replaced when observations or inspections indicate failure or cracking.6 To change

hub seals or the center post sleeve, the CPP blade is removed to access the blade port cover,

which, in turn, must be removed to access the seals and center post sleeve. The underwater

husbandry manual for the underwater change outs also references “NAVSEA Best Management

Practices (BMPs) to Prevent/Mitigate Oil Spills Related to Waterborne Removal(s) of Blades on

Variable Pitch Propellers for Naval Vessels.” This BMP is described in Section 3.2.2.

CPP Blade Replacement. CPP blade replacement normally occurs after a casualty that

causes blade damage (e.g., running aground, hitting a submerged object). During blade

replacements, a CPP blade is unbolted from the blade port cover and replaced (see Figure 1).

Removing a CPP blade does not, in itself, cause hydraulic oil to be released from the CPP hub

assembly (other than that released by the bleeding procedure described above). Seals, bearings,

and sleeves are still in place to prevent any oil from being released.

During CPP blade replacement, the blade is rotated to the 12 o’clock position to remove

the Morgrip bolts that secure the blade to the CPP hub.6 The Morgrip bolts are removed with a

hydraulic power head tool. Before the power head tool is used, it is bled of air underwater while

attached to the Morgrip bolt by allowing oil to flow from a port until a “steady stream of

hydraulic fluid (no air) bleeds from the loosened port opposite the HP tube in the power head.”6

2.3 Vessels Producing the Discharge

The Navy, MSC and USCG operate vessels equipped with CPPs. The Army and Air

Force do not operate any vessels equipped with CPPs. Table 1 lists the vessels that have CPPs

and the number of shafts (i.e., number of CPPs, per vessel).

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 provides concentrations of the constituents in the discharge.
Controllable Pitch Propeller Hydraulic Oil

4

3.1 Locality

Leaks of hydraulic oil past seals can occur at sea or within 12 n.m. of shore. Discharge

underway is more likely than while pierside or at anchor because the CPP system is operating

under a higher pressure.

Hydraulic oil can be discharged within 12 n.m. of shore during CPP repairs. The

replacements are performed in port and are conducted on an as-needed basis when dry-docking is

not scheduled for a vessel or is impractical.

3.2 Rate

The rate of oil release from CPPs will vary with the activity performed on the CPP. The

leakage rate from CPP seals is expected to be negligible while the release of oil from CPP blade

replacement will be larger. The release of oil from the underwater replacement of CPP seals will

generate more oil than the underwater replacement of CPP blades only. The following

paragraphs provide further information related to the anticipated release rates from CPPs.

3.2.1 Leaks From CPP Seals

The systems that monitor hydraulic oil loss can detect catastrophic failures on the order of

5 to 250 gallons over 12 hours, but not small leaks. The internal pressure in the CPP hub is

approximately 6 to 8 psi, depending on the vessel class, when the HOPM is not operating (e.g.,

while a vessel is pierside). The external pressure from the seawater is approximately 5.8 to 8 psi

provided by 13 to 18 feet of seawater, depending on the vessel class. Therefore, the pressure

differential between the hydraulic oil in the CPP and the seawater is low (e.g., 1 psi or less) and

provides little driving force to force oil from the CPP hub. Leakage rates under these conditions

constitute seal failures requiring repairs/replacement considering that CPP hubs are designed to

operate at 400 psi without leakage. CPPs are pressure tested at 400 psi prior to ship delivery and

during dry dock maintenance. The CPPs are inspected quarterly for damage and signs of failure

or excessive wear.7 CPP seals are designed to last five to seven years and are reported to last

their projected life.7,8 Most Navy vessels equipped with CPPs have dry-dock cycles of

approximately five years and MSC vessels have dry-dock cycles of two to three years.3,9,10

During the dry dock cycle, the CPP is removed and shipped back to the manufacturer for

inspection and maintenance, which includes replacement of the CPP seals. Based on the above

information, the release rate of hydraulic oil from CPPs under normal operating conditions is

expected to be negligible.

3.2.2 Underwater Replacements

Approximately thirty underwater CPP blade replacements occur per year, and five to

seven of these include blade port cover removal to access the seal or center post sleeve for

replacement.5

CPP Blade Port Cover Removal. According to Reference No. 2, as much as five
Controllable Pitch Propeller Hydraulic Oil

5

gallons of oil could be present in CPP hub cavities.2 It is unlikely that all of this oil is released

during a seal replacement because the hub cavity opening is required to be oriented to the 6

o’clock position; the hydraulic oil is buoyant and floats within the hub cavity, effectively

trapping the oil.6

Oil (0 to 5 gallons) could be released when oil is supplied to the assembly to displace

water before replacing the blade port cover.6 After the seals or the center post sleeve are

replaced, head pressure is applied from the head tank to force out any water that entered the hub.

The husbandry manual does not specify if oil is discharged when displacing water in the hub, but

it appears to be a reasonable probability. The blade port cover is then replaced, and the hub is

pressure tested at 20 psi. Leaks can appear if the seals are not properly seated, the mylar shims

(i.e., spacers) are not the proper thickness, or the bearing ring is worn.6 If the bearing ring

requires replacement the vessel must be put in a dry dock.

Small amounts of oil can be discharged when removing and replacing the seal, bearing

ring, blade seal base ring, and center post sleeve. Assuming the worst-case condition, five

gallons of oil are discharged from the CPP hub during each replacement. At most a total of 35

gallons of hydraulic oil could be discharged annually fleetwide based on an average of seven

replacements per year.

The BMP also requires the following precautionary measures:

a. Establish/install a floating oil boom in the vicinity of the work. Position this boom to

enclose the aft one-third of the vessel, with approximately 20 feet beyond the stern to

ensure that escaping oil is contained.11

b. Ensure that the oil recovery kit and personnel, who are trained in oil spill recovery,

are at the work site at all times during the propeller blade removal/ installation to

respond to any oil spill. The spill kit shall include a boom, absorbent pads, and other

materials that remove oil from water.11

c. Any released oil will be captured within the oil boom and subsequently removed by

the oil recovery team on the surface. A vacuum truck, equipped with a noncollapsible

hose, will be at the site to remove any visible oil on the surface.11

CPP Blade Replacement. For the replacement of a CPP blade, the only source of oil

release is from bleeding the Morgrip bolt power head tool. Each blade replacement results in

approximately twenty ounces of hydraulic oil bled from the power tool (e.g., 10 ounces for the

blade removal and 10 ounces for the blade replacement).12 For the estimated 30 replacements

that occur each year, this translates to approximately 600 ounces (4.7 gallons) of hydraulic oil

bled from power head tools.

3.3 Constituents

The expected constituents of the discharge are 2190 TEP hydraulic oil from the CPP and
Controllable Pitch Propeller Hydraulic Oil

6

the hydraulic oil (e.g., Tellus #10) that is bled from the power head tool. Constituents of the oil

vary by manufacturer and are noted in Table 2. Hydraulic oils contain C17 (heptadecane,

heptadecene) and large paraffins and olefins.13 The 2190 TEP oil can also contain up to 1%

tricresylphosphate (TCP) as an antiwear additive.14 Shell Oil Tellus Oil #10 (Code 65203)

hydraulic oil contains solvent-refined, hydrotreated middle distillates and light hydrotreated

naphthenic distillates.15 CPP hydraulic oil can contain copper, tin, aluminum, nickel, and lead

that are leached from the piping, hub, and propeller.

Copper, nickel, and lead are priority pollutants that could be present in the hydraulic oil.

There are no known bioaccumulators in this discharge.

3.4 Concentrations

The released material is expected to be hydraulic oil with metals such as copper, tin,

aluminum, nickel, and lead from the piping, hub, and propeller. These metal constituents are

expected to be in low concentrations because metals have low corrosion rates when in contact

with oil. In addition, the hydraulic oil is continually processed through a filtration system to

prevent particulate matter and water from entering the CPP system and potentially causing

system failures.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

4.1.1 Leaks From CPP Seals

As discussed in Section 3.2.1, the release rate of oil from CPP seals due to normal

operations is expected to be negligible. CPPs are designed not to leak and are tested prior to

delivery at 400 psi. In addition, the CPPs are inspected quarterly.7 The majority of those vessels

equipped with CPPs have dry-dock cycles of five years or less and CPPs are returned to the

manufacturer for inspection and overhaul during the dry dock period.3,7,9,10 Therefore, the mass

loading for oil leakage from CPPs is expected to be negligible.

4.1.2 Underwater Replacements

As estimated in Section 3.2.2, Armed Forces vessels could release up to 4.7 gallons of

hydraulic oil from the Morgrip tool and 35 gallons of hydraulic oil from blade port cover

removals each year. This quantity of oil has a mass of approximately 290 pounds based on a
Controllable Pitch Propeller Hydraulic Oil

7

specific gravity of 0.88 for the hydraulic oil.

4.2 Environmental Concentrations

The quantities of hydraulic oil released can cause a sheen on receiving waters that violate

federal and state “no sheen” standards. The metal constituents (e.g., copper, tin, nickel, and lead)

in the oil can also be toxic, but it is anticipated that the concentrations, when dissolved in water,

will be below toxicity thresholds. Florida has a water quality criterion for oil and grease of 5

milligrams per liter (mg/L) that the estimated environmental concentration for underwater

replacement exceeds.

4.2.1 Leaks From CPP Seals

Because the release of oil from a CPP under routine operations is negligible, the resulting

environmental concentration is negligible.

4.2.2 Underwater Replacements

The underwater replacements are expected to result in periodic, batch releases of

hydraulic oil. Based upon the estimated release rates given in Section 3.2.2, the estimated

discharge volume during each replacement is five gallons. During a typical underwater

replacement requiring the removal of the port blade cover, the aft third of a vessel plus an

additional 20 feet are enclosed with an oil boom. The Navy vessels having CPPs are between

445 and 567 feet in length and between 45 and 67 feet in beam (i.e., width). The average

boomed length is approximately 190 feet and width of approximately 65 feet (e.g., average beam

of 55 feet plus an estimated 10 feet for proper deployment). The quantity of oil released from

CPPs during underwater replacements will result in free-phase oil that will result in localized

visible oil sheens on the surface of the water. The resulting visible oil sheens are prohibited

releases of oil under the Discharge of Oil (40CFR110) regulations of the Federal Water Pollution

Control Act.

4.3 Potential for Introducing Non-Indigenous Species

CPPs do not transport seawater; there is no potential for transporting non-indigenous

species.

5.0 CONCLUSIONS

5.1 Leaks From CPP Seals

The release of oil from CPPs during normal operation due to seal leakage is expected to

be negligible. This is due to the following:

1) CPPs are designed not to leak at 400 pounds per square inch (psi) when new or
Controllable Pitch Propeller Hydraulic Oil

8

overhauled and are tested at 400 psi for leaks prior to delivery. There is a zero-leakage tolerance

under the 400 psi test.

2) CPP seals are designed with service lives of 5 to 7 years and leakage that can occur

due to wear or age occurs late within this operational life. The majority of vessels equipped with

CPPs have dry-docking cycles for overhauls of approximately 5 years such that the releases

occurring toward the end of the operational life of a CPP seal are avoided.

3) CPPs are inspected quarterly for damage and evidence of system failure (e.g., leaking

seals).

The amount of oil leakage of CPPs under routine operating conditions has a low potential

to cause an adverse environmental effect.

5.2 Underwater Replacements

CPP hydraulic oil discharge has the potential for causing adverse environmental effects

during underwater replacements because:

1) oil is released to receiving waters by the equipment used to perform the underwater

replacements, and

2) oil is released from the CPP hub assembly during underwater removals of the CPP

blade port covers.

Releases due to underwater replacements are periodic and occur approximately thirty

times per year. Those replacements that require the removal of the blade port cover release

sufficient oil to cause a visible oil sheen on receiving waters and also exceed state WQC. These

releases from waterborne CPP repairs are controlled using NAVSEA BMPs that reduce the

adverse effects of the oil releases to receiving waters.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information and assumptions were used to estimate the rate of discharge. The resulting

environmental oil and grease concentrations were then estimated. Table 3 shows the sources of

data used to develop this NOD report.

Specific References

1. Blank, David A.; Arthur E. Block; and David J. Richardson. Introduction to Naval

Engineering, 2nd Edition. Naval Institute Press, 1985.
Controllable Pitch Propeller Hydraulic Oil

9

2. John Rosner, NAVSEA 00C. Frequency of Underwater CPP Blade Replacements.

December 1996, Gordon Smith (NAVSEA 03L1).

3. Penny Weersing, Military Sealift Command. Controllable Pitch Propeller (CPP)

Hydraulic Seals for MSC Ships. April 1997.

4. LT Joyce Aivalotis, USCG. Response to Action Item RT11, May 28, 1997, David

Ciscon, M. Rosenblatt & Son, Inc.

5. John Rosner, NAVSEA 00C. Meeting on Underwater CPP Blade Replacements. April

14, 1997, Clarkson Meredith, Versar, Inc., and David Eaton, M. Rosenblatt & Son, Inc.

6. Naval Sea Systems Command. Underwater Hull Husbandry Manual, Chapter 12,

Controllable Pitch Propellers. S0600-PRO-1200. February 1997.

7. Harvey Kuhn, NAVSSES. Personal Communication, March 13, 1997, Jim O’Keefe, M.

Rosenblatt & Son, Inc.

8. UNDS Equipment Expert Meeting Minutes. CPP Hydraulic Oil. September 26, 1996.

9. William Berberich, NAVSEA 03Z51. Prepared Responses to UNDS Questionnaire,

UNDS Equipment Expert Meeting. September 26, 1996.

10. William Berberich, NAVSEA 03Z51. Response to CPP Hydraulic Oil Questions, March

28, 1997, Clarkson Meredith, Versar, Inc.

11. Naval Sea Systems Command. NAVSEA Best Management Practices (BMP) to

Prevent/Mitigate Oil Spills Related to Waterborne Removal(s) of Blades on Variable

Pitch Propellers for Naval Vessels. Undated.

12. John Rosner, NAVSEA 00C. Morgrip Power Head Purge During CPP Replacements,

June 6, 1997, David Eaton, M. Rosenblatt & Son, Inc.

13. Patty's Industrial Hygiene and Toxicology, 3rd Edition. George D. and Florence E.

Clayton, Ed. John Wiley & Sons: New York, 1981.

14. Military Specification MIL-L-17331H, Lubricating Oil, Steam Turbine and Gear,

Moderate Service. November 19, 1985.

15. Shell Oil Company. MSDS for Tellus Oil #10, Code 65203. August 1988.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.
Controllable Pitch Propeller Hydraulic Oil

10

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Controllable Pitch Propeller Hydraulic Oil

11

Figure 1. Cross Section of a CPP
Controllable Pitch Propeller Hydraulic Oil

12

Figure 2. Top View of a CPP Blade
Controllable Pitch Propeller Hydraulic Oil

13

Figure 3. Cross Section of a CPP Blade Port Assembly
Controllable Pitch Propeller Hydraulic Oil

14

Figure 4. Block Diagram of a CPP System
Controllable Pitch Propeller Hydraulic Oil

15

Table 1. Armed Forces Vessels with CPP Systems

Vessel

Class Description Vessel Shafts

Navy:

CG 47 Ticonderoga Class Guided Missile Cruiser 27 2

DD 963 Spruance Class Destroyers 31 2

DDG 51 Arleigh Burke Class Guided Missile Destroyers 19 2

DDG 993 Kidd Class Guided Missile Destroyers 4 2

FFG 7 Oliver Hazard Perry Guided Missile Destroyers 43 1

LSD 41 Whidbey Island Class Dock Landing Ships 8 2

LSD 49 Harpers Ferry Class Dock Landing Ships 3 2

MCM 1 Avenger Class Mine Counter Measures Ship 14 2

Total: 149

MSC:

T-AO 187 Henry J. Kaiser Class Oilers 13 2

T-ATF 166 Powhatan Class Fleet Ocean Tugs 7 2

Total: 20

USCG:

WHEC 715 Hamilton and Hero Class High Endurance Cutters 12 2

WMEC 901 Famous Class Medium Endurance Cutters 13 2

WMEC 615 Reliance Class Medium Endurance Cutters 16 2

WAGB 10 Polar Class Icebreakers 2 3

Total: 43

Total Armed Forces Vessels with CPP: 212
Controllable Pitch Propeller Hydraulic Oil

16

Table 2. Percentages of Constituents, TEP 2190 Oil and Tellus Hydraulic Oil

Constituent MIL-L-17331H

Turbine Oil 2190

Chevron Oil

MSDS Turbine

Oil 2190

Mobil Oil

MSDS Turbine

Oil 2190

Shell Oil MSDS

Tellus Oil #10

Virgin Petroleum

Lubricating Oil (a)

Balance

Tricresyl Phosphate

(TCP)

≤ 1%

Additives ≤ 0.5% Unknown

Formaldehyde

< 1%

Hydrotreated Heavy

Paraffinic Distillates

> 99% > 95%

Solvent-Dewaxed

Heavy Petroleum

Distillates

< 1%

Hydrotreated Middle

Distillate

0 - 100%

Hydrotreated Light

Naphthenic Distillate

0 - 100%

(a) Virgin Petroleum Lubricating Oil is all classes of lubricating oil including heavy and middle Paraffinic

distillates, solvent-dewaxed heavy distillates, light naphthenic distillates, etc.

Table 3. Data Sources

Data Sources

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database, Jane’s,

Navy Home Page,

USCG Cutters List

X

3.1 Locality X

3.2 Rate X

3.3 Constituents MSDSs, Mil Specs X

4.1 Mass Loadings X

4.2 Environmental Concentrations Federal and State Regs X

4.3 Potential for Introducing NonIndigenous SpeciesX
Deck Runoff

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Deck Runoff
Deck Runoff

2

2.0 DISCHARGE DESCRIPTION

This section describes the deck runoff discharge and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

Decks are addressed in this NOD report under three categories: weather decks, aircraft

flight decks, and oiler weather decks. The runoff from each deck type reflects the materials and

treatment to which it is exposed during normal operations. All decks are exposed to a similar

and harsh environment; however, there is a core group of activities, weapons, and machinery

common to all ships. These common elements are addressed under the general category of

weather deck runoff. Runoff from flight decks from which aircraft are launched and recovered

and from oiler weather decks are addressed separately since the unique nature of the operations

conducted on these decks distinguishes them from other weather deck surfaces.

2.1 Equipment Description and Operation

2.1.1 Weather Deck Runoff

Weather deck runoff consists of rain and other precipitation, seawater which washes over

the decks (green water), and freshwater washdowns. Precipitation is usually the primary source

within 12 nautical miles (n.m.) of shore. Except for small craft, green water or salt spray over the

deck occurs primarily at sea and does not contribute to deck runoff while a ship is in port or in

protected coastal waters. Freshwater washdowns also occur, but contribute less to weather deck

runoff than precipitation.

The following paragraphs summarize each source that can contribute components to

weather deck runoff.1

Deck Machinery - Ships have many pieces of deck machinery, such as windlasses,

mooring winches, boat winches, underway replenishment gear, cranes, towing winches,

and stern gates. This equipment is maintained with a variety of materials, including

lubricating oils and greases that may be present in the deck runoff.

Topside Debris - Debris is trash (e.g., cigarette butts, dirt, paper) that can be washed

overboard. The amount of debris is almost entirely a function of housekeeping practices,

and crew discipline determines how much is collected for disposal instead of being

washed overboard.

Wire Rope - Wire rope is used extensively in topside rigging, deck machinery,

replenishment gear, and other equipment. It must be lubricated to prevent premature

failure caused by friction between strands as the rope is worked. The lubricating oil or

grease must be thin enough to flow or be worked between individual strands, but

sufficiently wash-resistant to withstand rain and washdowns.
Deck Runoff

3

Fueling Operations - Fueling operations, either at sea or in port, may contaminate the

deck with petroleum hydrocarbons (e.g., diesel, JP-5, fuel oil).

Weapons Systems - Gun mounts, missile launchers, weapons directors, and other

weapons-related equipment can contribute constituents similar to those of deck

machinery; however, they are less likely to contribute to deck runoff because most are

contained in a turret or other water-tight or water-resistant enclosure.

Ship’s Boats - Surface ships have small boats (e.g., punts, landing craft, rigid inflatable

boats [RIBs]) that are stored topside. They have bilge plugs that are removed while

stored, to drain rainwater, washdown water, or green water through their bilge and onto

the deck if the boats are not properly covered. Constituents in the bilge (primarily diesel

fuel) are discharged with the water.

Soot Particles - Burned fuels can leave fine soot particles on the deck. Except for MSC

ships that are powered in equal numbers by steam and diesel propulsion equipment, the

majority of the Armed Forces’ surface ships and craft have diesel or gas turbine

propulsion and use clean-burning distillates to minimize soot. However, significant

amounts of soot can be produced during boiler light-off or after prolonged shutdowns of

turbines and diesels.

Firefighting Agents - Aqueous Film Forming Foam (AFFF) firefighting systems are

tested periodically in accordance with the planned maintenance system (PMS). These

tests are conducted beyond 12 n.m. or while making 12 knots or more when transiting

between 3 and 12 n.m.. The AFFF must be collected if the exercise occurs within 3 n.m.

As discussed in the AFFF NOD report, AFFF is not discharged overboard within 3 n.m.

of shore except in the rare instance of an actual shipboard fire.

Cleaning Solvents and Detergents - Miscellaneous solvents are used to clean and

maintain topside equipment. These solvents may contain chlorinated compounds.

However, they are also volatile and evaporate quickly. As such, their presence in deck

runoff is expected to be minimal to nonexistent. During freshwater washdowns, crew

members may use detergents that become part of the runoff.

Some or all of the above-listed sources that contribute to the contamination in deck runoff

are common to all vessels.

Various Navy ports treat weather deck runoff differently. To date, no port is known to

require the containment of rainwater runoff; however, a containment requirement may exist for

some freshwater washdowns in certain Navy ports. For instance, at the Naval Submarine Base,

Bangor, WA, freshwater washdowns containing cleaning agents, detergents, or other additives

are considered to be industrial discharges; and, as such are not permitted to be discharged into the

Hood Canal, rated a class AA “extraordinary” water body.2 On the other hand, low-pressure

freshwater washdowns completely free of cleaning agents or other chemicals need not be

contained, and may be discharged into the Hood Canal.2
Deck Runoff

4

The U.S. Coast Guard (USCG) performs washdowns of its ships after returning to port

and weekly while in port.3 Initially, the decks are cleared of debris by hand and/or vacuum and

then scrubbed with fresh water and detergent using brushes and screening pads. Fresh water is

used to rinse the washdown overboard.3

Deck runoff occurs on boats and craft although some, such as RIBs, are stored on land.

Because these vessels are small, green water becomes a significant contributor to deck runoff,

and freshwater washdowns occur more frequently to remove the effects of green water on these

vessels compared to larger ships. Craft, such as mechanized landing craft (LCMs), and smaller

boats, such as RIBs and river patrol boats (PBRs), are washed down frequently to remove

saltwater spray and residues left by heavy equipment and troops. However, many of these craft

have large wells and very little deck area, which reduces the amount of deck runoff. Instead,

precipitation, washwater, and green water collect in the bilge, rather than contributing to deck

runoff. The USCG washes down its smaller vessels (i.e., those less than 65 feet long) nearly

every day.3

2.1.2 Flight Deck Runoff

The same three sources of water contribute to this discharge as to that of weather deck

runoff: precipitation, greenwater over the deck from heavy seas, and deck washdowns, in this

case flight deck washdowns. As with weather deck runoff, flight deck runoff can be

contaminated with a variety of chemicals.

Aircraft carrier launch and recovery equipment, e.g., catapult troughs and jet blast

deflectors, are unique to aircraft carriers and are a major contributor of contaminants to flight

deck runoff. Lubricating oil is applied to the catapult before each launch, and a fraction of this

oil, along with the fuel mist emitted from aircraft during launch and hydraulic fluid and grease

from the catapult, are deposited in the four catapult troughs of each carrier. 4-6 Most of these

deposits drain overboard during flight operations, i.e., beyond 12 n.m., but a considerable amount

of residual deposits can remain where precipitation can wash it overboard, either during transit or

in port.4-6 Oil sheens have been observed in port around aircraft carriers. This usually occurs

following rainstorms due to runoff from the catapult troughs. In addition, the jet blast deflectors

accumulate soot from jet exhaust, and have hydraulic system leakage that could contribute to

flight deck runoff.

Most commissioned Navy vessels have flight decks for helicopter landing and takeoff.

Many of these ships also have hangar facilities for helicopter storage and maintenance. The

LHA, LHD, and LPH Classes of amphibious assault vessels have between 30 and 36 helicopters

embarked, and some have about a dozen Vertical/Short Take-Off and Landing (VSTOL) aircraft

as well. Flight exercises are conducted routinely with these aircraft.

Several other classes of vessels also have helicopter landing areas and hangars which

accommodate one to three helicopters. These ships carry helicopters as part of their normal

complement, but conduct flight operations less frequently than carriers or amphibious assault
Deck Runoff

5

ships. Exceptions are the large service force ships, such as fast support ships (AOEs),

ammunition ships (T-AEs), and combat stores ships (T-AFSs), which carry two or three UH-46

Sea Knight helicopters for underway replenishment (UNREP). These ships use the helicopters to

transfer large volumes of provisions and ammunition rapidly during UNREP operations.

Vessels with ancillary helicopter flight decks and do not have their own helicopters, are

not included in this analysis because they contribute very little helicopter-specific flight deck

runoff compared to an amphibious assault vessel, which can carry up to 36 helicopters.

Flight deck washdowns to eliminate fire and slip hazards and to wash salt spray off flight

decks are performed while ships are underway.7,8 Both Commander Naval Air Force, U.S.

Atlantic Fleet (COMNAVAIRLANT) and Commander Naval Air Force, U.S. Pacific Fleet

(COMNAVAIRPAC) have promulgated policies that carrier flight decks are not to be washed

down within 12 n.m. of shore except in cases of emergency.7,8 Further, both Commander Naval

Surface Force, U.S. Atlantic Fleet (COMNAVSURFLANT) and Commander Naval Surface

Force, U.S. Pacific Fleet (COMNAVSURFPAC) have policies in force that state that decks shall

not be washed within 12 n.m. of shore.9,10

Aircraft and helicopter freshwater washdowns are performed to remove dirt,

hydrocarbons, salt deposits, and other materials resulting from flight operations or from salt

spray. Unless the ship’s engineering officer is short of fresh water, the aircraft are washed before

they disembark upon the ship’s return to port. Since current policies require that flight deck

washing be completed prior to the ship arriving within 12 n.m. of shore, and since aircraft are

disembarked prior to washing the flight deck, aircraft are not usually aboard either aircraft

carriers or amphibious assault ships within 12 n.m. of shore. Therefore, aircraft freshwater

washdowns do not contribute to deck runoff with 12 n.m. of shore.11

MSC has not promulgated protocols for the washing of helicopter flight decks on its

vessels. The cleaning agent/solvent used and the washdown frequency are at the discretion of the

officer in charge of the deck. Except in unusual circumstances, flight decks are not washed in

port.12

2.1.3 Oiler Weather Deck Runoff

Oilers carry various petroleum products as cargo. This report examines the discharge

from Navy and MSC oilers and UNREP ships which perform fueling-at-sea (FAS) operations. It

also examines the discharge from the fuel barge service craft, which are used to fuel and defuel

surface vessels while in port.

During the receiving and off-loading of bulk fuel, oilers have the potential to discharge

oil. To prevent this, the weather deck is sealed by plugging or blocking the weather deck

openings as required by Federal Regulations.13 If the liquid contains oil from inadvertent spills

or releases, the liquid is processed through the ship’s oily waste treatment system. These ships

are also provided with oil spill containment and cleanup kits.
Deck Runoff

6

The newer oilers, such as the T-AO 187 Class, incorporate engineering design features

and follow fueling practices that minimize oil releases. Excess oil and other uncontained liquids

drain to a sludge collection tank, which is routed to an oily waste collection system. Any other

liquid that collects in these sumps, such as rainwater or seawater, is also routed through the oily

waste collection system.14 The 7-inch fueling hoses contain check valves to prevent spills when

disconnected. Additional protection against spills is provided by “blowing down” the hose with

compressed air and/or taking a “back suction” with the cargo or stripping pumps and pumping

the contents of the hose back to the oiler’s cargo reclamation system before disconnecting the

hose. FAS stations are also provided with spill response equipment to contain one to six barrels

of oil (42 to 252 gallons), and with sorbents to contain any drips or small spills.

The newer designs also include the required catchment basin around fuel tank vent

stations to contain oil and other liquids released because of overfilling during fueling

operations.13 If the liquids contain oily residues, these basins are pumped to the oily waste

collection system. If the catchment basin contains only rainwater, the rainwater is discharged

overboard. The catchments are routinely cleaned to remove oily residue. The disposition of

these wash waters is to the oily waste collection system.14 The treatment and disposition of oily

waste is covered in the Surface Vessel Bilgewater/OWS Discharge NOD report.

All fuel barges have fire and flooding alarms, and are equipped with high tank level

alarms. Ship alterations have been prepared to install oil retaining coamings and plugs for all

fuel barges. Most barges currently in use were built or retrofitted with the coamings.15 Fuel oil

barges refuel ships within 12 n.m. of shore, whereas the oilers/UNREP vessels refuel ships

beyond 12 n.m.

2.2 Releases to the Environment

Deck runoff is produced when water falls on or is applied to the exposed surfaces, such as

weather and flight decks, superstructure, bulkheads, and the hull above the waterline, of a ship.

Frequently runoff is contaminated by residues from the activities described in Section 2.1. The

probable contaminants include: oil and grease; petroleum hydrocarbons; surfactants; cleaners;

glycols; solvents; and particulates, such as soot, dirt, or metallic particles.

2.3 Vessels Producing the Discharge

Deck runoff is produced on all ships, submarines, boats, and craft of the Armed Forces

(Table 1). Table 1 lists ship class, number of ships homeported in the U.S., dimensions (length

and beam), flight deck dimensions (where applicable), and the number of days annually that

each class of ship averages within 12 n.m.16-25 The several thousand small boats and craft of the

Armed Forces are not individually categorized.

Water, other than green water, that falls on the decks of submarines while they are in port

or transiting inside of 12 n.m. is deck runoff. For submarines, green water is not considered deck

runoff because of their design. All operating equipment on a submarine, with some minor

exceptions, is contained within the double hull of the ship. Some outboard equipment, such as
Deck Runoff

7

the hydroplanes, rudder, shaft seals, periscope, and antennae, are greased on a submarine;

however, discharges from these sources are described in a separate NOD report. When

operating, submarines spend virtually all of their time submerged beyond 12 n.m., and no

activities are performed topside on a routine basis that could contribute to the contamination of

deck runoff. Similarly, while submarines are in port, the majority of work occurs on the inside of

the ship, not topside. Based on this information, the deck runoff from submarines is not a

significant discharge.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

This discharge consists of runoff from rainfall and other precipitation, from freshwater

washdowns, and from green water; therefore, it can occur while in port or at sea. Table 1

contains a tabulation of the number of days the various vessel types spend within 12 n.m. of

shore.16

3.2 Rate

The gallons of precipitation runoff per year estimated for each home port of a ship class is

the product of the deck area of a ship in the class, the number of ships in the class in a given

homeport, the average fraction of the year spent within 12 n.m. of shore, the average annual

rainfall in the homeport, and the appropriate conversion factors. The total gallons of runoff from

a ship class is the sum of the estimates thus developed for all the homeports of the class.

3.2.1 Weather Deck Runoff

Precipitation is expected to be the largest contributor to deck runoff in all types of

vessels. Annual average precipitation data were obtained for the largest ports used by the Armed

Forces as homeports: Norfolk and Little Creek, VA; San Diego, CA; Pearl Harbor, HI; Groton,

CT; Mayport, FL; Ingleside, TX; and Bremerton, WA.26 The average number of transits and

days in port were developed for the years 1991 through 1995 for Navy and USCG ships.16

The various deck areas were estimated by multiplying the product of a vessel’s length and

beam by a factor intended to account for the departure of the deck’s shape from a rectangle. In

Table 1, those ship classes which are asterisked have a helicopter platform, but do not have a

helicopter routinely embarked. The deck areas listed for these vessel classes include the area of

the flight deck. For vessel classes whose helicopter platform dimensions are without an asterisk,

such as the Spruance Class destroyers (DD 963), the deck area listed in Table 1 does not include
Deck Runoff

8

the area of the helicopter platform.

The gallons per year precipitation runoff values listed in Tables 2 through 7 and in Tables

9a and 9b were all estimated using the same formula:

(N) (D/365)(A)(P)(PF)(FG) = Annual Runoff (gallons per year)

where N = the number of ships with the same deck area contributing to the annual runoff

D = the number of days per year each ship is within 12 n.m. of shore

A = the area in square feet of the deck or flight deck under consideration

P = the annual rainfall in inches

PF = 1/12, the conversion factor - one foot per 12 inches

FG = 7.48 gallons per cubic foot

Based upon this information and average deck area, an estimate of weather deck runoff

from precipitation was developed for Navy ships by home port, and is presented in Table 2.

Approximately 37.6 million gallons of weather deck runoff occurs annually from Navy surface

ships in U.S. homeports due to rainfall.

To derive estimates of the precipitation-induced weather deck runoff from MSC, USCG,

and Army vessels, a 40-inches-per-year rainfall was assumed, the annual average for the Navy

homeports. The estimates are provided in Table 3. Approximately 54.6 million gallons of

weather deck runoff occur annually within 12 n.m. of the U.S. coast from MSC, USCG, and

Army vessels due to precipitation.

The Armed Forces operate literally thousands of boats and craft of a multitude of sizes

throughout the offshore waters, harbors, and rivers of the U.S. Because neither the precise

location of all of the boats and craft nor the mode of operation and storage at each location has

been determined, it is impractical to estimate rates for these vessels.

3.2.2 Flight Deck Runoff

An estimate for aircraft carrier flight deck precipitation runoff is based upon reported

average annual precipitation, the number of ships in each homeport, the flight deck area, and the

number of days in port. Approximately 23.3 million gallons of weather deck runoff from aircraft

carrier flight decks occur annually within 12 n.m. of the U.S. coast due to precipitation.

These results show that the quantity of aircraft carrier flight deck runoff varies

significantly with geographical location. San Diego, CA, has the lowest average annual rainfall

resulting in the least runoff. Although Norfolk, VA does not have the highest precipitation rate,

it produces the highest amount of flight deck runoff because it is homeport to the most carriers.

The data and results are presented in Table 4. Because it is not unusual for three carriers to be in

Norfolk at the same time, and for summer storms to produce an inch of rain in a few hours, the
Deck Runoff

9

three carriers, with a combined flight deck area of 690,000 ft2, will generate approximately

430,000 gallons of flight deck runoff for each inch of rain.

Of the 11 amphibious assault vessels in service, 10 are stationed in U.S. ports, and are

homeported either in Norfolk, VA, or San Diego, CA. The ships, by class, are divided evenly

between these two ports. The mine countermeasures support ship USS Inchon (MCS 12) is a

converted Iwo Jima Class LPH, and is homeported in Ingleside, TX. The estimated total annual

helicopter flight deck runoff for these vessels due to precipitation is approximately 8.3 million

gallons. Table 5 is a compilation of the data used to estimate the average annual deck runoff

from these ships due to precipitation.

Table 6 lists flight deck runoff from Navy surface vessels, other than aircraft carriers and

amphibious assault vessels, by U.S. homeport, number and location of vessels by class, and the

average annual rainfall for each port. Based on this information, these ships generate an annual

deck runoff of approximately 2.6 million gallons due to precipitation.

The estimate for precipitation runoff from helicopter flight decks of MSC and USCG

surface ships is presented in Table 7. The estimate was derived from the areas of the flight

decks, the average annual rainfall, and the number of days in port for each ship class. Based on

this information, MSC and USCG surface ships generate an estimated annual deck runoff of 860

thousand gallons due to precipitation.

A volume of helicopter flight deck wash water generated by USCG vessels is estimated in

Table 8. The volume used to wash and rinse a given flight deck area is considered to be the same

as would be used on a Navy ship, that is, 30-gallons of a cleaning solution mix of MIL-C-85570,

type II detergent, sodium metasilicate (anhydrous or pentahydrate), and freshwater will treat

approximately 3,000 ft2 of deck. The amount of water used to rinse the cleaning solution off of

the deck is on the order of three to five times the volume of the cleaning solution used. Further,

because the USCG washes weekly, the number of washes annually is estimated by dividing the

number of days a vessel is within 12 n.m. of shore by seven.3 Based upon these assumptions,

USCG surface ships generate approximately 70 thousand gallons of helicopter flight deck wash

water as compiled in Table 8.

3.2.3 Oiler Weather Deck Runoff

Estimates have been prepared, using the same methodology, for the deck runoff from

Navy and MSC oilers due to precipitation. They are presented in Table 9a. Similar estimates

were prepared for the various service craft, such as fuel barges, and are presented in Table 9b.

As indicated in the tables, the estimated annual runoff from the oilers is approximately 8 million

gallons, and from the various service craft approximately 8.9 million gallons.

3.2.4 Runoff Summary

Table 10 is a compilation of the runoff volumes associated with the various runoff

sources and vessel types. As indicated in the table, the estimated annual runoff from vessels of
Deck Runoff

10

the Armed Forces due to precipitation and the limited number of in-port washdowns is

approximately 143.9 million gallons.

3.3 Constituents

The runoff from flight and other weather decks can contain a number of different

constituents, including: JP-5, found in the runoff from aircraft carrier flight decks, helicopter

flight decks, and the weather decks of support ships carrying JP-5 as cargo; diesel fuel marine,

distillate fuel, or gasoline, from vessel fueling and refueling operations; various solids, such as

soot, paint chips, dirt, and trash; glycol from the windshield washing system; hydraulic fluid

leakage; metals from scrapes, gouges and corrosion; rubber from aircraft tires; and the residue

from cleaners and solvents, particularly sodium metasilicate.

These materials contain short- and medium-length aliphatics, light and heavy aromatics,

paraffins, olefins, surfactants, glycols, and metals. Some cleaning solvents can contain

chlorinated compounds, such as tetrachloroethylene. These solvents quickly evaporate.

Analytical data are available for one element of aircraft carrier flight deck runoff: the

runoff that flows through a catapult trough and is discharged overboard. This runoff was

sampled in a study on the feasibility of using an oil/water separator to treat trough runoff.27 The

resulting data are not representative of the runoff from the entire flight deck of a carrier, only of

runoff that is discharged from one of the catapult troughs. The aqueous phase of the catapult

trough runoff was analyzed for:

• oil and grease,

• phenols, and

• metals (silver, cadmium, chromium, copper, nickel, and lead).

The four catapult troughs are located in close proximity to the aircraft fueling spots, and

collect spilled JP-5. Lubricating oil is applied to a catapult before each shot. A fraction of this

oil, along with fuel mist emitted from aircraft during launch, and hydraulic fluid and grease from

the catapult is deposited in each of the four catapult troughs.4-6 The concentrations originating in

the catapult troughs can, therefore, be expected to exceed those for the flight deck runoff in

general.

None of the constituents analyzed for are bioaccumulators, and no bioaccumulators are

anticipated in this discharge. The materials used on the decks of vessels do not contain the

pesticides, herbicides, PCBs, or other chlorinated aromatic compounds that constitute

bioaccumulators.

Of the constituents listed above, silver, cadmium, chromium, copper, nickel, lead, and

phenols are priority pollutants.

3.4 Concentrations
Deck Runoff

11

The laboratory data from an aircraft carrier catapult trough drain system are presented in

Table 11. The data are the concentrations before processing the runoff through an oil/water

separator, and are not representative of the runoff from the entire flight deck of an aircraft

carrier.27

Constituent concentrations resulting from precipitation are expected to vary significantly

with a number of factors. These include: time since the last rain or deck washing; the intensity

and duration of the last rainfall; the season (which will effect glycol loading from deicing fluids);

the ship’s adherence to good housekeeping practices; and the type, intensity, and duration of

weather (high sea state and green water) and ship’s operations. For example, higher seas which

result in more frequent green water runoffs and more frequent freshwater washdowns, both of

which generally occur outside 12 n.m., will minimize the concentrations of accumulated residues

that contribute to runoff contamination in port. Further, it should be noted that deck runoff from

precipitation may mimic the constituent concentration patterns observed in storm water runoff

from highways and parking lots: contaminant concentrations will be higher in first portions of

the runoff, and then will taper off to low or nondetectable levels as the precipitation continues.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. A discussion of mass

loadings is presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

are compared with the water quality standards. In Section 4.3, the potential for transfer of nonindigenous species is discussed.

4.1 Mass Loadings

Currently, no basis exists for estimating the mass loadings of deck runoff accurately. The

factors discussed in Section 3.4, that combine to produce the great variance in deck runoff,

prohibit the development of engineering assumptions from which to estimate deck contaminant

concentrations. The use of the data from any analysis of the untreated runoff that had flowed

through an aircraft carrier catapult trough could result in mass loadings that are overestimated by

orders of magnitude.

4.2 Environmental Concentrations

As with mass loadings, because the constituent concentrations vary with a number of

factors, most of which vary over time since the last rainfall or washdown; the environmental

concentrations will vary accordingly. For any given set of factors discussed in Section 3.4, the

discharge concentrations for the catapult trough portion of deck runoff can be used as a worst

case for a specific contributor.

The catapult trough discharges as a component of the flight deck runoff are diluted as

they enter the receiving waters, but to what extent is unknown. Therefore, the raw concentration
Deck Runoff

12

values are used for comparison to the Federal and most stringent state water quality criteria listed

in Table 12. The comparisons show that a number of the constituent concentrations in catapult

trough runoff exceed Federal and state acute water quality criteria, in addition to discharging oil

exceeding the Federal discharge limits.28 Chromium concentrations exceed the most stringent

state’s water quality criteria. The detected metals that exceed the Federal and most stringent state

water quality criteria are: cadmium, nickel, and lead. In addition, two metals, silver and copper,

which were not detected, have reported limits that are more than an order of magnitude higher

than their corresponding Federal and state water quality criteria. The reported phenols

concentration exceeded the most stringent state criteria. The oil and grease concentration

exceeds the Federal criterion and the concentrations reported are also likely to cause a visible

sheen on receiving waters. Discharges of oil that cause a visible sheen on receiving waters must

be reported.28

4.3 Potential For Introducing Non-Indigenous Species

The potential for non-indigenous species transport is insignificant. The runoff due to

rainfall and washdown has a low potential to contain non-indigenous species, and the runoff

from green water is discharged in the same location from which it came aboard.

5.0 CONCLUSION

Oil in the deck runoff discharge has the potential to cause an adverse environmental

effect. This conclusion is based upon observations of oil sheens on the water surface

surrounding certain vessels during and after rainfalls.

6.0 DATA SOURCES AND REFERENCES

Table 13 shows the sources of data used to develop this NOD report.

Specific References

1. “Deck Runoff from U.S. Naval Vessels”, M. Rosenblatt & Son, Inc. Prepared for Naval

Sea Systems Command. September 1996.

2. Dye, J., Public Works Office, Naval Submarine Base, Bangor, WA. Response to UNDS

Questionnaire: Contained Washdowns and Deck Runoff.

3. Aivalotis, Joyce, USCG. Report Regarding USCG Outstanding Information, May 29,

1997, David Ciscon, M. Rosenblatt & Son, Inc.

4. UNDS Equipment Expert Meeting Minutes - Catapult Troughs, Water Brake, Jet Blast

Deflector, Arresting Cables. August 22, 1996.
Deck Runoff

13

5. UNDS Equipment Expert Meeting Minutes - Catapult Discharges. July 26, 1996.

6. Commander, Naval Sea Systems Command. Memorandum to Commander, Naval Air

Systems Command. Pollution of Coastal Waters Attributable to Catapult Lube Oil.

December 16, 1992.

7. LCDR Mills, Staff (N43), COMNAVAIRLANT. AIRLANT Policy Relative To Aircraft

Carrier Washdowns, August 21, 1997, Randy Salyer, M. Rosenblatt & Son, Inc.

8. ABECS Gibson, Staff (N43), COMNAVAIRPAC. AIRPAC Policy Relative To Aircraft

Carrier Washdowns, August 21, 1997, Randy Salyer, M. Rosenblatt & Son, Inc.

9. LT Carlos Castillo, Staff, Commander Amphibious Group Two. Norfolk - Little Creek,

VA. SURFLANT Policy Relative to Amphibious Assault Ship Flight Deck Washdowns,

November 5, 1997, Jim O’Keefe, M. Rosenblatt & Son., Inc.

10. LCDR Southall, Staff (N42), Commander Surface Force, U.S. Pacific Fleet, San Diego,

CA. SURFPAC Policy Relative To Amphibious Assault Ship Flight Deck and Surface

Ship Weather Deck Washdowns, November 6, 1997, Jim O’Keefe, M. Rosenblatt &

Son., Inc.

11. UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Steam

Blowdown Discharge. August 20, 1996.

12. Stucka, Bob, MSC Field Engineer, Norfolk, VA. MSC Policy Relative To Flight Deck

Washdowns, September 9, 1997, Jim O’Keefe, M. Rosenblatt & Son, Inc.

13. Code of Federal Regulations, 33CFR155, Sub Part B, Vessel Equipment.

14. Hofmann, Hans, MR&S. Responses To Inquiries Regarding The Design Features In The

T-AO 187 Class Oilers To Prevent Pollution, December 17, 1996, Clarkson Meredith,

Versar, Inc.

15. North, Dick, Puget Sound Naval Shipyard, Boston Detachment, Boston, MA. Status of

Pollution Preventative ShipAlts For Yard and Service Craft Oilers, September 3, 1997,

Jim O’Keefe, M. Rosenblatt & Son, Inc. (MR&S).

16. Pentagon Ship Movement Data for Years 1991 -1995, Dated March 4, 1997.

17. Ship Management Information System Report JQ02, U.S. Naval Battle Forces As Of 30

June 1997, June 13, 1997. 20.

18. Weersing, Penny, MSC Engineer, Estimates of Time In U.S. Ports For MSC Vessels,

March 19, 1997, Jim O’Keefe, M. Rosenblatt & Son, Inc. U.S. Navy Public Affairs

Home Page. List of U.S. Navy Ships and Their Homeports, March 1, 1997.
Deck Runoff

14

19. U.S. Coast Guard, Listing of Vessels and Permanent Stations, 1992.

20. Naval Sea Systems Command (NAVSEA), Data Book for Boats and Craft of the United

States Navy, NAVSEA 0900-LP-084-3010, Revision A. May 1988.

21. U.S. Army Combined Arms Support Command, Army Watercraft Master Plan,

November 1996.

22. Headquarters, Dept. of the Army. Watercraft Equipment Characteristics and Data,

Technical Manual TM 55-500, May 1992.

23. Sharpe, Richard. Jane’s Fighting Ships. Jane's Information Group, Ltd.,1996.

24. Aivalotis, Joyce, USCG. USCG Ship Movement Data, May 27, 1997,

Lee Sesler, Versar, Inc.

25. UNDS Ship Database, August 1, 1997.

26. The World Almanac and Book of Facts. Mahwah: Funk & Wagnalls, 1995.

27. “Waste Buster” Test of Oily Waste Treatment Facility. NNS Laboratory Services. April

1994.

28. Code of Federal Regulations, 40 CFR 110, EPA Regulations on Discharge of Oil.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.
Deck Runoff

15

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

M. Rosenblatt & Son, Inc. Comments on Draft Nature of Discharge Report: Flight Deck

Runoff, Aircraft Carriers. February 13, 1997.

UNDS Equipment Expert Meeting Minutes - Deck Runoff. September 19 and October 17, 1996.

Wallace, Christine, Public Works Office, Naval Base, Norfolk, VA. Response to UNDS

Questionnaires: Deck Runoff, Solvent Cleaning, Degreasing Solutions, Aircraft

Washdowns.

Military Specifications for Petroleum Compounds:

Diesel Engine Lubricating Oil Data, MIL-L-9000 Military Symbol (MS) 9250

JP-5 Aviation Fuel Data, MIL-T-5624 NATO Code F44

Fuel, Naval Distillate Data, MIL-F-16884 NATO Code F76

3M Corporation. MSDS - FC-203CF Light Water Brand Aqueous Film Forming Foam, April

1995.

MSDSs from Vermont SIRI - http://hazard.com/MSDS:

Texaco - Marine Diesel Blend 00813 (NATO Code F76) - Diesel Fuel DFM

Amoco - Marine Diesel Fuel (F76) - Diesel Fuel DFM

U.S. Oil Refining - JP-5 Jet Fuel, Turbine Engine, Aviation JP-5 F (44)
Deck Runoff

16

P-D-680 Type I Dry Cleaning Solvent (bought to spec)

Captree Chemical - Sodium Metasilicate, Pentahydrate

Lidochem - Sodium metasilicate anhydrous

Naval Surface Warfare Center, Norfolk Division. UNDS Small Boats and Craft Meeting,

September 12 and 13, 1996.

Patty’s Industrial Toxicology, 2nd Ed. New York: John Wiley & Sons, 1981.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Table 1. Listing of Ships and Vessels for Deck Runoff

Navy, MSC, USCG and Army

Homeported Additional Ship Dimensions Helo Pad Dimensions Weather Days

Vessel Category In U.S.* Projected Length Beam Length Width Deck Area within 12 n.m.

(ft) (ft) (ft) (ft) (sq ft)

* Where ships of this class are homeported in foreign ports, their number appears in parentheses, e.g., 8 (2) indicates 8 ships in the class, 2 homeported overseas, therefore only six are

 considered in calculating the deck runoff in that class.

** Denotes ships which do not embark helicopters as part of their normal complement, so helocopter flight deck area is included in weather deck area

*** DDG 51-78 do not have helos embarked; DDG 79 and Follow will have two embarked helos.

Navy Ships

Aircraft Carriers

Forrestal Class Carrier (CV 59) 1 (1) 0 1052 130 220,000 0

Kitty Hawk Class Carriers (CV 63) 3 0 1063 130 220,000 139

Enterprise Class Carriers (CVN 65) 1 0 1123 133 230,000 78

Nimitz Class Carriers (CVN 68) 7 2 1092 134 230,000 149

Amphibious Assault Ships

Wasp Class Assault Ship (LHD 1) 4 3 819 106 86,814 188

Tarawa Class Assault Ship (LHA 1) 5 (1) 0 820 118 92,800 175

Iwo Jima Class Assault Ship (LPH 2) 2 0 602 104 62,608 189

Submarines

Ohio Class Ballistic Missile Submarines (SSBN 726) 17 0 560 42 15,288 185

Sturgeon Class Attack Submarine (SSN 637) 13 0 302.2 31.8 6,246 185

Los Angeles Class Attack Submarine (SSN 688) 56 0 362 33 7,765 185

Narwhal Class Submarine (SSN 671) 1 0 314.6 37.7 7,709 185

Benjamin Franklin Class Submarines (SSN 640) 2 0 425 33 9,116 185

Surface Ships

Virginia Class Cruisers (CGN 38) 1 0 585 63 20** 27 28,747 164

California Class Cruisers (CGN 36) 2 0 596 61 43** 38 28,358 146

Ticonderoga Class Cruisers (CG 47) 27 (2) 0 567 55 54 40 22,164 169

Kidd Class Destroyers (DDG 993) 4 0 563.3 55 52** 41 24,166 104

Arleigh Burke Class Destroyers (DDG 51)*** 18 (2) 30 504.5 66.9 49** 42 26,326 178

Spruance Class Destroyers (DD 963) 31 (3) 0 563.2 55.1 52 42 22,021 181

Oliver Hazard Perry Class Frigates (FFG 7) 43 (2) 0 445 45 54 36 13,676 170

Blue Ridge Class Command Ships (LCC 19) 2 (1) 0 636.5 107.9 72** 74 53,569 181

Austin Class Amphibious Transport Dock (LPD 4) 3 0 570 100 209** 61 44,460 181

Austin Class Amphibious Transport Dock (LPD 7) 3 (1) 0 570 100 199** 61 44,460 191

Austin Class Amphibious Transport Dock (LPD 14) 2 0 570 100 203** 75 44,460 195

Whidbey Class Dock Landing Ships (LSD 41) 8 (2) 0 609.5 84 189** 71 39,934 171

Harpers Ferry Class Dock Landing Ships (LSD 49) 3 1 609.5 84 188** 72 39,934 216

Anchorage Class Dock Landing Ships (LSD 36) 5 0 553.3 84 78** 78 36,252 218

Newport Class Tank Landing Ships (LST 1179) 3 0 522.3 69.5 49** 54 28,314 183

Avenger Class Mine Countermeasures Ship (MCM 1) 14 (2) 0 224 39 6,814 239

Osprey Class Coastal Minehunters (MHC 51) 12 6 188 35.9 5,264 239

Cyclone Class Patrol Ships (PC 1) 13 1 170.3 24.9 3,308 110
Table 1. Listing of Ships and Vessels for Deck Runoff

Navy, MSC, USCG and Army

Homeported Additional Ship Dimensions Helo Pad Dimensions Weather Days

Vessel Category In U.S.* Projected Length Beam Length Width Deck Area within 12 n.m.

(ft) (ft) (ft) (ft) (sq ft)

* Where ships of this class are homeported in foreign ports, their number appears in parentheses, e.g., 8 (2) indicates 8 ships in the class, 2 homeported overseas, therefore only six are

 considered in calculating the deck runoff in that class.

** Denotes ships which do not embark helicopters as part of their normal complement, so helocopter flight deck area is included in weather deck area

*** DDG 51-78 do not have helos embarked; DDG 79 and Follow will have two embarked helos.

Patrol and Landing Craft

Pegasus Class Mk V Patrol Boats (SOC/PBF) 7 14 82 17.5 1,119 320

Mk III Patrol Boats (PB) 14 68 18 955 320

Stinger Class Patrol Boats (PB) 10 65 18 955 320

Mk II River Patrol Boats (PBR) 25 35 9.3 246 320

Landing Craft Air Cushion (LCAC) 91 (3) 81 43 3,483 320

LCU 1600 Class Utility Landing Craft (LCU) 40 134.9 29 3,912 320

LCM 8 Class Mechanized Landing Craft (LCM) 100 73.7 21 575 320

LCM 6 Class Mechanized Landing Craft (LCM) 60 56.2 14 300 320

Landing Craft Personnel (LCPL) 130 36 12.1 160 320

Armored Troop Carriers (AT) 21 36 12.7 365 365

Auxiliaries

Jumboised Cimmaron Class Oilers (AO 177) 5 0 709 88 59** 76 48,666 191

Sacramento Class Fast Combat Support (AOE 1) 4 0 793 107 83 71 60,291 186

Supply Class Fast Combat Support (AOE 6) 3 1 754 107 70 95 56,279 116

Raleigh Class Command ship (AGF 3) 1 (1) 522 90** 90** 76 34,201 0

Austin Class Command Ship (AGF 11) 1 0 570 100 195 78 29,250 186

Safeguard Class Salvage Ships (ARS 50) 4 0 255 51 20** 20 10,144 214

Simon Lake Class Submarine Tender (AS 33) 1 (1) 644 85 39** 65 42,697 0

Emory S Land Class Submarine Tenders (AS 39) 3 0 643.8 85 31** 34 42,684 295

Iwo Jima Class MCM Support Ship (MCS 12) 1 0 602 104 62,608 189

Diving Tenders (YDT) 3 50 12 600 320

Harbor Utility Craft (YFU) 2 134.9 29 3,912 365

Patrol Craft (YP) 28 108 24 2,022 365

Torpedo Trials Craft (YTT) 3 186.5 40 5,819 320

Torpedo Retrievers, 65 ft (TR) 3 65 14 710 320

Torpedo Retrievers, 72 ft (TR) 5 72 15 842 320

Torpedo Retrievers, 85 ft (TR) 5 85 18 1,193 320

Torpedo Retrievers, 100 ft (TR) 3 100 21 1,638 320

Torpedo Retrievers, 120 ft (TR) 6 120 25 2,340 320

Large Harbor Tugs (YTB) 72 109 30 2,551 320

Ashville Class Research Ships (YAG) 3 164.5 23.8 3,054 320

Fuel Oil Barge, Nonselfpropelled (YON) 40 165 40 6,600 365

Fuel Gasoline Barge, Nonselfpropelled (YOGN) 9 165 40 6,600 365

Fuel Oil Storage Barge (YOS) 5 165 40 6,600 365

Miscellaneous Boats and Craft 3000+ Various dimensions - 365

Military Sealift Command

Kilauea Class Ammunition Ships (T-AE) 8 0 564 81 69 60 31,494 45
Table 1. Listing of Ships and Vessels for Deck Runoff

Navy, MSC, USCG and Army

Homeported Additional Ship Dimensions Helo Pad Dimensions Weather Days

Vessel Category In U.S.* Projected Length Beam Length Width Deck Area within 12 n.m.

(ft) (ft) (ft) (ft) (sq ft)

* Where ships of this class are homeported in foreign ports, their number appears in parentheses, e.g., 8 (2) indicates 8 ships in the class, 2 homeported overseas, therefore only six are

 considered in calculating the deck runoff in that class.

** Denotes ships which do not embark helicopters as part of their normal complement, so helocopter flight deck area is included in weather deck area

*** DDG 51-78 do not have helos embarked; DDG 79 and Follow will have two embarked helos.

Mars Class Combat Stores Ship (T-AFS) 5 0 581 79 70 62 31,461 45

Sirius Class Combat Stores Ship (T-AFS) 3 0 524 72 64 67 25,140 45

Henry J. Kaiser Oilers (T-AO) 12 0 677 97 67** 73 51,222 50

Hayes Class Acoustic Research Ship (T-AG) 1 0 256.5 75 15,005 45

Mission Class Navigation Research Ship (T-AG) 1 0 595 75 34,808 45

Observation Is. Class (T-AGM) 1 0 563 76 33,375 45

Stalwart Class Ocean Surveillance Ship (T-AGOS) 5 0 224 43 7,513 60

Victorious Class Ocean Surveillance Ships (T-AGOS) 4 0 234.5 93.6 20** 20 21,949 120

Silas Bent Class Surveying Ships (T-AGS) 2 0 285.3 48 10,682 45

Waters Class Surveying Ship (T-AGS) 1 0 455 68.9 24,453 45

McDonnell Class Surveying Ships (T-AGS) 2 0 208 45 7,301 45

Pathfinder Surveying Ships (T-AGS) 4 1 328.5 58 14,861 45

Mercy Class Hospital Ships (T-AH) 2 0 894 105.6 80** 80 73,637 365

Maersk Class Strategic Sealift Ships (T-AKR) 3 0 946 106 80** 80 78,215 320

Gordon Class Strategic Sealift Ships (T-AKR) 2 1 956 106 80** 80 79,042 320

Algol Class Fast Sealift Ships (T-AKR) 8 0 946.2 106 81** 84 78,232 320

Zeus Class Cable Repairing Ship (T-ARC) 1 0 502.5 73 28,612 45

Powhatan Class Fleet Ocean Tugs (T-ATF) 7 0 240.2 42 25** 20 7,869 120

USCG

Hamilton Class High Endurance Cutters (WHEC) 12 0 378 42 50 35 10,633 154

Famous Class Medium Endurance Cutters (WMEC) 4 0 270 38 40 30 6,803 139

Famous Class Medium Endurance Cutters (WMEC) 9 0 270 38 40 30 6,803 166

Reliance Class Medium Endurance Cutters (WMEC) 5 0 210.5 34 48** 30 5,582 238

Reliance Class Medium Endurance Cutters (WMEC) 11 0 210.5 34 48** 30 5,582 151

Polar Class Icebreaker (WAGB) 2 0 399 86 65 82 21,435 365

Bay Class Tugs (WTGB) 9 0 140 37.6 4,106 365

Point Class Patrol Craft (WPB) 36 0 83 17.2 1,114 320

Island Class Patrol Boats (WPB) 49 0 110 21 1,802 320

Juniper Class Seagoing Buoy Tender (WLB) 2 1 225 46 8,073 287

Balsam Class Buoy Tenders (WLB) 23 0 180 37 5,195 295

Keeper Class Buoy Tenders (WLM) 2 12 175 36 4,914 227

Red Class Buoy Tenders (WLM) 9 157 33 4,041 227

White Sumac Class Buoy Tenders (WLM) 4 133 31 3,216 227

Inland Buoy Tenders (WLI) 2 100 24 1,872 365

Inland Buoy Tenders (WLI) 4 65 17 862 365

River Buoy Tenders, 65 ft (WLR) 6 65 22 1,115 365

River Buoy Tenders, 75 ft (WLR) 13 75 22 1,287 365
Table 1. Listing of Ships and Vessels for Deck Runoff

Navy, MSC, USCG and Army

Homeported Additional Ship Dimensions Helo Pad Dimensions Weather Days

Vessel Category In U.S.* Projected Length Beam Length Width Deck Area within 12 n.m.

(ft) (ft) (ft) (ft) (sq ft)

* Where ships of this class are homeported in foreign ports, their number appears in parentheses, e.g., 8 (2) indicates 8 ships in the class, 2 homeported overseas, therefore only six are

 considered in calculating the deck runoff in that class.

** Denotes ships which do not embark helicopters as part of their normal complement, so helocopter flight deck area is included in weather deck area

*** DDG 51-78 do not have helos embarked; DDG 79 and Follow will have two embarked helos.

River Buoy Tenders, 115 ft (WLR) 1 115 30 2,691 365

Pamlico Class Construction Tenders (WLIC) 4 160.9 30 3,765 365

Cosmos Class Construction Tenders (WLIC) 3 100 24 1,872 365

Anvil/Clamp Class Construction Tenders (WLIC) 9 75 22 1,287 365

Harbor Tugs (WYTL) 11 65 19 963 365

Motor Lifeboats 26 94 47.9 14 523 365

Misc. Rescue and Utility Craft 1400+ Various Sizes 365

Army Vessels

Frank Besson Class Logistic Support Ship (LSV) 6 272.8 60 6,547 183

Mechanized Landing Craft (LCM 8) 104 73.7 21 511 320

Utility Landing Craft (LCU 2000) 34 174 42 2,412 320

Utility Landing Craft (LCU 1600) 14 135 29 1,292 320

Lighter Amphibious Resupply, Cargo (LARC) 23 35 8 92 365

Large Tug (LT 128) 10 128 36 3,594 320

Large Tug (LT 100) 15 107 26.5 2,212 320

Barge Derrick, 115T (BD) 5 175 75 13,125 365

Barge Derrick, 89T (BD) 7 140 70 9,800 365

Barge Cargo (BC) 3 110 32 3,520 365
Table 2. Estimate of Annual Weather Deck Runoff From Precipitation

Navy Surface Ships, By Port

Ship Class Home Port:

Bremerton, 

WA Everett, WA Ingleside, TX

Little Creek, 

VA Mayport, FL

Average Annual Rainfall (in): 50 31 30 45 52

Weather Deck Area 

(sq ft)

Days within 12 

n.m. No. Ships No. Ships No. Ships No. Ships No. Ships

Virginia Class Cruisers (CGN 38) 28,747 164 1

California Class Cruisers (CGN 36) 28,358 146 1

Ticonderoga Class Cruisers (CG 47) 22,164 169 5

Kidd Class Destroyers (DDG 993) 24,166 104 2

Arleigh Burke Class Destroyers (DDG 51) 26,326 178 2

Spruance Class Destroyers (DD 963) 22,021 181 2 6

Oliver Hazard Perry Class Frigates (FFG 7) 13,676 170 3 10

Blue Ridge Class Command Ships (LCC 19) 53,569 181

Austin Class Transport Docks (LPD 4) 44,460 181

Austin Class Transport Docks (LPD 7) 44,460 191

Austin Class Transport Docks (LPD 14) 44,460 195

Whidbey Class Dock Landing Ships (LSD 41) 39,934 171 4

Harpers Ferry Class Dock Landing Ships (LSD 49) 39,934 216 2

Anchorage Class Dock Landing Ships (LSD 36) 36,252 218 2

Newport Class Tank Landing Ships (LST 1179) 28,314 183 1

Avenger Class Mine Countermeasures Ship (MCM 1) 6,814 239 12

Osprey Class Coastal Minehunters (MHC 51) 5,264 239 9

Cyclone Class Patrol Ships (PC 1) 3,308 110 9

Austin Class Command Ship (AGF 11) 29,250 186

Safeguard Class Salvage Ships (ARS 50) 10,144 214 2

Emory S Land Class Submarine Tenders (AS 39) 42,684 295

Estimated Surface Runoff, (gal/yr): 756,138 1,057,434 1,581,483 5,623,465 6,684,183
Table 2. Estimate of Annual Weather Deck Runoff From Precipitation

Navy Surface Ships, By Port

Ship Class Home Port:

Average Annual Rainfall (in):

Weather Deck Area 

(sq ft)

Days within 12 

n.m.

Virginia Class Cruisers (CGN 38) 28,747 164

California Class Cruisers (CGN 36) 28,358 146

Ticonderoga Class Cruisers (CG 47) 22,164 169

Kidd Class Destroyers (DDG 993) 24,166 104

Arleigh Burke Class Destroyers (DDG 51) 26,326 178

Spruance Class Destroyers (DD 963) 22,021 181

Oliver Hazard Perry Class Frigates (FFG 7) 13,676 170

Blue Ridge Class Command Ships (LCC 19) 53,569 181

Austin Class Transport Docks (LPD 4) 44,460 181

Austin Class Transport Docks (LPD 7) 44,460 191

Austin Class Transport Docks (LPD 14) 44,460 195

Whidbey Class Dock Landing Ships (LSD 41) 39,934 171

Harpers Ferry Class Dock Landing Ships (LSD 49) 39,934 216

Anchorage Class Dock Landing Ships (LSD 36) 36,252 218

Newport Class Tank Landing Ships (LST 1179) 28,314 183

Avenger Class Mine Countermeasures Ship (MCM 1) 6,814 239

Osprey Class Coastal Minehunters (MHC 51) 5,264 239

Cyclone Class Patrol Ships (PC 1) 3,308 110

Austin Class Command Ship (AGF 11) 29,250 186

Safeguard Class Salvage Ships (ARS 50) 10,144 214

Emory S Land Class Submarine Tenders (AS 39) 42,684 295

Estimated Surface Runoff, (gal/yr):

Norfolk, VA Pearl Hr, HI

Pascagoula, 

MS San Diego, CA

45 25 72 10

No. Ships No. Ships No. Ships No. Ships

1

7 3 2 8

2

7 2 5

9 4 6

12 2 2 12

1

1 2

1 1

2

3

1

3

1

4

1

2

1 1

14,458,310 2,165,816 1,492,969 3,451,692

Estimated Total, All Ports (gal/yr): 37,271,490
Table 3. Estimate of Annual Weather Deck Runoff From Precipitation

MSC, Army and USCG Surface Ships

Average Annual Rainfall (in): 40

Weather Deck 

Area

Days 

within

Number of 

Vessels

Estimated 

Runoff, (gal):

Vessel Category (sq ft) 12 n.m.

Military Sealift Command

Kilauea Class Ammunition Ships (T-AE) 31,494 45 8 774,534

Mars Class Combat Stores Ship (T-AFS) 31,461 45 5 483,587

Sirius Class Combat Stores Ship (T-AFS) 25,140 45 3 231,853

Henry J. Kaiser Oilers (T-AO) 51,222 50 12 2,099,533

Hayes Class Acoustic Research Ship (T-AG) 15,005 45 1 46,129

Mission Class Navigation Research Ship (T-AG) 34,808 45 1 107,004

Observation Is. Class (T-AGM) 33,375 45 1 102,600

Stalwart Class Ocean Surveillance Ship (T-AGOS) 7,513 60 5 153,975

Victorious Class Ocean Surveillance Ships (T-AGOS) 21,949 120 4 719,741

Silas Bent Class Surveying Ships (T-AGS) 10,682 45 2 65,674

Waters Class Surveying Ship (T-AGS) 24,453 45 1 75,172

McDonnell Class Surveying Ships (T-AGS) 7,301 45 2 44,888

Pathfinder Surveying Ships (T-AGS) 14,861 45 4 182,746

Mercy Class Hospital Ships (T-AH) 73,637 365 2 3,672,277

Maersk Class Strategic Sealift Ships (T-AKR) 78,215 320 3 5,129,551

Gordon Class Strategic Sealift Ships (T-AKR) 79,042 320 2 3,455,850

Algol Class Fast Sealift Ships (T-AKR) 78,232 320 8 13,681,694

Zeus Class Cable Repairing Ship (T-ARC) 28,612 45 1 87,959

Powhatan Class Fleet Ocean Tugs (T-ATF) 7,869 120 7 451,557

USCG

Hamilton Class High Endurance Cutters (WHEC) 10,633 154 12 1,342,412

Famous Class Medium Endurance Cutters (WMEC) 6,803 139 4 258,392

Famous Class Medium Endurance Cutters (WMEC) 6,803 166 9 694,312

Reliance Class Medium Endurance Cutters (WMEC) 5,582 238 5 453,826

Reliance Class Medium Endurance Cutters (WMEC) 5,582 151 11 633,449

Polar Class Icebreaker (WAGB) 21,435 365 2 1,068,959

Bay Class Tugs (WTGB) 4,106 365 9 921,430

Point Class Patrol Craft (WPB) 1,114 320 36 876,335

Island Class Patrol Boats (WPB) 1,802 320 49 1,930,053

Juniper Class Seagoing Buoy Tender (WLB) 8,073 287 2 316,565

Balsam Class Buoy Tenders (WLB) 5,195 295 23 2,407,882

Keeper Class Buoy Tenders (WLM) 4,914 227 2 152,408

Red Class Buoy Tenders (WLM) 4,041 227 9 564,018

White Sumac Class Buoy Tenders (WLM) 3,216 227 4 199,485

Inland Buoy Tenders (WLI) 1,872 365 2 93,357

Inland Buoy Tenders (WLI) 862 365 4 85,966

River Buoy Tenders, 65 ft (WLR) 1,115 365 6 166,875

River Buoy Tenders, 75 ft (WLR) 1,287 365 13 417,187

River Buoy Tenders, 115 ft (WLR) 2,691 365 1 67,100

Pamlico Class Construction Tenders (WLIC) 3,765 365 4 375,527

Cosmos Class Construction Tenders (WLIC) 1,872 365 3 140,035

Anvil/Clamp Class Construction Tenders (WLIC) 1,287 365 9 288,822

Harbor Tugs (WYTL) 963 365 11 264,219

Motor Lifeboats 523 365 26 339,110

Army

Frank Besson Class Logistic Support Ship (LSV) 6,547 183 6 491,105

Mechanized Landing Craft (LCM 8) 511 320 104 1,161,183

Utility Landing Craft (LCU 2000) 2,412 320 34 1,792,495

Utility Landing Craft (LCU 1600) 1,292 320 14 395,403

Lighter Amphibious Resupply, Cargo (LARC) 92 365 23 52,992

Large Tug (LT 128) 3,594 320 10 785,730

Large Tug (LT 100) 2,212 320 15 725,240

Barge Derrick, 115T (BC) 13,125 365 5 1,636,359

Barge Derrick, 89T (BD) 9,800 365 7 1,710,541

Barge Cargo (BC) 3,520 365 3 263,314

Estimated Total Annual Runoff (gals): 54,638,410
Table 4. Estimate of Annual CV/CVN Flight Deck Runoff From Precipitation

Homeport CV/CVN Flt Estimated Avg. Annual Estimated

Deck Area Days within Precip. (in) Annual

(sq.ft.) 12 n.m. Runoff (gal)

Bremerton, WA:

USS Carl Vinson (CVN 70) 230,000 149 50 2,926,455

USS Nimitz (CVN 68) 230,000 149 50 2,926,455

Everett, WA:

USS Abraham Lincoln (CVN 72) 230,000 149 31 1,814,402

Mayport, FL:

USS John F. Kennedy (CV 67) 220,000 139 52 2,715,804

Norfolk, VA:

USS Dwight D. Eisenhower (CVN 69) 230,000 149 45 2,633,809

USS Enterprise (CVN 65) 230,000 78 45 1,378,773

USS George Washington (CVN 73) 230,000 149 45 2,633,809

USS John C. Stennis (CVN 74) 230,000 149 45 2,633,809

USS Theodore Roosevelt (CVN 71) 230,000 149 45 2,633,809

San Diego, CA:

USS Constellation (CV 64) 220,000 139 10 522,270

USS Kitty Hawk (CV 63) 220,000 139 10 522,270

Total Annual Gallons: 23,341,665

Table 5. Estimate of Annual Helicopter Flight Deck Runoff from Precipitation

Navy Amphibious Assault and MCM Support Ships

Home Port: Norfolk, VA San Diego, CA Ingleside, TX

Days No. Ships Avg. Ann. No. Ships Avg. Ann. No. Ships Avg. Ann.

Ship Class Flt Deck within Rain (in) Rain (in) Rain (in)

Area (sq ft) 12 n.m.

Wasp Class (LHD) 86,814 188 2 45 2 10 0 0

Tarawa Class (LHA) 92,800 175 2 45 2 10 0 0

Iwo Jima Class (LPH) 62,608 189 1 45 1 10 0 0

Iwo Jima Class (MCS) 62,608 320 0 45 0 10 1 30

Estimated Runoff, gal: 5,914,333 1,314,296 1,026,497

Total Amphibious Assault Ship Runoff: 7,228,629

Total Mine Countermeasure Runoff: 1,026,497

Total Runoff, gallons: 8,255,126
Table 6. Estimate of Annual Helicopter Flight Deck Runoff from Precipitation

Navy Surface Ships

Ship Class Home Port:

Bremerton 

WA Earle, NJ

Everett, 

WA

Mayport, 

FL Norfolk, VA

Pascagoula 

MS Pearl, HI

San Diego, 

CA

Avg.Annual Rainfall (in): 50 42 31 52 45 72 25 10

Navy Surface Ships: Flt Deck Days within No. Ships No. Ships No. Ships No. Ships No. Ships No. Ships No. Ships No. Ships

Area (sq ft) 12 n.m.

Ticonderoga Class Cruisers (CG) 2,160 169 5 7 2 3 8

Spruance Class Destroyers (DD) 2,184 181 2 6 9 4 6

Oliver Hazard Perry Class Frigates (FFG) 1,944 170 3 10 12 2 2 12

Austin Class Command Ships (AGF) 15,210 186 1

Sacramento Class Fst Combat Spt (AOE1) 5,893 186 2 2

Supply Class Fst Combat Spt (AOE6) 6,650 116 1 2

Annual Flight Deck Runoff (gals): 253,073 157,248 94,349 666,234 893,170 171,052 142,492 206,430

Total Annual Flight Deck Runoff (gals): 2,584,049
Table 7. Estimate of Annual Flight Deck Runoff From Precipitation

MSC and USCG Surface Ships

Estimated

No. Ships Flight Deck Avg Days U.S. Avg. Annual

Area (sq ft) within 12 n.m. An. Prec.(in) Runoff (gal)

Military Sealift Command

Kilauea Class Ammunition Ships (T-AE) 8 4,140 45 40 101,817

Mars Class Combat Stores Ship (T-AFS) 5 4,340 45 40 66,710

Sirius Class Combat Stores Ship (T-AFS) 3 4,288 45 40 39,546

Henry J. Kaiser Oilers (T-AO)* 12 0 50 40 0

Estimated Subtotal (gals/yr): 208,073

USCG

Hamilton Class High Endurance Cutters (WHEC) 12 1,750 154 40 220,931

Famous Class Medium Endurance Cutters (WMEC) 4 1,200 139 40 45,580

Famous Class Medium Endurance Cutters (WMEC) 9 1,200 166 40 122,475

Polar Class Icebreaker (WAGB) 2 5,330 365 40 265,807

Estimated Subtotal (gals/yr): 654,793

Estimated Total (gal/yr): 862,866

* Denotes ships having helicopter flight decks but do not embark helicopters as part of their normal complement. Flight deck area included in deck area listed in Table 1.

Table 8. Estimate of Annual Helicopter Flight Deck Runoff From Washdowns

 USCG Surface Ships

Ship Class Flt Deck Volume (gals/wash) No. Ships In Port

Area (sq ft) Cleaner Rinseate Total U.S. Ports Washdowns Totals

Hamilton Class High Endurance Cutters (WHEC) 1,750 18 72 90 12 22 23,760

Famous Class Medium Endurance Cutters (WMEC) 1,200 12 48 60 4 20 4,800

Famous Class Medium Endurance Cutters (WMEC) 1,200 12 48 60 9 24 12,960

Polar Class Icebreaker (WAGB) 5,330 54 216 270 2 52 28,080

Estimated Total (gals/yr): 69,600

* Assumes flight deck washed as a result of visiting helicopter operations.
Table 9a. Estimate of Annual Weather Deck Runoff From Precipitation

Oiler Weather Decks

U.S. Home Port: Bremerton Earle Norfolk Pearl Harbor

WA NJ VA HI

Average Annual Rainfall (in): 50 42 45 25

Ship Class Deck Area Days within 12 n.m. No. Ships No. Ships No. Ships No. Ships

Jumboised Cimarron Class Oilers (AO) 48,666 191 3 2

Sacramento Class Fast Combat Support Ships (AOE 1) 60,291 186 2 2

Supply Class Fast Combat Support Ships (AOE 6) 56,279 116 1 1 1

Henry J Kaiser Class Oilers (TAO187)* 0 50

Estimated Runoff, (gal): 2,472,708 2,077,075 2,644,856 793,749

* See Tables 1 and 3 Estimated Annual Total, All Ports (gal): 7,988,388

Table 9b. Estimate of Annual Weather Deck Runoff From Precipitation

Navy Auxiliary Service Craft Oilers

Service Craft Category Deck Area (sq ft)

Days within 12 

n.m. No. Ships

U.S. Avg. An. 

Rainfall (in)

Estimated 

Annual 

Runoff (gal)

Fuel Oil Barge, Nonself Propelled (YON) 6,600 365 40 40 6,582,840

Fuel Gasoline Barge, Nonself Propelled (YOGN) 6,600 365 9 40 1,481,139

Fuel Oil Storage Barge (YOS) 6,600 365 5 40 822,855

Estimated Annual Total (gal): 8,886,834
Table 10. Summary of Annual Runoff Estimates

Weather Deck Runoff from Precipitation

Totals

(gal/yr)

Navy Surface Ships 37,271,490

MSC, Army, and USCG Surface Ships 54,638,410

Navy Oilers 7,988,388

Navy Service Craft, Oilers 8,886,834

Flight Deck Runoff from Precipitation

Navy Aircraft Carriers 23,341,665

Navy Amphibious Assault Ships 7,228,629

Navy Mine Countermeasure Support Ship 1,026,497

Navy Surface Ships 2,584,049

MSC and USCG Surface Ships 862,866

Flight Deck Runoff from Freshwater Washdowns

USCG Surface Ships 69,600

Estimated Annual Total (gal/yr) 143,898,427
Table 11. Laboratory Results, Catapult Trough Drains Aqueous Phase Discharge*

Constituent Sample Results (mg/L)

Date: 4/13/94 4/14/94

Phenols 4.6 5.3

Oil and grease 9,683 13,919

Silver <0.050 <0.050

Cadmium 0.155 0.141

Chromium 0.l03 0.088

Copper <0.050 <0.050

Nickel 1.90 1.81

Lead 26.1 76.3

Zinc <0.050 <0.050

Source: NNS Laboratory Services, 199428

* Data represent concentrations prior to processing through an oil water separator.
Table 12. Comparison of Catapult Trough Drains Discharge to

Water Quality Criteria27

Constituent Sample Results (mg/L) Federal Acute WQC (mg/L) Most Stringent State Acute WQC

Date: 4/13/94 4/14/94 (mg/L)

Phenols 4.6 5.3 none 0.17 (HI)

Oil and grease 9,683 13,919 Visible sheen 1/1525 (FL)

Silver <0.050 <0.050 0.0019 0.0012 (WA)

Cadmium 0.155 0.141 0.042 0.0093 (FL, GA)

Chromium 0.103 0.088 1.1 0.05 (FL, GA)

Copper <0.050 <0.050 0.0024 0.0025 (WA)

Lead 26.1 76.3 0.210 0.0056 (FL, GA)

Nickel 1.90 1.81 0.074 0.0083 (FL, GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

FL = Florida

GA = Georgia

HI = Hawaii

WA = Washington

1. The Federal Pollution Control Act, 40CFR110, defines a prohibited discharge of oil as any discharge sufficient to

cause a sheen on the receiving waters.

2. International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 is

implemented by the Act to Prevent Pollution From Ships (APPS).

Table 13. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Dirty Ballast

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Dirty Ballast
Dirty Ballast

2

2.0 DISCHARGE DESCRIPTION

This section describes the dirty ballast discharge and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Dirty ballast is created when seawater is pumped into fuel tanks for the purpose of

improving ship stability. Ballast is weight added to a vessel to move the center of gravity to a

position that increases the vessel's stability. Ballast is normally placed low within a vessel's hull

to lower the center of gravity. Permanent ballast is usually heavy solid material, such as lead.

Temporary ballast is normally seawater, which is pumped in and out of tanks in the vessel.

Dirty ballast systems are different from compensated ballast and clean ballast systems.

Compensated ballast systems continuously replace fuel with water in a system of tanks as fuel is

consumed. Clean (or segregated) ballast systems have tanks that only carry ballast water;

therefore, the ballast water does not mix with fuel. These systems are covered in other NOD

reports. In a dirty ballast system, water is added to a fuel tank after most of the fuel is used.

Some fuel remaining in the tank mixes with the ballast water, producing "dirty" ballast.

Most classes of Armed Forces vessels use segregated tanks as the primary ballast system

and use dirty ballast systems only in extraordinary or emergency situations. Some vessel classes,

however, are not provided with clean ballast systems. These vessels regularly use dirty ballast

systems and discharge overboard, using oil content monitors (OCM) and oil water separators

(OWS) to avoid discharging oil at concentrations greater than regulatory limits.1 Using fuel

tanks for ballast water degrades fuel quality and is therefore avoided whenever possible.

As a vessel consumes fuel, air displaces the fuel in its fuel tanks, thus reducing the

vessel’s stability. There is an added detrimental effect to stability when a tank is partially full

and the liquid inside can slosh around. The degree to which these factors affect ship stability are

dependent on ship design and the sea state. Some classes of ships are more susceptible to

stability problems than others and certain locations have historically high wave action. When

ship stability is threatened, ballast water can be pumped into a fuel tank to replace the consumed

fuel and to regain stability. Ballast water is discharged when it is no longer needed for

operational reasons or when preparing for fuel reintroduction.

To maintain safe stability, vessels without clean ballast systems may begin ballasting fuel

tanks when remaining ship’s fuel drops to approximately 70-80% of total capacity. These

vessels may continue to ballast fuel tanks until approximately 20% of ship’s fuel capacity

remains (the minimum percentage allowed by U.S. Coast Guard (USCG) ships).1 Therefore, by

the end of a voyage, as much as 80% of the fuel tanks’ contents could be seawater.

Procedures have been established for both ballasting and deballasting to minimize the

concentration of fuel in the dirty ballast. To prepare a fuel tank for ballast, most of the remaining
Dirty Ballast

3

fuel is pumped to another fuel tank. The small quantities of fuel not removed in this first step is

transferred to a waste oil tank. When deballasting, most of the dirty ballast is pumped overboard,

while being monitored by an OCM, which measures the concentration of oil (fuel) in the water.

If the OCM detects oil concentrations in excess of the 15 parts per million (ppm), an alarm

sounds and the overboard discharge is stopped. The remaining dirty ballast is then processed

through an OWS to reduce the oil concentration to 15 ppm or below, as measured by another

OCM. The processed seawater is discharged overboard and the separated oil (fuel) is retained in

a waste oil tank for pierside disposal.

2.2 Releases to the Environment

Dirty ballast is water which may contain residual fuel and other constituents as a result of

sea water being stored in fuel tanks. Dirty ballast is discharged to the environment after being

processed through OCMs and/or OWS systems that ensure the ballast water fuel/oil

concentrations are below Federal standards. The discharge is infrequent and occurs just above

the waterline of the ship. The possible sources of the constituents of dirty ballast are seawater,

fuel remaining in the tank, fuel additives, materials used in the ballast system, and the zinc

anodes in the fuel tanks.

2.3 Vessels Producing the Discharge

Three USCG vessel classes use dirty ballast systems. Ships of the WHEC 378 Class (12

ships), WMEC 210 (16 ships), and the WAGB 399 Class icebreakers (2 ships) use their fuel

tanks for ballasting in accordance with published Coast Guard directives and as conditions

dictate.

In an emergency, all vessels of the Armed Forces with fuel tanks have the capability to

generate emergency dirty ballast. Generation of emergency dirty ballast on Navy, MSC, Army,

Air Force, Marine Corps, and the remainder of the USCG vessels occurs only when the vessels’

clean or compensated ballast systems are insufficient to maintain proper stability during

extraordinary or emergency circumstances. Emergency dirty ballast is not considered a discharge

under UNDS, and is not addressed in this report.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Two of the three USCG ship classes (WHEC 378 and WAGB 399) that use dirty ballast

systems operate beyond 12 nautical miles (n.m.) of land and only transit through 12 n.m. of land
Dirty Ballast

4

entering and leaving port. These ships may deballast within 12 n.m. of land using their OCM and

OWS systems however this is rarely done. The third class of ship that uses a dirty ballast system

is the USCG’s WMEC 210. These ships are located in several ports on the East, Gulf and West

Coasts. They may conduct normal operations within 12 n.m. of land on these Coasts, and

therefore may ballast and deballast within 12 n.m. of land. These vessels also deballast using

their OCM and OWS systems.

The policy for MSC and Navy vessels, and the practice of USCG vessels, is to discharge

dirty ballast beyond 12 n.m. of shore, or to hold the dirty ballast until it can be transferred to a

shore facility or containment barge.2,3

3.2 Rate

A survey found that few cutters routinely use dirty ballast within 12 n.m. even though

USCG policy permits discharge within this area if using an OWS and OCM.4 The limited

number of ballasting operations were insufficient to estimate the annual volume of dirty ballast

discharged. Therefore, for cutter class vessels, fuel capacities, and the maximum percentage of

these fuel tank capacities that are allowed by USCG policy for dirty ballasting, were used to

estimate the annual volume of dirty ballast discharged. This resulted in an overestimate of dirty

ballast discharge volumes for USCG vessels. Table 1 lists USCG vessel fuel capacities.

Using 80% of fuel capacities listed in Table 1 to estimate the deballasting discharge for

each deballasting event, WMEC 210 Class vessels could discharge approximately 41,800 gallons

of dirty ballast [(0.8)(52,236 gallons)]. The WAGB 399 Class ships could generate up to

1,080,000 gallons of dirty ballast and WHEC 378 Class ships could generate up to 166,400

gallons per deballasting event. The estimated maximum total annual discharge of dirty ballast

for the three classes of USCG ships is 21.6 million gallons, using the number of deballast events

per year from Table 2 and the following calculations. All of this discharge is assumed to occur

within 12 n.m. of shore and the results are believed by the USCG to be a gross overestimate of

the actual discharge. Of this 21.6 million gallons, two-thirds is from one class (WHEC 378)

which operates principally beyond 12 n.m.

The estimated maximum dirty ballast total annual discharge for WHEC 378 Class ships

is:

Total (gal/yr) = sum of [(0.8)(capacity)(# vessels)(# deballasting events)]

where,

Total = estimated maximum dirty ballast total annual discharge

0.8 = maximum percentage of fuel tank capacity allowed by USCG policy for

dirty ballast

capacity = fuel capacity in gallons

# vessels = number of vessels per class

# deballasting events = number of deballasting events per year
Dirty Ballast

5

(0.80) (208,000 gallons of fuel) (12 vessels in the class) (7 deballasting events per year)

 = approximately 14 million gallons per year.

The duration of USCG vessels’ dirty ballast discharge is estimated by considering

deballasting procedures and equipment characteristics. Based on operational experience,

approximately 75% of the dirty ballast can be discharged directly overboard while being

monitored through an OCM at an estimated flow rate of 250 gallons per minute (gpm).2 The

remaining 25% of ballast is required to be processed through an OWS, at a flow rate of 25 gpm.

Using a dirty ballast volume of 80% of vessel fuel capacity, an estimated flow rate of 250 gpm

for direct ballast overboard discharge, and 25 gpm through the OWS, the discharge duration is

summarized in Table 3. For example, the maximum time to deballast for WHEC 378 Class ships

is approximately 36 hours.

These values result in the maximum expected time to deballast since the calculations

assume the largest dirty ballast volume (the maximum allowed is 80% of the ship’s fuel capacity)

and ignore any processing of ballast through the OWS performed concurrently with the ballast

being discharged directly overboard. Also, it is unlikely that the entire duration of deballasting is

within 12 n.m. of shore, so the calculations overestimate the amount of dirty ballast discharged

within 12 n.m.

3.3 Constituents

Because process information and data on compensated fuel ballast, a similar discharge,

were sufficient to characterize this discharge, no sampling was performed on dirty ballast. The

constituent sources of dirty ballast are almost identical to the constituent sources in compensated

fuel ballast systems. Therefore, sampling performed for compensated fuel ballast discharge can

be used to predict the constituents in dirty ballast.

Soluble components of the fuel remaining in the tank mix with the seawater ballast

during extended contact while in the compensated fuel or dirty ballast tanks. The fuels will

normally be either Naval Distillate Fuel (NATO F-76) or Aviation Turbine Fuel (JP-5). In

addition, the USCG uses biocide fuel additives in their fuel tanks to control bacterial growth in

the fuel-water interface.5,6 All these sources can contribute to the concentrations reported as total

petroleum hydrocarbons and oil and grease. Specific fuel-based constituents can include

benzene, toluene, ethylbenzene, xylene, cresols, phenols, and polycyclic aromatic hydrocarbons.7

Materials used in fuel and ballast systems on the ships, which include copper, nickel, iron

and zinc, and the fuel or additives in the fuel such as biocides, can contribute to metal

concentrations in the discharge. Based on compensated ballast sampling, the metals in the

discharge can include copper, nickel, silver and zinc. The biocides used can contain naphtha and

dioxaborinane compounds.

The potential priority pollutants in dirty ballast discharge are 2-propenal, benzene,

toluene, ethylbenzene, phenol, copper, nickel, silver, thallium, and zinc. The only

bioaccumulator found in compensated ballast screening was mercury.
Dirty Ballast

6

3.4 Concentrations

Knowledge of dirty ballasting systems and practices and use of compensated fuel ballast

screening enables the characterization of dirty ballast discharge concentrations.

In support of the Compensated Ballast NOD report, a sampling effort was conducted

during a refueling evolution. The results of the sampling effort are applicable to this NOD report

because the same fuels are used in both compensated ballast and dirty ballast. Constituent

concentrations are based on compensated ballast with the exception of oil concentrations, which

are limited to 15 ppm by USCG practices and the use of OCMs and OWSs. The concentrations

of detected priority pollutants, oil and grease, and a bioaccumulator are shown in Table 4.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

An estimate of the maximum oil loading from dirty ballast for the three USCG vessel

classes was calculated by first estimating the greatest potential discharge volume and assuming

that the discharge contains the maximum allowable concentration of oil (15 ppm). In reality, the

concentration is expected to be somewhat lower than this, due to the preballasting and

deballasting procedures used by the USCG vessels, as described in Section 2.1. Using these

values with existing information on vessel operating profiles, an annual oil mass loading value

for each of the three USCG vessel classes was calculated.

The estimated maximum oil mass loading generated for each deballast event was

calculated using the equation:

Using this equation, the estimated maximum oil loading generated in each deballasting

event for WHEC 378 Class ships is:

(0.80)(208,000 gal)(3.785 L/gal)(15 mg/L)(10-6 kg/mg)(2.205 lb/kg) = approximately 21 lbs

Similarly, the WMEC 210 Class and the WAGB 399 Class would generate approximately

Estimated Maximum Oil Loading Generated by Deballasting Event in Pounds (lbs) =

[80% fuel capacity (gal)] (3.785 L/gal)(15 mg/L)(10-6 kg/mg)(2.205 lb/kg)
Dirty Ballast

7

5 and 135 pounds of fuel for each deballasting event, respectively.

The annual maximum oil mass loading per class was calculated using the equation:

Using this equation, the estimated maximum oil loading generated by deballasting per

year for WHEC 378 Class ships is:

(21 lbs per deballast) (12 vessels in class) (7 deballasting events per year) = 1,764 lbs/yr

Given the assumed maximum concentration of 15 ppm, the maximum total mass loading

for oil for all Coast Guard vessels is 2,704 pounds per year as shown in Table 2.

In a similar manner, the concentrations of each of the constituents shown in Table 4

(which are based on compensated ballast data for constituent concentrations) were used to

calculate the mass loadings shown in Table 5.

4.2 Environmental Concentrations

Dirty ballast water discharged from armed forces vessels is expected to be similar to the

compensated ballast discharge. In compensated ballast samples, copper, nickel, silver, and zinc

exceeded Federal and the most stringent state WQC, and ammonia, benzene, phosphorous,

thallium, total nitrogen, O&G, and 2-propenal concentrations exceeded the most stringent state

WQC.7 Table 4 is a summary of compensated ballast sample concentrations and applicable

WQC.

4.3 Potential for Introducing Non-Indigenous Species

There is no significant potential for introducing, transporting, or releasing non-indigenous

species with dirty ballast discharge. Navy and MSC policy requires that all dirty ballast be

discharged beyond 50 n.m., and those USCG vessels with a combination of clean and dirty

ballast systems also follow that practice.2,3 The potential is mitigated by the fact that the three

classes of USCG vessels with exclusively dirty ballast systems do not take on ballast while in

port and normally ballast and deballast beyond 12 n.m., where they are less likely to take on nonindigenous species. In addition, the USCG has a policy that states if a cutter does ballast within

12 n.m. of land, a full-tank ballast exchange should be conducted twice while in open waters

beyond 12 n.m., otherwise, hold the ballast and discharge it on the next voyage beyond 12 n.m.

Estimated Maximum Oil Loading Generated by Deballasting (lbs/yr) =

(discharge amt. per event (lbs))(# vessels)(# deballasts/year)

where,

discharge amt. = pounds of oil per deballasting event

# vessels = number of vessels in class

# deballasts/year = number of deballasting events per year
Dirty Ballast

8

Dirty ballast could also be discharged to a shore facility for processing. Most USCG vessels

deballast prior to returning to port, at greater than 12 n.m. from shore.

5.0 CONCLUSIONS

Uncontrolled, dirty ballast has the potential to cause an adverse environmental effect

because:

1) oil can be discharged in significant amounts above water quality criteria, and

2) oil in the discharge can also create a sheen that diminishes the appearance on surface

waters.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 6

lists data sources for this NOD report.

Specific References

1. LT. Aivalotis, Joyce, USCG, April 15, 1997, to File.

2. UNDS Equipment Expert Meeting Minutes, Dirty Ballast, August 2, 1996.

3. Department of the Navy. Environmental and Natural Resources Programs Manual,

OPNAVINST 5090.1B, Chapter 19-10, November 1994.

4. Department of the Navy. Carderock Division, Naval Surface Warfare Center. Summary

of Dirty Ballast Questionnaire Responses for the Uniform National Discharge Standards

(UNDS) Program. NSWCCD-TM-63-98/48. March 1998.

5. Military Specification MIL-S-53021A, Stabilizer Additive, Diesel Fuel, August 15, 1988.

6. LT Aivalotis, Joyce, USCG, Dirty Ballast Reply, 20 May, 1997.

7. UNDS Phase 1 Sampling Data Report, Volumes 1-13, October 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Dirty Ballast

9

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Dirty Ballast

10

Table 1. USCG Vessel Fuel Capacity and Consumption Data 8

Vessel Class WMEC 210 WHEC 378 WAGB 399

Fuel Capacity (100%) (gal):

 F-76 (diesel) 52,236 208,000 1,349,920

Table 2. Maximum Annual Oil Mass Loading Estimate for USCG Vessels

Vessel Class No. of Vessels Oil per Deballast

Event (lb)

Deballast Events

per Year

Maximum Oil

Discharged (lbs/yr)A

WMEC 210 16 5 5 400

WHEC 378 12 21 7 1764

WAGB 399 2 135 2 540

Notes: Total: 2,704 lbs/yr

A - based on maximum allowable OWS system discharge concentration limit (15 ppm),

Table 3. USCG Vessel Dirty Ballast Discharge Duration

Vessel Class WMEC 210 WHEC 378 WAGB 399

Amount to Deballast (gal)A41,800 166,400 1,080,000

Direct Discharge (gal) 31,400 124,800 810,000

Direct Discharge (gpm) 250 250 250

Direct Discharge (hours) 2.1 8.3 54

OWS Processing (gal) 10,500 41,600 270,000

OWS Processing (gpm) 25 25 25

OWS Processing (hours) 7.0 27.7 180

Total Ballast Discharge Time (hours)B9.1 36 234

Notes:

A - Amount to deballast is 80% of F-76 fuel capacity.

B - Time estimates are maximum values per deballast event, based on maximum ballast volumes and moderate direct

discharge flow rates.
Dirty Ballast

11

Table 4. Estimated Dirty Ballast Constituent Concentrations that Exceed Federal and/or

Most Stringent State Water Quality Criteria Based on Compensated Ballast Sampling

Measurements

Constituent

Maximum Dirty Ballast

Concentration (μg/L)

Federal Acute WQC

(μg/L)

Most Stringent State

Acute WQC (μg/L)

Ammonia as

Nitrogen

300 none 6 (HI)A

Benzene 153 none 71.28 (FL)

2-Propenal 203 none 18 (HI)

Total Nitrogen 580 none 200 (HI)A

Total Phosphorous 340 none 25 (HI)A

Copper 86 2.4 2.4 (CT, MS)

MercuryB0.00083 1.8 0.025 (FL, GA)

Nickel 267 74 8.3 (FL, GA)

Silver 5.7 1.9 1.9 (CA, MS)

Thallium 10.8 none 6.3 (FL)

Zinc 4845 90 84.6 (WA)

Oil & Grease 15000 visible sheenC

/15,000D

5000 (FL)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Mercury was not found in excess of WQC; concentration is shown only because it is a bioaccumulator.

C - Discharge of Oil. 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen

on receiving waters.

D - International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as

implemented by the Act to Prevent Pollution from Ships (APPS).

CA= California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Dirty Ballast

12

Table 5. Estimated Maximum Annual Mass Loadings for Dirty Ballast Constituents that

Exceed Water Quality Criteria

Constituent Annual Mass Loading (lb/yr)

AmmoniaA54.2

BenzeneA27.6

PhosphorousA61.4

Total Nitrogen 105

2-Propenal 36.6

CopperA15.5

NickelA48.1

SilverA1.0

Thallium 1.95

ZincA872.1

MercuryA,B 0.00015

Oil & GreaseC2704

Notes:

A - Based on constituent concentrations found in compensated ballast water

B - Mercury was not found in excess of WQC; mass loading is shown only because it is a bioaccumulator.

C - Oil and Grease mass loading based on maximum allowable OWS system discharge concentration limit (15

ppm), not on compensated ballast sampling results.

80% of the ship’s fuel capacity is always used for ballast anytime a ship takes on ballast water.
Dirty Ballast

13

Table 6. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

Data Call Responses X

2.2 Releases to the Environment Data Call Responses X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality Data Call Responses X

3.2 Rate Data Call Responses X

3.3 Constituents Data Call Responses X X

3.4 Concentrations Data Call Responses X X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Distillation and Reverse Osmosis Brine

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Distillation and Reverse Osmosis Brine
Distillation and Reverse Osmosis Brine

2

2.0 DISCHARGE DESCRIPTION

This section describes the distillation and reverse osmosis (RO) brine discharge and it

includes information on: the equipment that is used and its operation (Section 2.1), general

description of the constituents of the discharge (Section 2.2), and the vessels that produce this

discharge (Section 2.3).

2.1 Equipment Description and Operation

Distilling and RO plants, known as “water purification plants,” generate freshwater from

seawater for a variety of shipboard applications. These include potable water for drinking and

hotel services (e.g., sanitary, laundry, and food preparation) and high-purity feedwater for boilers.

Vessels with steam turbine propulsion plants are equipped with large boiler systems that require

significant amounts of high-purity feedwater for generating high-pressure steam to operate the

ship's engines. Vessels also need low-pressure steam for producing hot water and for heating.

2.1.1 Distilling Plants

Distilling plants, also known as evaporators, are used to distill freshwater from seawater.

Non-volatile seawater components, such as inorganic and organic solids (dissolved and

suspended), remain in the plant and become concentrated. The mixture of concentrated seawater

components that remain and the constituents leached from material in the plant is known as brine

and is discharged overboard.

There are two types of distilling plants used on Armed Forces vessels. One type uses

low-pressure steam as the heat source and generally operates under vacuum. Figure 1 is a

diagram of a two-stage flash-type distilling plant. The other type, vapor compression, uses a

compressor to "drive" the evaporation process. Both types produce similar brine discharges.

The heat that is essential to the distilling process is transmitted to the influent seawater

through one or more heat exchangers. The heat exchangers consist of a series of metal tubes or

plates enclosed in a metal casing. They are designed to segregate the heat source fluid (steam in

the case of distilling plants) from the fluid to which the heat is transmitted (influent seawater)

while providing as much thermal contact through the metal surfaces as possible. This is

accomplished by having a high density of tubes or plates.

Condensate, which is segregated from distillate and brine, is produced from the

generating steam when it is cooled by distilling plant heat transfer surfaces. The condensate can

be directed to a collection tank along with condensate from other heating devices (e.g.,

ventilation heaters) for reuse in the ship's boilers. The condensate that is not reused in the boilers

is a source of non-oily machinery wastewater, as discussed in the NOD report for that discharge.

During the distilling process, inorganic seawater constituents form a scale on the

distilling plant heat transfer surfaces. Anti-scaling compounds are continuously injected into the

influent seawater to control the scaling. Nevertheless, the surfaces will gradually foul from
Distillation and Reverse Osmosis Brine

3

scaling over extended periods and periodic cleaning is required to restore flow and heat transfer

efficiency.

Citric acid cleaning can be done at sea or in port. At-sea acid cleaning is done during

distillation by injecting the citric acid solution into the influent seawater. The citric acid reacts

with the distilling plant scale to form soluble byproducts that are discharged with the distilling

plant brine. Carbon dioxide is also given off by this reaction and is removed by the distilling

plant air ejector.

In-port citric acid cleaning is done every 5 to 7 years on Navy distilling plants. The

cleaning solution is recirculated between the distilling plant and a tank truck on the pier. The

spent cleaning solution is disposed at an off-site shore facility.1

2.1.2 RO Plants

RO plants separate freshwater from seawater by using semi-permeable membranes as a

physical barrier. The RO membrane retains a large percentage of suspended and dissolved

constituents, allowing freshwater to pass through. The retained substances become concentrated

into brine. Shipboard RO plants produce lower-purity freshwater than distilling plants, with total

dissolved solids (TDS) concentrations two orders of magnitude greater than distilling plant

distillate.

2

Because RO plants operate at ambient temperatures, scaling is not a concern. Therefore,

chemicals are not used in RO plants for either scaling suppression or cleaning.

2.2 Releases to the Environment

The overboard discharge from water purification plants on vessels is RO and distilling

plant brine. The brine primarily consists of seawater, but can also contain materials from the

purification plants and anti-scaling treatment chemicals. RO and distilling processes separate a

relatively small proportion of freshwater from the influent seawater, returning the slightly more

concentrated brine effluent to the sea. The discharged brine from distilling plants is at elevated

temperatures, typically 100 to 120 °F.

The citric acid cleaning solutions that are used to periodically clean the distilling plants

are either collected on-site after shoreside cleaning or discharged overboard beyond 12 n.m. after

at sea cleaning.

2.3 Vessels Producing the Discharge

There are currently 541 vessels of the Armed Forces equipped with water purification

plants. Four hundred fifty-seven vessels have distilling plants and the remainder have RO plants.

Table 1 provides a list of Navy, MSC, USCG, and Army vessels that produce this discharge.3
Distillation and Reverse Osmosis Brine

4

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

The distilling plant on a steam-propelled vessel can be operated any time the vessel’s

boilers are operating. MSC steam-propelled ships typically operate one distiller while in port,

except for ships on reduced operating status. As a result, discharge of brine from steampropelled vessels can occur in port, at sea, and while transiting to and from port. However,

diesel- and gas-turbine-propelled vessels with distilling plants, and all vessels with RO plants

seldom operate their water purification plants in port or while transiting coastal waters less than

12 nautical miles (n.m.) from shore.

For Navy vessels, brine discharge within 12 n.m. is from the production of boiler

feedwater. Navy vessels do not produce potable water within 12 n.m., except during extended

operations.

3.2 Rate

While the existing Navy fleet has water purification plants of many sizes and capacities,

current naval ship design practice is to use standardized water purification plants of two

capacities: 12,000-gallons per day (gpd) distilling and RO plants and 100,000-gpd distilling

plants. Multiple water purification plants will be used to achieve capacities of up to 450,000-

gpd. For example, a destroyer's RO system may include two 12,000-gpd plants, while the new

LPD 17 Class amphibious transport dock vessels require five 12,000-gpd plants to meet

freshwater demand. Aircraft carriers have multiple 100,000-gpd distilling plants.

The volume of brine discharged from water purification plants depends on the type of

plant. When operating, distilling plants are typically run at full capacity, even when the demand

for potable water is low. Excess distillate is discharged directly overboard. Based on operating

experience, distilling plants generate 17 gallons of brine for every gallon of fresh water. RO

plants generate 4 gallons of brine for every gallon of fresh water.3 These brine production factors

can be used to calculate the water purification plant brine flow rate in gallons per day:

A single distilling plant on a typical Navy DD 963 Class destroyer produces 8,000 gpd of

freshwater.4Therefore:

(8,000 gpd freshwater) (17) = 136,000 gpd brine discharge

Water Purification Plant Brine Flow Rate in gallons per day (gpd) =

(total freshwater flow in gpd) (brine production factor)
Distillation and Reverse Osmosis Brine

5

A single RO plant on a typical Navy MHC 51 coastal minehunter produces 1,600 gpd of

freshwater.3 Therefore:

(1,600 gpd freshwater) (4) = 6,400 gpd brine discharge

Current Navy vessel water purification plant operating practice is for steam-propelled

ships to operate one distilling plant in port for one to five days before departure (to fill boiler

feed water tanks) and while transiting through coastal waters less than (<) 12 n.m.). Submarines

are normally supplied boiler feed water by shore or a tender while in port. The distilling plants

on all these vessels can be operated at full capacity while at sea (greater than (>) 12 n.m.)).

Table 1 shows estimated distilling and RO plant brine discharge quantities for various

vessel classes. The estimates are based on available information regarding the number of vessels

in each class, type and capacity of water purification plant(s), vessel operating schedules (number

of transits and days in port per year), and water purification plant operating practices while in

port, in transit (<12 n.m.) and at sea (>12 n.m.). The assumptions and formulas used to calculate

the brine discharge estimates are summarized in the notes section of Table 1, and include four

hours per vessel transit in coastal waters. The assumptions also include operation of one

distilling plant to produce boiler feedwater for four hours prior to departure from port in the case

of submarines.3 Surface steam-powered vessels may operate a distilling plant for as much as

three days prior to departure from port (i.e., every second transit).

3,5 The calculation of the total

annual brine discharge within 12 n.m. of shore consists of an in-port component and a transit

component, which are added together. The formula for a Navy vessel class is:

A sample calculation for the LSD 36 Class dock landing ship is as follows:

(5 ships) (510,000 gal/day/ship) (26 transits/yr) ((3 days before each transit /2) +

 (4/24 day per transit)) = 111 million gals/yr

Table 1 lists the results of the above calculation for all vessels of the Armed Forces. A

total of approximately 2.47 billion gallons of distilling and RO plant brine discharges occur

annually within 12 n.m. from shore. Of this, approximately 1.84 billion gallons is discharged in

port and 620 million gallons is discharged in transit within 12 n.m. These calculations

overestimate the actual discharge rate because steam-powered surface ships can operate a

distilling plant for less than three days prior to leaving port.

The volume of influent seawater to a distilling plant can be estimated using the ratio of

brine produced to gallons of freshwater produced, or 17:1. This ratio indicates that for every 18

Annual Flow within 12 n.m. (gals/yr) =

(number of vessels in class) (single distiller brine flow in gal/day/vessel) (number of

distillers/vessel) (number of transits/yr) ((3 days before each transit/2 transits) +

(4 hours/transit X 1 day/24 hours))
Distillation and Reverse Osmosis Brine

6

gallons of seawater introduced into a distilling plant, 17 gallons of brine is produced. Knowing

that a total of approximately 2.47 billion gallons of distilling and RO plant brine discharges occur

annually within 12 n.m. of shore, the following calculation can be made to approximate the total

annual volume of seawater influent:

(18 gallons of seawater/17 gallons of brine) (2.47 billion gallons of brine)

= 2.62 billion gallons seawater

Therefore, the influent flow rate is approximately 2.62 billion gallons, and the effluent

flow rate is approximately 2.47 billion gallons

3.3 Constituents

The three sources of the constituents of water purification plant discharge are: 1) influent

seawater; 2) anti-scaling treatment chemicals; and 3) the purification plant components,

including heat exchangers, casings, pumps, piping and fittings. The primary constituents of the

brine discharge are identical to those in seawater. These include non-volatile dissolved and

suspended solids, and metals.

Distilling plants are made primarily of metal alloys that are corroded by seawater,

particularly at the elevated temperatures at which these plants operate. The metal alloys used for

heat transfer surfaces and other components include copper-nickel alloys, nickel/chromium

alloys, stainless steel, titanium, brass, and bronze. Based on the metallurgical composition of

these alloys, the corrosion process could be expected to introduce copper, chromium, nickel, and

zinc into the brine. The corrosion effect on the brine discharge metal loadings is less of a

concern for the RO plants, with non-metallic membranes and ambient seawater operating

temperatures.

The distilling plant anti-scaling compound used in Navy surface ships is Distiller Scale

Preventive Treatment Formulation. The military specification requires anti-scaling compound

products to contain organic polyelectrolytes such as polyacrylates, and an antifoaming agent in

aqueous solution.6 The polyelectrolyte chelates (ties-up) inorganic constituents (calcium,

magnesium, metals) to prevent them from depositing on equipment surfaces. Equipment supplier

material safety data sheets (MSDSs) indicate that the products contain about 10% to 20%

polyacrylate and low levels of antifoaming chemicals (e.g., one product contains 1%

polyethylene glycol). Ethylene oxide was identified on two of the MSDSs as potentially present

in trace amounts. One of the MSDSs also indicated that acrylic acid, acetaldehyde, and 1,4-

dioxane can also be present at trace levels.7

Distilling plant influent and effluent were sampled for materials that had a potential for

being in the discharge. An aircraft carrier, an amphibious assault ship, and a landing ship dock

were sampled.8

 Based on the brine generation process, system designs, and analytical data

available, analytes in the metals, organics, and classicals classes were tested. In addition, Bis(2-

ethylhexyl) phthalate, a semi-volatile organic compound, was specifically tested for, since it is

not covered in the three aforementioned analyte classes, but is a standard parameter in sampling
Distillation and Reverse Osmosis Brine

7

for semi-volatile constituents. The results of the sampling are provided in reference 8. Table 2

provides a list of all constituents and their concentrations that were detected in the discharge. In

terms of thermal effects, this discharge is expected to be warmer than ambient water

temperatures with a maximum overboard discharge temperature of 120 oF.

Priority pollutants that were detected included copper, iron, lead, nickel, and zinc; and the

semi-volatile organic compound bis(2-ethylhexyl) phthalate. No bioaccumulators were detected.

3.4 Concentrations

The concentrations of detected constituents are listed in Tables 2 and 3.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria.

Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

The water purification plant brine annual discharge flow rate (Section 3.2) and constituent

concentration data (Tables 2 and 3) were used to develop brine constituent effluent mass loading

estimates. Similarly, constituent influent mass loadings were found by using the seawater annual

flow rate (Section 3.2) and constituent concentration data (Tables 2 and 3).

The following general formula was used to determine influent mass loading and effluent

mass loading:

For instance, the estimated effluent mass loading for copper generated by distilling plant

brine discharge is:

(217.38 μg/L) (2.47 billion gal/yr) (3.7854 L/gal)) (2.2 lb/kg) (10-9 kg/μg) = 4471.48 lbs/yr

The estimated influent mass loading calculation for copper is:

(83.51 μg/L) (2.62 billion gal/yr) (3.7854 L/gal) (2.2 lb/kg) (10-9 kg/μg) = 1822.11 lbs/yr

Mass Loading (lbs/yr) =

(concentration in μg/L) (flow rate in gal/yr) (3.7854 L/gal) (2.2 lb/kg) (10-9 kg/μg)
Distillation and Reverse Osmosis Brine

8

The mass loading of the discharge was then determined by subtracting the influent mass

loading from the effluent mass loading for each constituent. Concentration values and mass

loadings are provided in Table 2. Log-normal average concentrations were used because the

sample data were assumed to approximate a log-normal distribution.

The mass loadings were calculated based upon flow from all distilling and RO plants and

assuming constituent concentrations in distiller and RO effluent are equal. Calculations using

this assumption are expected to overestimate mass loadings because constituent concentrations

will be lower in RO effluent because the operating temperature is lower, resulting in less

corrosion. Table 3 provides a water purification plant brine discharge mass loading summary.

4.2 Environmental Concentrations

Table 4 identifies distilling plant brine constituents that were detected at or above their

respective Federal or most stringent state water quality criteria (WQC). Copper and zinc

exceeded both Federal and most stringent state WQC. Nitrogen (as ammonia, nitrate/nitrite, and

total kjeldahl nitrogen), phosphorous, iron, lead, nickel, and zinc exceed the most stringent state

WQC.

4.3 Thermal Effects

The potential for distilling plant brine discharge to cause thermal environmental effects

was evaluated by modeling the thermal plume generated and then comparing it to plumes

representing state thermal discharge requirements. Thermal effects of distilling plant brine were

modeled using the Cornell Mixing Zone Expert System (CORMIX) to estimate the plume size

and temperature gradients in the receiving water body. The model was run under conditions that

would overestimate the size of the thermal plume (minimal wind, slack tide) for the largest

generator of distilling plant brine (aircraft carrier) and for a typical distillation brine generator

(cruiser). The plume characteristics were compared to thermal mixing zone criteria for Virginia

and Washington. Other coastal states require that thermal mixing zones be established on a caseby-case basis.

The Washington thermal regulations state that when natural conditions exceed 16 °C, no

temperature increases will be allowed that will raise the receiving water temperature by greater

than 0.3 °C. The mixing zone requirements state that mixing zones shall not extend for a

distance greater than 200 feet plus the depth of the water over the discharge point, or shall not

occupy greater than 25% of the width of the water body. The Virginia thermal regulations state

that any rise above natural temperature shall not exceed 3 °C. Virginia requires that the plume

shall not constitute more than one-half of the receiving watercourse, and shall not extend

downstream at any time a distance more than five times the width of the receiving of water body

at the point of discharge.

The aircraft carrier distilling plant brine flow rate was determined to be 24,083 gallons

per hour at a temperature of 104 °F while the cruiser flow parameters were 120 °F and 6,375

gallons per hour for temperature and flow rate, respectively. The ambient water temperature was
Distillation and Reverse Osmosis Brine

9

dependent upon location and varied between 40 and 60 °F. Both modeled discharges were

continuous and were assumed to emanate from a 6-inch diameter pipe located at the bottom of

the hulls. The results of this modeling are provided in Table 5.9

Some of the model parameter assumptions lead to a reduced amount of mixing within the

harbor. The assumptions are:

• wind velocity is at a minimum (1 m/s);

• the discharge will occur during a simulated slack tide event, using a minimum water

body velocity (0.03 m/s);

• the average depth of water at the pier is 40 feet.

Using the above parameters and assumptions, distilling plant brine discharges from

Armed Forces vessels do not exceed state thermal mixing zone criteria.

4.4 Potential for Introducing Non-Indigenous Species

The potential for introducing, transporting, or releasing non-indigenous species with this

discharge is low because the maximum retention time of water in these plants is short; therefore

the effluent is discharged in the same area from which the influent seawater is taken.

5.0 CONCLUSIONS

The discharge from vessel water purification plants has the potential to cause adverse

environmental effects because significant amounts of metals are discharged at concentrations

above WQC.

6.0 DATA SOURCES AND REFERENCES

Table 6 lists the data source of the information presented in each section of this NOD

report.

Specific References

1. Personal communication between Carl Geiling, Malcolm Pirnie, Inc., and Chief Luedtke,

USS Carter Hall (LSD 50), 23 January, 1997.

2. Aerni, Walter, NAVSEA. Elements Present in Water, 19 November 1997, Greg

Kirkbride, M. Rosenblatt & Son, Inc.

3. UNDS Equipment Expert Meeting Minutes - Evaporator Brine & Reverse Osmosis (RO)

Plant. August 27, 1996.
Distillation and Reverse Osmosis Brine

10

4. Aqua-Chem Marine, Inc. Marine Multi-Stage Flash Distilling Plants.

5. U.S. Navy. Commander, Naval Air Forces Pacific. Implementation of Uniform National

Discharge Standards. Letter to SEA 00T-E1, 17 December 1996.

6. Specification for Distiller Scale Preventive Treatment Formulations (Metric), DOD-D24577(2), 19 December, 1986.

7. Ashland Chemical Company. Material Safety Data Sheets - Ameroyal Evaporator

Treatment, January 5, 1996.

8. UNDS Phase 1 Sampling Data Report, Volumes 1-13, October 1997.

9. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed

Services. Versar, Inc. July 3, 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
Distillation and Reverse Osmosis Brine

11

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.

UNDS Ship Database, August 1, 1997.
Distillation and Reverse Osmosis Brine

12

Figure 1. Diagram of a Two Stage Flash-Type Distilling Plant 
Distillation and Reverse Osmosis Brine

13

Table 1. Water Purification Plant Discharge Summary

VESSEL CLASSIFICATION INFORMATION WATER PURIFICATION SYSTEM TRANSIT ANNUAL

TYPE TOTAL TOTAL INFORMATION BRINE WASTEWATER

NO. PRO- AND H20 BRINE DAYS DISCHARGE

CLASS ARMED CLASS OF PULSION NO. OF FLOW FLOW TRAN- IN (million gals/year)

ID NO. SVCE NAME VESSEL TYPE VESSELS SYSTEM PLANTS (gpd) (gpd) SITS PORT IN-PORT IN TRANSIT >12 n.m. TOTAL

AE 26 MSC Kilauea Ammunition Ship 5 Steam Distill / 2 32,000 544,000 8 26 35.4 1.8 918.5 955.6

AE 26 MSC Kilauea Ammunition Ship (ROS) 3 Steam Distill / 2 32,000 544,000 8 26 9.8 1.1 551.1 562.0

AFS 1 (1) MSC Mars Combat Store Ship (ROS) 1 Steam Distill / 2 24,000 408,000 14 148 4.3 0.5 87.6 92.3

AFS 1 (3,5,6,7) MSC Mars Combat Store Ship 4 Steam Distill / 2 32,000 544,000 14 148 161.0 2.5 467.1 630.7

AFS 8 MSC N/A Combat Store Ship 3 Steam Distill / 2 32,000 544,000 14 148 120.8 1.9 350.3 473.0

AG 194 MSC Vanguard Navigation Research Ship 1 Steam Distill / 1 16,000 272,000 20 151 41.1 0.9 57.3 99.3

AG 195 MSC Hayes Sound Trials Ship 1 Diesel RO 2 10,000 40,000 20 151 0 0 8.4 8.4

AGM 22 MSC Converted Haskell Missile Range Instrumentation Ship 1 Steam Distill / 2 24,000 408,000 8 133 27.1 0.3 94.1 121.5

AGOS 1 MSC Stalwart Ocean Surveillance Ship 5 Diesel Distill / 2 6,000 102,000 8 70 0 0 149.8 149.8

AGOS 19 MSC Victorious Ocean Surveillance Ship 4 Diesel Distill / 2 6,000 102,000 10 107 0 0 104.6 104.6

AGS 26 MSC Silas Bent and Wilkes Surveying Ship 2 Diesel Distill / 2 6,000 102,000 12 44 0 0 65.1 65.1

AGS 45 MSC Waters Surveying Ship 1 Diesel Distill/ 2 15,324 260,508 2 7 0 0 93.2 93.2

AGS 51 MSC John McDonnell Surveying Ship 1 Diesel RO/ 2 4,000 16,000 12 96 0 0 4.3 4.3

AGS 52 MSC John McDonnell Surveying Ship 1 Diesel RO/ 3 6,000 24,000 12 96 0 0 6.4 6.4

AGS 60 MSC Pathfinder Surveying Ship 4 Diesel RO/ 2 8,000 32,000 NA NA 0 0 0 NA

AH 19 MSC Mercy Hospital Ship (ROS) 2 Steam Distill/ 4 300,000 5,100,000 4 184 15.3 1.7 1839.4 1856.4

AKR 287 MSC Algol Vehicle Cargo Ship (ROS) 8 Steam NA NA NA 6 109 NA NA NA NA

AKR 295 MSC NA Vehicle Cargo Ship (ROS) 2 Diesel Distill/ 1 9,511 161,687 NA NA 0 0 NA NA

AKR 296 MSC NA Vehicle Cargo Ship (ROS) 1 Diesel Distill/ 4 8,200 139,400 NA NA 0 0 NA NA

ARC 7 MSC Zeus Cable Ship 1 Diesel Distill/ 2 18,000 306,000 4 8 0 0 109.0 109.0

AO 187 MSC Henry J. Kaiser Oiler 12 Diesel Distill 2 20,000 340,000 12 78 0 0 1162.8 1162.8

ATF 166 MSC Powhatan Fleet Ocean Tug 7 Diesel RO/ 1 2,000 8,000 32 127 0 0 13.0 13.0

AO 177 NAVY Jumboised Cimarron Oiler 5 Steam Distill/ 2 12,000 204,000 20 188 15.3 1.7 177.1 194.1

AOE 1 NAVY Sacramento Fast Combat Support Ship 1 Steam Distill/ 2 100,000 1,700,000 22 183 28.1 3.1 303.2 334.3

AOE 1 (2-4) NAVY Sacramento Fast Combat Support Ship 3 Steam Distill/ 2 80,000 1,360,000 22 183 67.3 7.5 727.6 802.4

AOE 6 NAVY Supply Fast Combat Support Ship 3 Gas Distill/ 2 60,000 1,020,000 12 114 0 0 761.9 761.9

ARS 50 NAVY Safeguard Salvage Ships 3 Diesel Distill/ 2 8,000 136,000 44 208 0 0 61.1 61.1

ARS 50 (ARS 52) NAVY Safeguard Salvage Ships 1 Diesel Distill/ 3 12,000 204,000 44 208 0 0 30.5 30.5

AS 33 NAVY Simon Lake Submarine Tender 1 Steam Distill/ 2 100,000 1,700,000 12 229 15.3 1.7 227.8 244.8
Distillation and Reverse Osmosis Brine

14

VESSEL CLASSIFICATION INFORMATION WATER PURIFICATION SYSTEM TRANSIT ANNUAL

TYPE TOTAL TOTAL INFORMATION BRINE WASTEWATER

NO. PRO- AND H20 BRINE DAYS DISCHARGE

CLASS ARMED CLASS OF PULSION NO. OF FLOW FLOW TRAN- IN (million gals/year)

ID NO. SVCE NAME VESSEL TYPE VESSELS SYSTEM PLANTS (gpd) (gpd) SITS PORT IN-PORT IN TRANSIT >12 n.m. TOTAL

AS 39 NAVY Emory S Land Submarine Tender 3 Steam Distill/ 2 100,000 1,700,000 12 293 45.9 5.1 357.0 408.0

CG 47 NAVY Ticonderoga Guided Missile Cruiser 27 Gas Distill/ 2 24,000 408,000 24 166 0 0 2126.1 2126.1

CGN 36 NAVY California Guided Missile Cruiser 2 Nuclear Distill/ 2 36,000 612,000 22 143 20.2 2.2 265.0 287.4

CGN 38 NAVY Virginia Guided Missile Cruiser 1 Nuclear Distill/ 2 36,000 612,000 22 143 10.1 1.1 132.5 143.7

CV 59 (CV 62) NAVY Forrestal Aircraft Carrier 1 Steam Distill/ 5 380,000 6,460,000 14 137 27.1 3.0 1450.3 1480.4

CV 63 NAVY Kitty Hawk Aircraft Carrier 1 Steam Distill/ 5 380,000 6,460,000 14 137 27.1 3.0 1450.3 1480.4

CV 63 (CV 64) NAVY Kitty Hawk Aircraft Carrier 1 Steam Distill/ 6 400,000 6,800,000 14 137 23.8 2.6 1526.6 1553.0

CVN 65 NAVY Enterprise Aircraft Carrier 1 Nuclear Distill/ 5 350,000 5,950,000 12 76 21.4 2.4 1701.7 1725.5

CV 67 NAVY Kennedy Aircraft Carrier 1 Steam Distill/ 5 450,000 7,650,000 14 137 32.1 3.6 1717.4 1753.1

CVN 68 NAVY Nimitz Aircraft Carrier 7 Nuclear Distill/ 4 400,000 6,800,000 14 147 249.9 27.8 10210.2 10487.9

DD 963 NAVY Spruance Destroyer (Typical) 27 Gas Distill/ 2 16,000 272,000 24 178 0 0 1329.3 1329.3

DD 963 NAVY Spruance Destroyer (DD 963 & DD 964) 2 Gas RO/ 2 24,000 96,000 24 178 0 0 34.8 34.8

DD 963 NAVY Spruance Destroyer (DD 992) 1 Gas Distill/RO 3 25,000 308,000 24 178 0 0 55.7 55.7

DD 997 NAVY Spruance Destroyer 1 Gas Distill/ 2 24,000 408,000 24 178 0 0 73.8 73.8

DDG 51 NAVY Arleigh Burke Guided Missile Destroyer 18 Gas RO/ 2 24,000 96,000 22 101 0 0 446.7 446.7

DDG 993 NAVY Kidd Guided Missile Destroyer 4 Gas Distill/ 2 20,000 340,000 24 175 0 0 250.2 250.2

FFG 7 NAVY Oliver Hazard Perry Guided Missile Frigate 43 Gas Distill/ 2 8,000 136,000 26 167 0 0 1119.9 1119.9

LCC 19 NAVY Blue Ridge Amphibious Command Ship 2 Steam Distill/ 2 100,000 1,700,000 16 179 40.8 4.5 618.8 664.1

LHA 1 NAVY Tarawa Amphibious Assault Ship 5 Steam Distill/ 2 140,000 2,380,000 18 173 160.7 17.9 2231.3 2409.8

LHD 1 NAVY Wasp Amphibious Assault Ship 4 Steam Distill/ 2 200,000 3,400,000 26 185 265.2 29.5 2359.6 2654.3

LPD 4 NAVY Austin Amphibious Transport Dock 3 Steam Distill/ 2 60,000 1,020,000 22 178 50.5 5.6 555.4 611.5

LPD 7 NAVY Austin Amphibious Transport Dock 3 Steam Distill/ 2 60,000 1,020,000 24 188 55.1 6.1 523.3 584.5

LPD 14 NAVY Austin Amphibious Transport Dock 2 Steam Distill/ 2 60,000 1,020,000 22 192 33.7 3.7 341.7 379.1

LPH 2 NAVY Iwo Jima Amphibious Assault Helicopter

Carrier

2 Steam Distill/ 2 100,000 1,700,000 22 186 56.1 6.2 589.9 652.2

LSD 36 NAVY Anchorage Dock Landing Ship 5 Steam Distill/ 2 60,000 1,020,000 26 215 99.5 11.1 731.9 835.4

LSD 41 NAVY Whidbey Island Dock Landing Ship 8 Diesel Distill/ 2 60,000 1,020,000 26 170 0 0 1538.2 1538.2

LSD 49 NAVY Harpers Ferry Dock Landing Ship 3 Diesel Distill/ 2 60,000 1,020,000 NA NA 0 0 NA NA

MCM 1 (1-10) NAVY Avenger Mine Countermeasure Vessel 10 Diesel Distill/ 2 4,000 68,000 56 232 0 0 80.9 80.9

MCM 1 (11-14) NAVY Avenger Mine Countermeasure Vessel 4 Diesel Distill/RO 2 6,000 76,000 56 232 0 0 36.2 36.2
Distillation and Reverse Osmosis Brine

15

VESSEL CLASSIFICATION INFORMATION WATER PURIFICATION SYSTEM TRANSIT ANNUAL

TYPE TOTAL TOTAL INFORMATIO

N

BRINE WASTEWATER

NO. PROP- AND H20 BRINE DAYS DISCHARGE

CLASS ARMED CLASS OF ULSION NO. OF FLOW FLOW TRAN- IN (million gals/year)

ID NO. SVCE NAME VESSEL TYPE VESSELS SYSTEM PLANTS (gpd) (gpd) SITS PORT IN-PORT IN TRANSIT >12 n.m. TOTAL

MHC 51 NAVY Osprey Coastal Minehunter Vessel 12 Diesel RO/ 1 1,600 6,400 56 232 0 0 9.1 9.1

MCS 12 NAVY Converted Iwo Jima MCM Support Ship 2 Steam Distill / 2 100,000 1,700,000 22 186 56.1 6.2 589.9 652.2

PC 1 NAVY Cyclone Coastal Defense Ship 13 Diesel RO/ 3 1,200 4,800 36 105 0 0 15.7 15.7

SSN 637 NAVY Sturgeon Submarine 13 Nuclear Distill / 1 8,000 136,000 14 NA 2.1 4.1 NA NA

SSN 640 NAVY Ben Franklin Submarine 2 Nuclear Distill / 1 8,000 136,000 14 NA 0.3 0.6 NA NA

SSN 671 NAVY Narwhal Submarine 1 Nuclear Distill / 1 8,000 136,000 14 NA 0.2 0.3 NA NA

SSN 688 NAVY Los Angeles Submarine 56 Nuclear Distill / 1 10,000 170,000 14 NA 11.1 22.2 NA NA

SSBN 726 NAVY Ohio Submarine 17 Nuclear Distill / 1 12,000 204,000 22 NA 6.4 12.7 NA NA

WAGB 399 USCG Polar Icebreaker 2 Diesel Distill / 2 16,000 272,000 NA NA 0 0 NA NA

WHEC 378 USCG Hamilton/Hero Class High Endurance Cutter 12 Diesel Distill / 1 10,000 170,000 26 151 0 100.0 329.9 429.9

WIX 295 USCG Eagle Sailing Ship (Barque, Training) 1 Diesel RO/ 2 7,600 30,400 24 265 0 0 2.9 2.9

WLB 180B USCG Balsam Seagoing Tenders 2 Diesel RO/ 1 500 2,000 10 120 0 0.0 0 0.0

WLB 225 USCG Juniper Seagoing Tenders 2 Diesel Distill / 1 1,000 17,000 NA NA 0 0 NA NA

WMEC 210A USCG Reliance Medium Endurance Class 5 Diesel Distill / 1 3,000 51,000 18 149 0 59.9 60.0 119.9

WMEC 210B USCG Reliance Medium Endurance Class 11 Diesel Distill / 1 3,000 51,000 18 149 0 59.9 60.0 119.9

WMEC 213 USCG Diver Medium Endurance Class 1 Diesel Distill / 1 3,000 51,000 18 98 0 7.0 20.0 27.0

WMEC 230 USCG Storis Medium Endurance Class 1 Diesel Distill / 1 3,000 51,000 22 167 0 2.0 8.0 10.0

WMEC 270A USCG Bear Medium Endurance Class 4 Diesel Distill / 1 6,000 102,000 14 164 0 83.0 100.0 183.0

WMEC 270B USCG Bear Medium Endurance Class 9 Diesel Distill / 1 6,000 102,000 14 164 0 83.0 100.0 183.0

WPB 110A USCG Island Patrol Craft 16 Diesel RO/ 1 300 1,200 4 72 0 6.0 0 6.0

WPB 110B USCG Island Patrol Craft 21 Diesel RO/ 1 300 1,200 14 137 0 6.0 0 6.0

WPB 110C USCG Island Patrol Craft 12 Diesel RO/ 1 300 1,200 10 157 0 3.0 0 3.0

LSV ARMY NA Logistics Support Vessel 6 Diesel Distill/ 2 2,000 34,000 40 150 0 0.0 41.8 41.8

LCU-2000 ARMY NA 2000 Class Landing Craft Utility 35 Diesel RO/ 2 800 32,000 6 275 0 0.0 9.9 9.9

LT-128 ARMY NA 128 ft Large Tug 6 Diesel RO/ 2 600 2,400 10 245 0 0.0 1.7 1.7

TOTALS: 541 1,480 10,957 1,836 616 43,575 46,027
Distillation and Reverse Osmosis Brine

16

Notes:

1. NA = Information not available; distilling plant assumed.

2. One transit = travel from sea to port, or from port to sea.

3. General Assumptions (typical or average per fleet):

a. Vessel and submarine travel time in coastal waters (<12 n.m.) is 4 hours per transit.

b. Steam propelled ships operate one distilling plant unit in port for an average of 3 days (4 hours for submarines) prior to departure (to fill boiler feed

water tanks) and while transiting outbound through coastal waters. Ship distilling plants are operated at full capacity while at sea (>12 n.m.).

c. Diesel and gas turbine propelled ships do not operate water purification systems in port or while transiting coastal waters.

d. Daily Brine Flow = H20 Design Capacity times 17 for evaporation systems and 4 for RO systems..

4. MSC Water Purification Operating Criteria

a. Steam propelled MSC ships operate at least one distilling plant unit at all times while in port, except for ships in reduced operating status (ROS).

5. Annual Brine Discharge Formulas:

a. IN-PORT (steam propelled)

1.) Navy and MSC ROS

2.) MSC NON-ROS

b. IN-TRANSIT (steam propelled)

c. >12 n.m. (all ships)

6. Out of the 18 DDG51 Class ships currently in commission, DDG 52 through 63 do not have RO units. They have vapor compression distillers. There are

plans to replace them with ROs in the future.
Distillation and Reverse Osmosis Brine

17

Table 2. Summary of Detected Analytes

Constituent Log Normal

Mean

Frequency

of Detection

Minimum

Concentration

Maximum

Concentration

Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Influent Mass

Loading

Effluent Mass

Loading

Mass Loading

(Effluent -

Influent)

Evaporator Brine Influent Evaporator Brine Effluent

Metals (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (lbs/yr) (lbs/yr) (lbs/yr)

Aluminum

 Dissolved 34.54 1 of 3 BDL 61.3 41.65 1 of 3 BDL 187 753.63 856.73 103.1

 Total 370.83 2 of 3 BDL 2390 938.56 3 of 3 493.5 1380 8091.16 19306.05 11214.89

Arsenic

 Dissolved ~ ~ ~ ~ 2.93 2 of 3 BDL 10.9 ~ 60.27 60.27

 Total 1.71 1 of 3 BDL 2 2.18 1 of 3 BDL 1 37.31 44.84 7.53

Barium

 Dissolved 12.51 3 of 3 7.1 17.8 21.21 3 of 3 17.5 23.8 272.96 436.29 163.33

 Total 22.18 3 of 3 16.6 27.5 30.15 3 of 3 27 34.35 483.95 620.18 136.23

Boron

 Dissolved 2368.67 3 of 3 2140 2810 2472.67 3 of 3 2270 2775 51682.12 57033.44 5351.32

 Total 2466.79 3 of 3 2030 3160 2588.76 3 of 3 2350 3115 53823 53250.44 (a)

Calcium

 Dissolved 227789.51 3 of 3 204000 267000 234484.79 3 of 3 210500 264000 4970149.71 4823320.15 (a)

 Total 234025.72 3 of 3 193000 290000 243238.76 3 of 3 221000 287500 5106217.86 5003388.16 (a)

Copper

 Dissolved 29.97 2 of 3 BDL 404 59.21 3 of 3 49.7 71.15 653.92 1217.94 564.02

 Total 83.51 3 of 3 12.7 1560 217.38 3 of 3 127 325.5 1822.11 4471.48 2649.37

Iron

 Total 594.59 3 of 3 107 2090 1081.50 3 of 3 576.5 1590 12973.39 22246.31 9272.92

Lead

 Dissolved ~ ~ BDL BDL 10.94 2 of 3 BDL 12.95 ~ 225.03 225.03

 Total 6.77 1 of 3 BDL 2.7 23.84 2 of 3 BDL 24.4 147.71 490.39 342.68

Magnesium

 Dissolved 765931.19 3 of 3 699000 883000 783038.72 3 of 3 712500 904500 16711887.56 16106999.66 (a)

 Total 781032.79 3 of 3 661000 978000 793166.24 3 of 3 693500 945500 17041390.06 16315321.37 (a)

Manganese

 Dissolved 11.10 3 of 3 3.5 24 9.83 3 of 3 6.6 12.5 242.19 202.20 (a)

 Total 39.86 3 of 3 25.1 51.3 35.27 3 of 3 23.65 51.75 869.71 725.50 (a)

Molybdenum

 Dissolved 6.83 1 of 3 BDL 8.5 5.97 2 of 3 BDL 7.05 149.02 122.80 (a)

 Total 8.57 2 of 3 BDL 14 6.72 2 of 3 BDL 15.4 186.99 138.23 (a)

Nickel

 Dissolved 32.40 1 of 3 BDL 500 9.71 1 of 3 BDL 20.1 706.94 199.73 (a)

 Total 44.43 1 of 3 BDL 1290 13.17 2 of 3 BDL 32 969.42 270.91 (a)

Selenium

 Dissolved ~ ~ BDL BDL 13.83 1 of 3 BDL 42.9 ~ 284.48 284.48

 Total ~ ~ BDL BDL 13.72 1 of 3 BDL 41.6 ~ 282.22 282.22

Sodium

 Dissolved 6733418.84 3 of 3 5840000 8500000 7096448.89 3 of 3 6190000 8585000 146916772.7 145972985.71 (a)
Distillation and Reverse Osmosis Brine

18

 Total 6756605.00 3 of 3 5540000 8310000 7047726.17 3 of 3 6390000 8110000 147422672.6 144970766.01 (a)

Tin

 Dissolved ~ ~ BDL BDL 7.20 1 of 3 BDL 6.9 ~ 148.10 148.1

 Total ~ ~ BDL BDL 14.68 3 of 3 8.2 42.1 ~ 301.97 301.97

Titanium

 Total 13.12 2 of 3 BDL 55.8 25.49 3 of 3 8.85 51.15 286.27 524.33 238.06

Zinc

 Dissolved 14.78 2 of 3 BDL 26.8 70.33 3 of 3 54.15 116.5 322.49 1446.68 1124.19

 Total 18.49 2 of 3 BDL 43.9 122.26 3 of 3 92.95 174 403.43 2514.87 2111.44

Classicals (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (lb/yr) (lb/yr) (lbs/yr)

Alkalinity 82.44 3 of 3 70 92 91.50 3 of 3 76 105 1798762.12 1882142.52 83380.4

Ammonia as Nitrogen 0.07 1 of 3 BDL 0.11 0.17 2 of 3 BDL 0.33 1527.33 2262.68 735.35

Chemical Oxygen

Demand

139.58 2 of 3 BDL 412 244.93 3 of 3 137 429 3045502.39 5038176.69 1992674.3

Chloride 12288.42 3 of 3 10900 15200 13260.50 3 of 3 11500 14800 268121596.3 272766676.27 4645080

HEM 3.83 1 of 3 BDL 9 2.86 1 of 3 BDL 5 83566.94 58829.81 (a)

Nitrate/Nitrite 0.02 1 of 3 BDL 0.2 0.02 1 of 3 BDL 0.22 436.38 411.39 (a)

Sulfate 1626.17 3 of 3 1360 1860 1629.17 3 of 3 1370 1890 35481477.38 33511804.68 (a)

Total Dissolved Solids 20202.53 3 of 3 18200 22100 20659.78 3 of 3 17700 26500 440799923.3 424968856.61 (a)

Total Kjeldahl

Nitrogen

0.54 3 of 3 0.31 0.75 0.47 2 of 2 0.46 0.49 11782.28 9667.84 (a)

Total Organic Carbon 1.59 2 of 3 BDL 3.5 3.01 3 of 3 2.6 3.5 34692.28 61915.29 27223.01

Total Phosphorous 0.17 3 of 3 0.13 0.25 0.23 3 of 3 0.16 0.27 3709.24 4731.07 1021.83

Total Recoverable Oil

& Grease

1.38 2 of 3 BDL 3.4 1.95 3 of 3 0.6 4.2 30110.28 40111.23 10000.95

Total Sulfide 5.77 3 of 3 4 8 5.52 3 of 3 4 7 125895.89 113545.65 (a)

Total Suspended

Solids

48.34 3 of 3 32 107 85.04 3 of 3 27 386 1054732.66 1749261.20 694528.54

Volatile Residue 620.87 2 of 3 BDL 18200 594.19 2 of 3 BDL 18900 13546790.84 12222407.25 (a)

Organics (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (lb/yr) (lb/yr) (lbs/yr)

4-Chloro-3-

Methylphenol

~ ~ BDL BDL 20.94 2 of 3 BDL 75 ~ 430.73 430.73

BDL = Below Detection Limit

~ = Value could not be calculated because samples are BDL

(a) = Mass loading estimates were not determined for parameters for which the influent mass loading exceeded the effluent mass loading.
Distillation and Reverse Osmosis Brine

19

Table 3. Estimated Mass Loadings of Constituents

Constituent Log-normal Mean

Influent (μg/L)

Log-normal

Mean Effluent

(μg/L)

Influent Mass

Loading (lbs/yr)

Effluent Mass

Loading

(lbs/yr)

Estimated Annual

Mass Loading

(Effluent - Influent)

(lbs/yr)

Ammonia as

Nitrogen

0.07 0.17 1527.33 2262.68 735.35

Nitrate/Nitrite 20 20 436.38 411.39 -24.99

Total Kjeldahl

Nitrogen

540 470 11782.28 9667.84 -2114.44

Total

Phosphorous

0.17 0.23 3709.24 4731.07 1021.83

Copper

 Dissolved 29.97 59.21 653.92 1217.94 564.02

 Total 83.51 217.38 1822.11 4471.48 2649.37

Iron

 Total 594.59 1081.50 12973.39 22246.31 9272.92

Lead

 Total 6.77 23.84 147.71 490.39 342.68

Nickel

 Total 44.43 13.17 969.42 270.91 -698.51

Zinc

 Total 18.49 122.26 403.43 2514.87 2111.14

Notes:

1. The table lists all constituents whose effluent log-normal mean concentration exceeds the Federal or most

stringent state water quality criteria. 2. The average total concentration is the log-normal mean for a constituent,

determined from Table 2, by subtracting the influent total average (background) concentration from the effluent

total average concentration.

3. Mass loadings are based on average total concentrations and a total fleet brine discharge flow estimate of 2.47

billion gallons per year to navigable waters less than 12 n.m. from shore (1.84 billion gallons per year in port and

0.62 billion gallons per year in transit, from Table 1). Mass loading was not determined for nickel, for which the

influent concentration exceeded the effluent concentration.
Distillation and Reverse Osmosis Brine

20

Table 4. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Constituent Log-normal

Mean

Effluent

Minimum

Concentration

Effluent

Maximum

Concentration

Effluent

Federal

Acute WQC

Most Stringent

State Acute WQC

Classicals (μg/L)

Ammonia as

Nitrogen

170 BDL 330 None 6 (HI)A

Nitrate/Nitrite 20 BDL 220 None 8 (HI)A

Total Kjeldahl

Nitrogen

470 460 490 None -

Total NitrogenB490 None 200 (HI)A

Total Phosphorous 230 160 270 None 25 (HI)A

Metals (μg/L)

Copper

 Dissolved 59.21 49.7 71.15 2.4 2.4 (CT, MS)

 Total 217.38 127 325.5 2.9 2.5 (WA)

Iron

 Total 1081.5 576.5 1590 None 300 (FL)

Lead

 Total 23.84 BDL 24.4 217.2 5.6(FL, GA)

Nickel

 Total 13.17 BDL 32 74.6 8.3 (FL, GA)

Zinc

 Total 122.3 93.0 174 95.1 84.6 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA = California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Distillation and Reverse Osmosis Brine

21

Table 5. Summary of Thermal Effects of Distilling Plant Brine Discharge9

CASE Discharge

Temp (°F)

Discharge

Flow

(gallons per

hour)

Ambient

Water

Temp (°F)

Predicted

Plume

Length (m)

Allowable

Plume

Length (m)

Predicted

Plume Width

(m)

Allowable

Plume Width

(m)

Predicted

Plume

Depth (m)

Virginia State (3.0°C ΔT)

4a (CV 63) 104 24,083 40 3.8 32,000 0.43 3,200 0.43

4b (CGN 36) 120 6,375 40 2.57 32,000 0.35 3,200 0.35

Washington State (0.3°C ΔT)

4a (CV 63) 104 24,083 50 16.42 73 1.83 400 1.83

4b (CGN 36) 120 6,375 50 7.72 73 19.28 400 0.96

Table 6. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

NSTMa X

2.2 Releases to the Environment NSTM and

MSDSsa,b

X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate Design

Documentation

X X

3.3 Constituents X X

3.4 Concentrations MSDSb X

4.1 Mass Loadings X

4.2 Environmental Concentrations X X

4.3 Thermal Effects X

4.4 Potential for Introducing NonIndigenous SpeciesX

a

 NSTM - Naval Ships’ Technical Manual

b

 MSDS - Material Safety Data Sheet
Distillation and Reverse Osmosis Brine MPCD Analysis

1

DISTILLATION AND REVERSE OSMOSIS BRINE

MARINE POLLUTION CONTROL DEVICE (MPCD) ANALYSIS

Several alternatives were investigated to determine if any reasonable and practicable

MPCDs exist or could be developed for controlling distillation and reverse osmosis (RO) brine

discharges. An MPCD is defined as any equipment or management practice, for installation or

use onboard a vessel, designed to receive, retain, treat, control, or eliminate a discharge incidental

to the normal operation of a vessel. Phase I of UNDS requires several factors to be considered

when determining which discharges should be controlled by MPCDs. These include the

practicability, operational impact, and cost of an MPCD. During Phase I of UNDS, an MPCD

option was deemed reasonable and practicable even if the analysis showed it was reasonable and

practicable only for a limited number of vessels or vessel classes, or only on new construction

vessels. Therefore, every possible MPCD alternative was not evaluated. A more detailed

evaluation of MPCD alternatives will be conducted during Phase II of UNDS when determining

the performance requirements for MPCDs. This Phase II analysis will not be limited to the

MPCDs described below and may consider additional MPCD options.

MPCD Options

Distilling and RO plants generate freshwater from seawater for a variety of shipboard

applications, including potable water for drinking, hotel services, aircraft and vehicle washdowns,

boiler feedwater on steam-powered vessels, and auxiliary boiler feedwater on most vessels.

Discharges from distilling and RO plants contain influent seawater, contaminants from system

components, and anti-scaling treatment chemicals. Distilling plants boil seawater, and the

resulting steam is condensed into distilled water. During the distilling process, seawater

constituents form a scale on the heat transfer surfaces. Therefore, anti-scaling compounds are

continuously injected into the influent seawater to control the scaling. The remaining seawater

concentrate or “brine” that does not boil away is discharged overboard. RO systems separate

freshwater from seawater using semi-permeable membranes as a physical barrier, allowing a

portion of the influent seawater to pass through the membrane as freshwater, while capturing

suspended and dissolved constituents. These captured substances become concentrated in a

seawater brine that is subsequently discharged overboard.

Five potential MPCD options were investigated for controlling this discharge within 12

n.m. of shore. The MPCD options were selected based on screenings of alternate materials and

equipment, pollution prevention options, and management practices. They are listed below with

brief descriptions of each:

Option 1: Restrict operation of water purification plants in port - Eliminate or

minimize distilling and RO plant use in port. This would require alternate sources of

distilled/demineralized water for boiler feedwater for steam powered vessels.
Distillation and Reverse Osmosis Brine MPCD Analysis

2

Option 2: Layup non-essential water purification plants with freshwater when in

port - Require the use of shore-supplied freshwater to layup all water purification plants

on non-steam powered vessels and the non-essential plants onboard steam powered

vessels, to reduce corrosion.

Option 3: Require RO systems on new ships - Specify RO plants instead of distilling

plants to meet freshwater requirements (except boiler feedwater production) for new

construction ships. RO plant discharges are expected to contain fewer heavy metals.

Option 4: Substitute freshwater for seawater to operate distilling plants onboard

steam-powered vessels while in port - Require freshwater from a shore connection,

instead of seawater, to provide feedwater for distilling plants on steam-powered vessels.

This option would reduce metal mass loadings in the brine discharge by reducing seawater

induced corrosion.

Option 5: Change distilling and RO plant construction materials - Specify water

purification plants that are constructed of materials that minimize or eliminate discharge of

harmful constituents.

MPCD Analysis Results

Table 1 shows the results of the MPCD analysis. It contains information on the elements

of practicability, effect on operational and warfighting capabilities, cost, environmental

effectiveness, and a final determination for each option. Based on these findings, Option 3 --

requiring RO systems on new construction ships – offers the best combination of these elements

and is considered to represent a reasonable and practicable MPCD.
Distillation and Reverse Osmosis Brine MPCD Analysis

3

Table 1. MPCD Option Analysis and Determination

MPCD Option Practicability Effect on Operational &

Warfighting Capabilities

Cost Environmental

Effectiveness

Determination

Option 1. Restrict

operation of water

purification plants in

port

This option primarily affects

steam-powered surface

ships, which run their

distillers in port to produce

feedwater for their

propulsion boilers. Distilled

water would alternatively

have to be provided by shore

facilities and it is unlikely

that the shore facilities

could meet the full

feedwater requirements of

the ships in a port.

The impact of this option on

operational capabilities

depends on the amount of

distilled water that can be

obtained from shore for

boiler feedwater.

Inadequate feedwater supply

will adversely affect the

ability to get a steampowered ship underway,

and whether or not

sufficient reserves are

available to quickly go to

full power and to sustain

that power for as long as

needed.

This option would impose

additional costs to meet

distilled water requirements

from an alternate, shoreside

source.

1

 Costs include

shore infrastructure and

possible additional

shoreside manning. Similar

costs would be incurred if

shore-supplied steam were

used in place of steam from

in-port boiler operation.

This option would reduce

shipboard water purification

plant operating and

maintenance costs.

This option would be

effective in reducing in-port

distilling plant brine

discharge constituents and

any accompanying thermal

effects. The effectiveness of

this option is proportional

to how much the distilling

plant operation could be

restricted, which would

depend on the availability of

alternate sources of boiler

feedwater and/or steam.

Although this option would

reduce the discharge, there

is currently no alternate

source of boiler feedwater,

the option has the

possibility to cause an

adverse effect on

operational capabilities, and

this option would impose

additional costs to provide

an alternate source of boiler

feedwater for the operation

of propulsion boilers.

However, on vessels that are

not steam powered, this

option warrants further

consideration.

Option 2. Layup nonessential water

purification plants with

fresh-water when in port

Steam powered vessels

normally operate just one

plant in port to produce the

required high purity

feedwater for boilers.

Therefore, this option

addresses all plants on nonsteam powered vessels and

the non-essential plants

onboard steam powered

vessels. Freshwater is

predicted to be less

corrosive than seawater,

leading to improved

maintenance and reliability.

NSTM procedure already

allows for freshwater

Freshwater layup of nonessential water purification

plants in port is a minor

change in management

practice, which will not

affect the operational

availability of the vessel.

The additional cost for the

freshwater layup procedure

would include shore

supplied freshwater for the

layup, at approximately

$1.00/1000 gallons,1 and

engineering and installation

costs for pipings and fittings

to provide a pierside

freshwater supply. The

beneficial effects of reduced

corrosion may decrease

maintenance costs.

This option would reduce

the magnitude of metal

mass loadings, however,

purification plants still

operated in port, may

continue to exceed water

quality standards.

Implementing a freshwater

layup of water purification

plants on is: 1) feasible, 2)

would not affect ship

capabilities, 3) should not

impose significant costs,

and 4) could reduce metal

mass loading. Despite this

reduction, metal

concentrations could

continue to exceed water

quality standards.
Distillation and Reverse Osmosis Brine MPCD Analysis

4

MPCD Option Practicability Effect on Operational &

Warfighting Capabilities

Cost Environmental

Effectiveness

Determination

layups. A freshwater source

and the means to feed it to

the plant are required for

this option.

Option 3. Require RO

systems on new ships

Steam-powered-vessel

propulsion boilers require

quantities of high purity

feedwater not currently

achievable by shipboard RO

systems, so these vessels

would require a

combination of RO and

distilling plants. RO units

are smaller, requiring less

space and equipment

interface than distilling

plants.

RO membranes are

damaged by oil and other

contaminants prevalent in

littoral waters.2,3 This

option would reduce

acoustic and thermal

signatures since RO plants

have fewer motors and

pumps, and do not require

or produce heat.

Overall, RO systems cost

significantly less than

distilling plants with respect

to life cycle costs, including

acquisition, engineering and

installation, logistics

support, operation, and

maintenance. RO units do

not require chemical feed

and cleaning agents, so

chemical and cleaning costs

would not incur.

This option would reduce

the brine discharge volume

and is predicted to reduce

the concentrations of

constituents in the

discharge. Compared to

distillers, RO plants contain

fewer heavy metal sources,

do not use heat in the water

purification processeliminating thermal effects,

and do not use anti-scaling

chemical additives.

Requiring the installation of

RO plants on all new ships

would: 1) be feasible if

installed along with

distilling plants on steampowered vessels, 2) have

minimal operational

impacts, 3) cost

significantly less than

distilling plants, and 4)

reduce brine discharge

constituent concentrations.

Option 4. Substitute

freshwater for seawater

to operate distilling

plants onboard steampowered vessels while in

port

Influent water for the

distillers would require a

pierside freshwater supply,

however, shore facilities

may not be equipped to

provide a sufficient volume

of freshwater. Considerable

shore infrastructure

upgrades would be required

to implement this option.

Since this option is confined

to in-port operation of

distilling plants, it will not

impact operational and

warfighting capabilities.

This option would impose

cost increases due to: 1)

shore supplied freshwater at

$1.00/1000 gallons1 and 2)

engineering and installation

costs for shore

infrastructure upgrades.

The beneficial effects of

reduced corrosion could

reduce maintenance costs,

therefore compensating for

and increase from cleaning

and de-scaling.

This option would reduce,

but not eliminate the

discharge of heavy metals,

such as copper and nickel,

originating from distilling

plant components.

Implementing the use of

freshwater for water

purification plant operation

on steam powered vessels in

port is: 1) feasible with

shore infrastructure

upgrades, 2) would not

affect ship capabilities, and

3) would reduce metal mass

loading. Despite this

reduction, metal

concentrations could

continue to exceed water

quality standards.

Option 5. Change

distilling and RO plant

construction materials

This option would primarily

apply to distilling plants

because RO plants do not

employ heating coils which

introduce metals into the

This option would not

impact ship operations,

provided that system

reliability is maintainted.

Thermal signature is not

This option would impose

research, development, and

material costs. The

alternative materials (i.e.

stainless steel, titanium, or

Alternate materials would

reduce the concentration

and volume of brine

discharge constituents. The

level of constituent

Changing plant piping and

fitting materials will reduce

heavy metal and scaling

treatment constituent

concentrations and loadings
Distillation and Reverse Osmosis Brine MPCD Analysis

5

MPCD Option Practicability Effect on Operational &

Warfighting Capabilities

Cost Environmental

Effectiveness

Determination

discharge stream. In order

for this option to be

practicable, the new

materials could not increase

the maintenance

requirements, size, or

weight of the water

purification plant. If

materials are simply

substituted, space

requirements would remain

the same and weight would

be expected to decrease,

making this a practicable

option.

expected to change. nickel alloys) would range

in cost from $0.10/lb to

$100/lb.4,5,6 Shore

infrastructure and manning

costs would increase if

material changes required

special maintenance and

repair capabilities.

reduction would be

proportional to the extent to

which materials

contributing to heavy metals

in the discharge are

replaced or removed from

the system.

from brine discharge.

Using alternate materials

for the actual water

purification equipment is

less practicable, may entail

higher life cycle cost, and

Navy grade water

purification plants made of

alternate materials are not

readily available.
Distillation and Reverse Osmosis Brine MPCD Analysis

6

REFERENCES

1

 Memorandum from Mr. R. Bernstein (M. Rosenblatt & Son, Inc.), Subj: Estimate for

Freshwater Supply to Vessels While Inport, November 13, 1997.

2

 Naval Ship’s Technical Manual, Chapter 531 - Desalination, Volume 1 - Low-Pressure Distilling

Plants, S9086-SC-STM-010/CH-531V1, First Revision, March 21, 1996.

3

 Naval Ship’s Technical Manual, Chapter 533 - Potable Water Systems, S9086-SC-STM010/CH-533, Third Revision, March 15, 1995.

4

 Titanium Prices, e-mail from Mr. Sam Fisher, Principal Metals, Inc., November 13, 1997.

5

 Titanium Prices, personal communication with Mr. Bob Marsh, Titanium Industries, Inc.,

November 24, 1997.

6

 Metals Prices, MetalWorld, Inc., http://www.metalworld.com, August 29, 1997.
Elevator Pit Effluent

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second phase

will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Elevator Pit Effluent
Elevator Pit Effluent

2

2.0 DISCHARGE DESCRIPTION

This section describes the discharge from elevator pits and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Most large surface vessels have at least one type of elevator; however, elevator

configurations vary between ship classes. On each ship, several different types and sizes of

elevators may be used to transport small packages, large cargo items, ordnance, food supplies,

and personnel.1 Elevators can service several decks depending on their purpose. Elevator doors

open at each deck for loading and unloading. The elevator operates using either cables, rails, or

hydraulic pistons. The elevators that raise and lower aircraft on aircraft carriers cannot produce

this discharge because they are open to the sea and do not have elevator pits. Elevators that

operate in shafts have a sump in the pit to collect liquids that may enter the elevator and shaft

area.

1

 If the elevator pit is located above the waterline, the sump is fitted with a drain that directs

the waste overboard. This drain is normally higher than the sump floor to prevent clogging from

solids. If the elevator pit is located below the waterline, the pit is educted dry using the firemain

water supply.

2.2 Releases to the Environment

For elevators with pits, deck runoff and elevator equipment maintenance activities are the

major sources of liquid that accumulate in the pit. Deck runoff occurs during heavy rains, rough

seas, and deck washdowns. During these events, water from the deck can enter the elevators and

elevator shafts when the elevator doors are open, or through worn seals when the doors are

closed (non-watertight). When water enters the elevator pit, it can contain materials that were on

the deck, including aviation fuel, hydraulic fluid, lubricating oil, residual water, and aqueous film

forming foam (AFFF).2 The runoff may also include lubricant applied to the elevator doors, door

tracks, and other moving elevator parts. Residue in the elevator car from the transport of

materials may also be washed into the elevator pit. The cleaning solvent used during

maintenance cleaning operations as well as liquid wastes generated by the cleaning process drain

into the elevator pit sump. This mixture of materials and liquid collects in the sump at the

bottom of the elevator pit.

Waste accumulated in the elevator pits is removed by gravity draining, by educting

overboard using firemain powered eductors, by using a vacuum or sponges to transfer the waste

to the ship’s bilge system for treatment as bilgewater, or by containerizing it for shore disposal.3

Since elevator pit eductors use the firemain water supply, the elevator pit effluent can contain any

constituents present in the firemain water. The ratio of elevator pit waste to firemain supply can

vary from 1:1 to 3:1, depending on the type of eductor used to evacuate the elevator pit.

2.3 Vessels Producing the Discharge
Elevator Pit Effluent

3

All of the ships listed in Tables 1, 2, and 3 have the potential to produce an elevator pit

discharge. Table 1 lists the MSC ships that have elevators. Tables 2 and 3 list the number and

types of major elevator systems on Navy surface combatants and support ships, respectively.4

U.S. Coast Guard (USCG), Air Force, and Army vessels do not produce this discharge because

they do not have elevator pits.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

This discharge has the potential to occur within and beyond 12 nautical miles (n.m.) from

shore. Inspections of elevator pits on Navy ships in port revealed that elevator pits are generally

dry and that elevator pit effluent is not expected to be discharged in significant amounts within

12 n.m. because of current practices which educt the waste overboard prior to the ship coming

within 12 n.m. of shore.3 Without these practices, this effluent could be discharged while

pierside or underway.

3.2 Rate

The rate of this discharge is subject to frequency and amount of deck runoff (e.g.,

washdown water and rainfall), as well as the frequency of use of the elevators and the size of the

elevator opening. These factors vary greatly between vessel classes. Inspections were performed

on nine vessels to investigate the presence of accumulated waste in elevator pits. The inspections

revealed that elevator pits in each vessel were often dry when the vessel came into port, because

the accumulated waste had either been drained or educted overboard prior to the vessel coming

within 50 n.m. of land, containerized for shore disposal, or the waste had been transferred to the

bilge for treatment by the oil water separator (OWS) as bilgewater.3

 Based on this information, it

is estimated that the discharge flow rates of elevator pit effluent within the 12 n.m. zone are

minimal.

3.3 Constituents

The constituents of elevator pit effluent are affected by the amount and type of materials

on deck, the agents used during cleaning and maintenance of the elevators, and to some degree

the material transported in the elevators. At any given time elevator pit effluent may contain the

following constituents:

• grease;

• lubricating oil;
Elevator Pit Effluent

4

• solvent;

• soot;

• dirt;

• paint chips;

Additional constituents that may be carried into the elevator pit by deck runoff can

include fuel, AFFF, glycol, and sodium metasilicate. Material safety data sheet (MSDS)

information on these materials indicate that the constituents can include polymers, heavy

hydrocarbons, paraffinic distillates, silicone compounds, various organic acids, hydroxyl

compounds, naphtha compounds, various oils, and some metals such as lead and zinc.

When eductors are used to remove the waste accumulated in elevator pits, the effluent is a

combination of the pit waste and the firemain water that is used for eduction. It is not possible to

determine the percentages of each of these sources, because they would vary from ship to ship

depending upon a number of factors. Furthermore, effluent sampling would not help to

determine these percentages, as it would be impossible to isolate and analyze the three sources of

the discharge. The Firemain Systems NOD report contains a more complete discussion of those

constituents found in firemain water. The only constituents present in the firemain water that

were found to exceed water quality criteria were copper, iron, and nickel.

Of the constituents listed above, the expected priority pollutants in this discharge are

bis(2-ethylhexyl) phthalate, silver, chromium, copper, iron, nickel, lead, zinc, and phenols. Deck

runoff is the source of these pollutants, with the exception of bis(2-ethylhexyl) phthalate, copper,

iron, and nickel, which are also present in firemain water. Additional information concerning

these pollutants can be found in the Deck Runoff NOD report.

No bioaccumulators are anticipated in this discharge.

3.4 Concentrations

Constituent concentrations of deck runoff resulting from precipitation will vary with a

number of factors. The following factors affecting deck runoff constituent concentrations are

dependent on time since the last rainfall or deck washdown:

• intensity and duration of rainfall;

• type, intensity, and duration of weather (high sea state and green water);

• season (which will affect glycol loading from deicing fluids);

• ship’s adherence to good housekeeping practices; and

• ship’s operations.

The periodicity of cleaning and lubrication of the mechanical components in the elevator

pit will also affect constituent concentrations. For example, if the guide rollers, bearings, etc.,

located in the bottom of the elevator shaft are cleaned and greased more often, the concentrations

of solvent and grease in the effluent could increase.
Elevator Pit Effluent

5

The Firemain Systems NOD report contains a more detailed analysis of firemain water

constituent concentrations. As shown in Table 4, the firemain water constituents that exceeded

the most stringent water quality criteria were total nitrogen, bis(2-ethylhexyl) phthalate, copper,

iron, and nickel, where the total measured effluent log-normal mean concentrations were 500

micrograms per liter (μg/L), 22 μg/L, 62.4 μg/L, 370 μg/L, and 15.2 μg/L, respectively. 5

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. A discussion of mass

loadings is presented in Section 4.1. In Section 4.2, the concentrations of discharge are

discussed, and in Section 4.3, the potential for the transfer of non-indigenous species is

evaluated.

4.1 Mass Loading

Mass loadings cannot be calculated because the quantity of constituents released from

elevator pits cannot be estimated, and because the concentration of these constituents will vary as

discussed in Section 3.4. Inspections of elevator pits on Navy ships in port revealed that elevator

pits are generally dry and that elevator pit effluent is not expected to be discharged in significant

amounts within 12 n.m. because of current practices which educt the waste overboard prior to the

ship coming within 12 n.m. of shore.3

4.2 Environmental Concentrations

Concentrations of grease, oil, cleaning solvent, and other pollutants that might be present

in elevator pit effluent have not been estimated. The concentrations of total nitrogen, bis(2-

ethylhexyl) phthalate, copper, iron, and nickel in the firemain water used for eduction have been

found to exceed water quality criteria.

4.3 Potential for Introducing Non-Indigenous Species

The major sources of elevator pit effluent, deck runoff and maintenance activities, do not

have a significant potential to introduce non-indigenous species; therefore, this discharge does

not have a significant potential for transporting non-indigenous species.

5.0 CONCLUSION

Uncontrolled, elevator pit effluent could possibly have the potential to cause an adverse

environmental effect because oil could be discharged in amounts and concentrations high enough

to cause an oil sheen, especially when the vessel is pierside. There are currently no formalized

management practices in place regulating this discharge. However, surveys and inspections of

nine Navy ships indicated that the current practice is to containerize the waste for shore disposal,
Elevator Pit Effluent

6

to transfer the waste to the ship’s bilges for processing by the OWS, or to refrain from discharging

the waste overboard.3

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained, reviewed,

and analyzed. Table 5 indicates the data source of the information presented in each section of

this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Elevator Pit Effluents. October 1, 1996.

2. Round 2 Equipment Expert Meeting Minutes - Elevator Pit Effluent. April 3, 1997.

3. Navy Fleet Technical Support Center Pacific (FTSCPAC) Inspection Report Regarding

Elevator Pit and Anchor Chain Locker Inspection Findings on Six Navy Ships, March 3,

1997.

4. Naval Surface Warfare Center, Carderock Division, Philadelphia Site (NSWCCD-SSES)

Report Regarding Number and Type of Elevators on Various Navy Vessels, Paul

Hermann, October 17, 1997.

5. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR 22230.

May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.
Elevator Pit Effluent

7

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Elevator Pit Effluent

8

Table 1. Type of Elevators and Conveyors on MSC Ships

Vessel Passenger

Elevators

Cargo Elevator Stores Lift

(British)

Mars

AFS 1

(1) 16,000 lb CARGO

(2) 4,000 lb (HYD)

HELO

Niagara Falls

AFS 3

(1) 16,000 lb CARGO

(2) 10,000 lb HELO

(2) 12,000 lb CARGO

Concord

AFS 5

(1) 16,000 lb CARGO

(2) 10,000 lb HELO

(2) 12,000 lb CARGO

San Diego

AFS 6

(1) 16,000 lb CARGO

(2) 10,000 HELO

San Jose

AFS 7

(1) 16,000 lb CARGO

(2) 10,000 lb HELO

(2) 12,000 CARGO

(3) 4,000 lb CARGO

T-AFS 8 Class

3 Vessels

8 per vessel 1 per vessel

T-AH 19 Class

2 Vessels

10 per vessel

T-AO 187 Class

10 Vessels

1 per vessel

LKA-113 Class

2 Vessels

6 per vessel

T-AE 28 Class

4 Vessels

6 per vessel

T-AE 32 Class

4 Vessels

6 per vessel1

1. Number 6 elevator divides into two elevators.
Elevator Pit Effluent

9

Table 2. Number and Type of Major Elevator Systems

(Navy Surface Combatants)

Ship Class Number of

Vessels

Number of Elevators

Per Vessel

Type of

Elevator

CG 47 27 2 Ammunition

DD 963/

DDG 993

35 2 Ammunition

FFG 7 48 1 Pallet

CVN 65 1 14 Weapons

CVN 68 7 9 (CVN 72 - 74)

10 (CVN 68, 70, 71)

11 (CVN 69)

Weapons

CV 67 1 9 Weapons

CV 63 2 11 (CV 63)

12 (CV 64)

Weapons
Elevator Pit Effluent

10

Table 3. Number and Type of Major Elevator Systems

(Navy Auxiliary and Amphibious ships)

Ship Class Hull Number of Type of

Elevators Elevator

Underway AE 27 6 Cargo/Weapons

Replenishment AE 28 6 Cargo/Weapons

Ships AE 29 6 Cargo/Weapons

AE 32 7 Cargo/Weapons

AE 33 7 Cargo/Weapons

AE 34 7 Cargo/Weapons

AE 35 7 Cargo/Weapons

AOE 1 9 Cargo/Weapons

AOE 2 9 Cargo/Weapons

AOE 3 9 Cargo/Weapons

AOE 4 9 Cargo/Weapons

AOE 6 6 Cargo/Weapons

1 Cargo

AOE 7 6 Cargo/Weapons

1 Cargo

AOE 8 7 Cargo/Weapons

AO 177 1 Weapons

AO 178 1 Weapons

AO 179 1 Weapons

AO 180 1 Weapons

AO 186 1 Weapons

Material AS 36 8 Cargo

Support 2 Component

Ships 2 Weapons

AS 39 8 Cargo

2 Component

1 Weapons

AS 41 8 Cargo

2 Component

1 Weapons

Amphibious LCC 19 1 Vehicle

Warfare LCC 20 1 Vehicle

Ships LHA 1 5 Cargo/Weapons

1 Medevac

LHA 2 5 Cargo/Weapons

1 Medevac

LHA 3 5 Cargo/Weapons

1 Medevac

LHA 4 5 Cargo/Weapons

1 Medevac

LHA 5 5 Cargo/Weapons

1 Medevac

LHD 1 6 Cargo/Weapons

1 Medevac

LHD 2 6 Cargo/Weapons

1 Medevac
Elevator Pit Effluent

11

Ship Class Hull Number of Type of

Elevators Elevator

Amphibious LHD 3 6 Cargo/Weapons

Warfare 1 Medevac

Ships (continued) LHD 4 6 Cargo/Weapons

1 Medevac

LHD 5 6 Cargo/Weapons

1 Medevac

LPD 1 Decommissioned

LPD 2 Decommissioned

LPD 4 1 Cargo/Weapons

LPD 5 1 Cargo/Weapons

LPD 6 1 Cargo/Weapons

LPD 7 1 Cargo/Weapons

LPD 8 1 Cargo/Weapons

LPD 9 1 Cargo/Weapons

LPD 10 1 Cargo/Weapons

MCS 12 1 Cargo/Weapons

LPD 13 1 Cargo/Weapons

LPD 14 1 Cargo/Weapons

LPD 15 1 Cargo/Weapons

LPH 3 2 Weapons

LPH 11 2 Weapons

LPH 12 2 Weapons

LSD 41 1 Cargo

1 Weapons

LSD 42 1 Cargo

1 Weapons

LSD 43 1 Cargo

1 Weapons

LSD 44 1 Cargo

1 Weapons

LSD 45 1 Cargo

1 Weapons

LSD 46 1 Cargo

1 Weapons

LSD 47 1 Cargo

1 Weapons

LSD 48 1 Cargo

1 Weapons

LSD 49 2 Cargo

1 Ammunition

3 Lift Platform

LSD 50 2 Cargo

1 Ammunition

3 Lift Platform

LSD 51 2 Cargo

1 Ammunition

3 Lift Platform

Other Auxiliary AGF 3 1 Cargo/Weapons/Stores

Ships AGF 11 1 Cargo/Weapons
Elevator Pit Effluent

12

Table 4. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Constituents Log-normal

Mean

Effluent

Minimum

Concentration

Effluent

Maximum

Concentration

Effluent

Federal Acute

WQC

Most Stringent

State Acute WQC

Classicals (μg/L)

Total Nitrogen 500 None 200 (HI)A

Organics (μg/L)

Bis(2-ethylhexyl)

phthalate

22 BDL 428 None 5.92 (GA)

Metals (μg/L)

Copper

 Dissolved 24.9 BDL 150 2.4 2.4 (CT, MS)

 Total 62.4 34.2 143 2.9 2.5 (WA)

Iron

 Total 370 95.4 911 None 300 (FL)

Nickel

 Total 15.2 BDL 52.1 74.6 8.3 (FL, GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

CT = Connecticut

FL = Florida

GA = Georgia

MS = Mississippi

WA = Washington

Table 5. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X X

3.2 Rate X

3.3 Constituents MSDS X

3.4 Concentrations unknown

4.1 Mass Loadings unknown

4.2 Environmental Concentrations unknown

4.3 Potential for Introducing NonIndigenous SpeciesX
Firemain Systems

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Firemain Systems
Firemain Systems

2

2.0 DISCHARGE DESCRIPTION

This section describes the firemain discharges and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Firemain systems distribute seawater for fire fighting and secondary services. The

firefighting services are fire hose stations, seawater sprinkling systems, and foam proportioning

stations. Fire hose stations are distributed throughout the ship. Seawater sprinkling systems are

provided for spaces such as ammunition magazines, missile magazines, aviation tire storerooms,

lubricating oil storerooms, dry cargo storerooms, living spaces, solid waste processing rooms,

and incinerator rooms. Foam proportioning stations are located in rough proximity to the areas

they protect, but are separated from each other for survivability reasons. Foam proportioners

inject fire fighting foam into the seawater, and the solution is then distributed to areas where

there is a risk of flammable liquid spills or fire. Foam discharge is covered in the aqueous film

forming foam (AFFF) NOD report. The secondary services provided by wet firemain systems

are washdown countermeasures, cooling water for auxiliary machinery, eductors, ship

stabilization and ballast tank filling, and flushing for urinals, commodes and pulpers. The

washdown countermeasure system includes an extensive network of pipes and nozzles, to

produce a running water film on exterior ship surfaces. Not all these services are provided on all

vessels.

Firemain systems fall under two major categories: wet and dry firemains. Wet firemains

are continuously pressurized so that the system will provide water immediately upon demand.

Dry firemains are not charged with water and, as a result, do not supply water upon demand.

Most vessels in the Navy's surface fleet operate wet firemains.1 Most vessels in the Military

Sealift Command (MSC) use dry firemains.1 All U.S. Coast Guard (USCG), and U.S. Army

vessels use dry firemains.

For the purposes of the Firemain Systems NOD report, the firemain system includes all

components between the fire pump suction sea chest and the cutout valves to the various

services. If the discharge from the service is not covered by its own NOD report, it is included in

this Firemain Systems NOD report. The components of the firemain system are the sea chests,

fire pumps, valves, piping, fire hose, and heat exchangers.

Seawater from the firemain is discharged over the side from fire hoses, or directly to the

sea through submerged pipe outlets. Seawater discharges from secondary services supplied from

the firemain are described in the pertinent NOD reports; see Section 2.2 below.

The sea chest is a chamber inset into the hull, from which seawater flows to a fire pump.

The fire pump sea chests are constructed of the hull material - steel - and are coated with durable

epoxy paints. They also contain steel waster pieces or zinc sacrificial anodes for corrosion

protection. The fire pumps are constructed of titanium, stainless steel, copper alloyed with tin or
Firemain Systems

3

nickel, or non-metallic composites. The pipes in wet firemain systems are primarily coppernickel alloys and fittings are bronze that are connected by welding or by silver-brazed joints. Dry

firemain systems can be constructed of these same materials but are normally constructed of

steel.

Fire pumps are centrifugal style pumps driven by steam turbines, electric motors, and/or

diesel engines. The pumps are located in the lower levels of vessels and are sized to deliver

required flow and pressure to equipment or systems on the upper decks. Pump sizes range from

50 to 250 gallons per minute (gpm) on small vessels to 2,000 gpm on large vessels.1 To prevent

overheating when firemain load demands are low, Navy fire pumps are designed to pass 3 to 5%

of the nominal flow rate back to the sea suction or overboard.2 This also provides flow to the

pump’s seals.

The firemain piping layout (architecture) is governed by the mission or combatant status

of the ship. The simplest architecture consists of a single main run fore and aft in the ship, with

single branches to the various services supplied from the firemain. More complex architectures

incorporate multiple, widely separated mains with cross connects, and feature multiple pipe paths

to vital services. Regardless of the architecture, all firemain systems include pipe sections which

may contain stagnant water. For example, except during fire fighting, the valves at the fire plugs

are closed and sprinkling systems do not flow.

Navy firemain system capacity is designed to meet peak demand during emergency

conditions, after sustaining damage. This capacity is determined by adding the largest fire

fighting demand, the vital continuous flow demands, and a percentage of the intermittent cooling

demands. The number of fire pumps required to meet this capacity is increased by a 33% margin

to account for battle damage or equipment failure.2 As a result, Navy firemain systems have

excess capacity during routine operations.

Firemain capacity on most MSC, U.S. Coast Guard (USCG), and Army ships is designed

to commercial standards as prescribed by regulations pertinent to each ship type.3,4 Ships

acquired from naval or other sources satisfy other design criteria, but the firemain capacity

requirements meet or exceed commercial standards. A minimum of two pumps is required. The

required firemain capacity is less than would be required on Navy ships of similar type and size.

Dry firemains are not charged and do not provide instantaneous water pressure. These

systems are periodically tested as part of the planned maintenance system (PMS) and are

pressurized during training exercises.

2.2 Releases to the Environment

Seawater discharged overboard from the firemain contains entrained or dissolved

materials, principally metals, from the components of the firemain system. Some traces of oil or

other lubricants may enter the seawater from valves or pumps.
Firemain Systems

4

Fire fighting, space dewatering using eductors, counterflooding, and countermeasure

washdown constitute emergency discharges from the firemain, and are not incidental to the

vessel’s operation. Some auxiliary machinery is provided with backup emergency cooling from

the firemain. Use of the firemain for backup emergency cooling is not an incidental discharge.

Seawater from the firemain is released to the environment as an incidental discharge for the

following services:

• Test and maintenance;

• Training;

• Cooling water for auxiliary machinery and equipment, for which the firemain is the

normal cooling supply. Examples are central refrigeration plants, steering gear

coolers, and the Close In Weapon System;

• Bypass flow overboard from the pump outlet, to prevent overheating of fire pumps

when system demands are low; and

• Anchor chain washdown.

The following are incidental services provided from the firemain, but the release to the

environment is discussed separately as shown:

• Ballast tank filling (Clean Ballast NOD report);

• Flushing water for commodes (Black Water[sewage]; not part of the UNDS study);

• Flushing water for food garbage grinders (Graywater NOD report);

• Stern tube seals lubrication (Stern Tube Seals & Underwater Bearing Lubrication

NOD report); and

• AFFF (AFFF NOD report).

2.3 Vessels Producing the Discharge

All Navy surface ships use wet firemain systems with the exception of two classes of

oceanographic research ships. Submarines use dry systems. Boats and craft are not equipped

with firemain systems and generally use portable fire pumps or fire extinguishers for fire

fighting. Most ships operated by the MSC use dry firemain systems, so they do not continuously

discharge water overboard as part of normal operations; however, two classes of ships use wet

firemains. These classes are ammunition ships (T-AE) and combat stores ships (T-AFS). The

USCG and Army use dry firemain systems, so they do not continuously discharge water

overboard as part of normal operations. Table 1 lists the ships and submarines in the Navy,

MSC, USCG, and Army, and notes whether their firemain systems are the wet or dry type.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
Firemain Systems

5

3.1 Locality

Firemain discharge occurs both within and beyond 12 nautical miles (n.m.) of shore.

3.2 Rate

The flow rates for wet firemain discharge depend on the type, number, and operating time

of equipment and systems that use water from the firemain. Operating times of many systems are

highly variable. Some connected services, such as refrigeration plants, are operated

continuously; others, such as hydraulics cooling or aircraft carrier jet blast deflectors, are

operated only during specific ship evolutions. Ships with auxiliary seawater cooling systems

tend to have relatively few services that draw continuous flow from the firemain. For these

ships, the firemain discharge will be small compared to the discharge from the seawater cooling

system. Table 2 shows the theoretical upper bound estimate of discharge from wet firemain

systems, with an estimated total annual volume of approximately 18.6 billion gallons. The

estimate is considered an upper bound because, for most ships, all flow from the fire pumps is

assumed to be an environmental release attributable to the firemain system.

Sample calculation for Table 2:

(Qty of ships)(Flow rate (gpm))(1440 min/day)(Days within 12 n.m./yr) = gal/yr

The discharge from dry firemains is approximately 0.1% of the discharge from wet

firemains because none of the discharge is continuous. A theoretical upper bound estimate for

discharges from dry systems within 12 n.m. is given in Table 3.

Sample calculation for Table 3:

(Qty of ships)(Flow rate (gpm))(10 minutes/wk)(Days within 12 n.m./yr)(1 wk/7 days) = gal/yr

The 10 minutes/week is based on a minimum of 2 pumps required by USCG regulations,

in addition to a run time of 5 minutes/week per pump based upon equipment expert

knowledge.5,6,7

3.3 Constituents

The water for firemain services is drawn from the sea and returned to the sea. Metals and

other materials from the firemain and its components can be dissolved by the seawater. Table 4

lists such metals and other materials. Where seawater flow is turbulent, particles of metal will be

eroded from pump impellers, valve bodies, and pipe sections, and carried in the firemain as

entrained particles.8 Electrochemical corrosion attacks at the junctions of dissimilar metals to

produce both dissolved and particulate metals. Any wetted material in the system can contribute

dissolved or particulate constituents to the firemain discharge. These constituents can include

copper, nickel, aluminum, tin, silver, iron, titanium, chromium, and zinc. Based on knowledge
Firemain Systems

6

of the system, the principal expected constituents that are priority pollutants would be copper,

nickel, and zinc. Copper and nickel are found in the piping of wet firemain systems, and

sacrificial zinc anodes are placed in some sea chests and heat exchangers. None of these

expected constituents are bioaccumulators.

Most dry type firemain systems are constructed of steel pipe, without zinc anodes.

Therefore, copper, nickel and zinc are not expected constituents of dry type firemain systems.

3.4 Concentrations

The firemain systems of three ships were sampled for 26 metals (total and dissolved),

semi-volatile organic compounds, polychlorinated biphenyls (PCBs), and classical constituents.

Only wet firemains were sampled because the volumes discharged by wet firemains comprise the

vast majority of the total volume of the discharge. The firemains were sampled both at the inlet

and at the discharge to determine what constituents were contributed by the firemain system.

The three ships sampled were a dock landing ship, an aircraft carrier, and an amphibious assault

ship. Details of the sampling effort and the sampled data are described in the Sampling Episodes

Report for seawater cooling. Table 4 summarizes the results.

Variability is expected within this discharge as a result of several factors including

material erosion and corrosion, residence times, passive films, and influent water variability.

Pipe erosion is caused by high fluid velocity, or by abrasive particles entrained in the seawater

flowing at any velocity. In most cases of pipe erosion, the problematic high fluid velocity is a

local phenomenon, such as would be caused by eddy turbulence at joints, bends, reducers,

attached mollusks, or tortuous flow paths in valves. Passive films inhibit metal loss due to

erosion. Corrosion is influenced by the residence time of seawater in the system, temperature,

biofouling, constituents in the influent, and the presence or absence of certain films on the pipe

surface. All of these influences on metallic concentrations are variable within a given ship over

time, and between ships.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria.

Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

Mass loadings are shown in Table 5. The concentrations of constituents contributed by

the firemain system were combined with the estimated annual firemain discharge from Table 2

for wet firemains to determine mass loadings by the equation:
Firemain Systems

7

Mass Loading (lbs/yr) = (Table 4 net log normal mean concentration (μg/L))

(Table 2 discharge volume (18.6 billion gal/yr))(3.785 L/gal)(2.205 lbs/kg)(10-9 kg/μg)

Dry firemains were not sampled. Most dry firemain systems are constructed of steel, so

the principal expected metallic constituent will be iron. The discharge rate from dry firemain

systems is about 0.1% of the rate from wet firemain systems, so the mass loadings should also be

much less. Accordingly, the mass loadings from dry firemain systems were not included in the

mass loading estimates.

4.2 Environmental Concentrations

Table 6 compares measured constituent concentrations with Federal and the most

stringent state chronic water quality criteria (WQC). The comparison in Table 6 shows that the

effluent concentrations of bis(2-ethylhexyl) phthalate, nitrogen (as nitrate/nitrite and total

nitrogen), copper, iron, and nickel exceed WQC. The copper and nickel contributions each

exceed both the Federal and most stringent state criteria. The ambient copper concentration in

most ports exceeds the chronic WQC. As mentioned previously, copper and nickel constitute the

major construction materials for wet firemains in the Navy. Bis(2-ethylhexyl) phthalate, nitrogen,

and iron concentration exceeds the most stringent state chronic criterion.

4.3 Thermal Effects

As mentioned previously, portions of the firemain are used for seawater cooling purposes

and will discharge excess thermal energy to receiving waters. The thermal plume from firemains

was not modeled directly; however, firemain discharge can be compared to a discharge that was

modeled, such as seawater cooling water from an Arleigh Burke Class (DDG 51) guided missile

destroyer. The use of DDG51 flow parameters for seawater cooling will overestimate the size of

the thermal plume because all vessels have firemain discharge rates less than the estimated

pierside seawater cooling rate of 1,680 gpm for a DDG 51 class ship. Additionally, the

temperature difference (delta T) between the effluent and influent for firemain is lower

(measured at 5°F) than the delta T for seawater cooling from a DDG 51 class ship (measured at

10°F).

The seawater cooling water discharge was modeled using the Cornell Mixing Zone

Expert System (CORMIX) to estimate the plume size and temperature gradients in a receiving

water body using conditions tending to produce the largest thermal plume. Thermal modeling

was performed for the DDG 51 in two harbors (Norfolk, Virginia; and Bremerton, Washington).

Of the five states that have the largest presence of Armed Forces vessels, only Virginia, and

Washington have established thermal mixing zone criteria.9 The discharge was also assumed to

occur in winter when the discharge would produce the largest thermal plume. Based on

modeling for a DDG 51 class ship, the resulting plume did not exceed the thermal mixing zone

requirements for Virginia or Washington.9

All vessels have firemain discharge rates less than the seawater cooling discharge rate,

and delta T’s less than the measured temperature difference associated with a DDG 51.
Firemain Systems

8

Therefore, the heat rejection rate from any firemain system will be lower than that of a DDG 51

class ship for seawater cooling water. Accordingly, the resulting thermal plume for the firemain

discharge is not expected to exceed the thermal criteria for , Virginia or Washington and adverse

thermal effects are not anticipated.

4.4 Potential for Introducing Non-Indigenous Species

Wet and dry firemain systems have a minimal potential for transporting non-indigenous

species, because the residence times for most portions of the system are short. Some portions of

the system lie stagnant where marine organisms may reside. However, these areas tend to

develop anaerobic conditions quickly, except at the junctions with the active portions of the

system, where oxygenated water continuously flows by and through the ship. Anaerobic

conditions are not hospitable to most marine organisms. Additionally, firemain systems do not

transport large volumes of water over large distances.

5.0 CONCLUSIONS

Firemain discharge has the potential to cause an adverse environmental effect because the

concentrations of Bis(2-ethylhexyl) phthalate, nitrogen, copper, nickel, and iron exceed federal or

most stringent state water quality criteria and the estimated annual mass loadings for these metals

are significant. The thermal effects of this discharge were reviewed and are not significant. The

potential for introducing non-indigenous species is minimal.

6.0 REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information and assumptions were used to estimate the rate of discharge and sampling was

performed to gather results related to the constituents and concentrations of the discharge. Table

7 shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes. Firemain System Discharge. 8 October,

1996.

2. Naval Sea Systems Command, Design Practice and Criteria Manual for Surface Ship

Firemain Systems, 1988.

3. Naval Sea Systems Command, Commercial General Specifications for T-ships of the

United States Navy, 1991 Ed. 15 March 1991.

4. Code of Federal Regulations, 46 CFR Parts 34, 76, and 95.
Firemain Systems

9

5. Code of Federal Regulations, 46 CFR Part 34. 10-5.

6. Weersing, Penny, Military Sealift Command Central Technical Activity. Dry firemain

discharge within 12 n.m., 17 March 1997, David Eaton, M. Rosenblatt & Son.

7. Fischer, Russ, Army. Dry Firemain Discharge within 12 n.m., 13 March 1998, Ayman

Ibrahim, M. Rosenblatt & Son.

8. The International Nickel Company, Guidelines for Selection of Marine Materials, 2nd

Ed., May 1971.

9. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed

Services. Versar, Inc. July 3, 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.
Firemain Systems

10

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Van der Leeden, et al. The Water Encyclopedia, 2nd Ed. Lewis Publishers: Chelsea, Michigan,

1990.

Malcolm Pirnie, Inc. UNDS Phase 1 Sampling Data Report, Volumes 1 through 13, October

1997.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.

UNDS Ship Database, August 1, 1997.
Firemain Systems

11

Table 1. Wet and Dry Firemains of the Navy, MSC, USCG, and Army

Class Description Quantity of

Vessels

Wet/Dry

Navy Ships

SSBN Ohio Class Ballistic Missile Submarines 17 Dry

SSN Sturgeon Class Attack Submarines 13 Dry

SSN Los Angeles Class Attack Submarines 56 Dry

SSN Narwhal Class Submarine 1 Dry

SSN Benjamin Franklin Class Submarines 2 Dry

CV Forrestal Class Aircraft Carrier 1 Wet

CVN Enterprise Class Aircraft Carrier 1 Wet

CV Kitty Hawk Class Aircraft Carriers 3 Wet

CVN Nimitz Class Aircraft Carriers 7 Wet

CGN Virginia Class Guided Missile Cruiser 1 Wet

CG Ticonderoga Class Guided Missile Cruisers 27 Wet

CGN California Class Guided Missile Cruisers 2 Wet

DDG Kidd Class Guided Missile Destroyers 4 Wet

DDG Arleigh Burke Class Guided Missile Destroyers 18 Wet

DD Spruance Class Destroyers 31 Wet

FFG Oliver Hazard Perry Guided Missile Frigates 43 Wet

LCC Blue Ridge Class Amphibious Command Ships 2 Wet

LHD Wasp Class Amphibious Assault Ships 4 Wet

LHA Tarawa Class Amphibious Assault Ships 5 Wet

LPH Iwo Jima Class Assault Ships 2 Wet

LPD Austin Class Amphibious Transport Docks 3 Wet

LPD Amphibious Transport Docks 2 Wet

LPD Amphibious Transport Docks 3 Wet

LSD Whidbey Island Class Dock Landing Ships 8 Wet

LSD Harpers Ferry Dock Landing Ships 3 Wet

LSD Anchorage Class Dock Landing Ships 5 Wet

MCM Avenger Class Mine Countermeasure Vessels 14 Wet

MHC Osprey Class Minehunter Coastal Vessels 12 Wet

PC Cyclone Class Coastal Defense Ships 13 Wet

Navy Auxiliary Ships

AGF Raleigh Class Miscellaneous Command Ship 1 Wet

AGF Austin Class Miscellaneous Command Ship 1 Wet

AO Jumboised Cimarron Class Oilers 5 Wet

AOE Supply Class Fast Combat Support Ships 3 Wet

AOE Sacramento Class Fast Combat Support Ships 4 Wet

ARS Safeguard Class Salvage Ships 4 Wet

AS Emory S Land Class Submarine Tenders 3 Wet

AS Simon Lake Class Submarine Tender 1 Wet

AGOR Gyre Class Oceanographic Research Ship 1 Dry

AGOR Thompson Class Oceanographic Research Ships 2 Dry

Military Sealift Command

T-AE Kilauea Class Ammunition Ships 8 Wet

T-AFS Mars Class Combat Stores Ships 8 Wet

T-ATF Powhatan Class Fleet Ocean Tugs 7 Dry

T-AO Henry J Kaiser Class Oilers 13 Dry
Firemain Systems

12

Class Description Quantity of

Vessels

Wet/Dry

T-AGM Compass Island Class Missile Instrumentation Ships 1 Dry

T-ARC Zeus Class Cable Repairing Ship 1 Dry

T-AKR Maersk Class Fast Sealift Ships 3 Dry

T-AKR Algol Class Vehicle Cargo Ships 8 Dry

T-AGOS Stalwart Class Ocean Surveillance Ships 5 Dry

T-AGOS Victorious Class Ocean Surveillance Ships 4 Dry

T-AG Mission Class Navigation Research Ships 2 Dry

T-AGS Silas Bent Class Surveying Ships 2 Dry

T-AGS Waters Class Surveying Ship 1 Dry

T-AGS McDonnell Class Surveying Ships 2 Dry

T-AGS Pathfinder Class Surveying Ships 4 Dry

Coast Guard

WHEC Hamilton and Hero Class High Endurance Cutters 12 Dry

WMEC Storis Class Medium Endurance Cutter 1 Dry

WMEC Diver Class Medium Endurance Cutter 1 Dry

WMEC Famous Class Medium Endurance Cutters, Flight A 4 Dry

WMEC Famous Class Medium Endurance Cutters, Flight B 9 Dry

WMEC Reliance Class Medium Endurance Cutters, Flight A 5 Dry

WMEC Reliance Class Medium Endurance Cutters, Flight B 11 Dry

WAGB Mackinaw Class Icebreaker 1 Dry

WAGB Polar Class Icebreakers 2 Dry

WTGB Bay Class Icebreaking Tugs 9 Dry

WPB Point Class Patrol Craft 36 Dry

WPB Island Class Patrol Craft 49 Dry

WLB Juniper Class Seagoing Buoy Tenders 2 Dry

WLB Balsam Class Seagoing Buoy Tenders, Flight A 8 Dry

WLB Balsam Class Seagoing Buoy Tenders, Flight B 2 Dry

WLB Balsam Class Seagoing Buoy Tenders, Flight C 13 Dry

WLM Keeper Class Coastal Buoy Tenders 2 Dry

WLM White Sumac Class Coastal Buoy Tenders 9 Dry

WLI Inland Buoy Tenders 6 Dry

WLR River Buoy Tenders, 115-foot 1 Dry

WLR River Buoy Tenders, 75-foot 13 Dry

WLR River Buoy Tenders, 65-foot 6 Dry

WIX Eagle Class Sail Training Cutter 1 Dry

WLIC Inland Construction Tender, 115-foot 1 Dry

WLIC Pamlico Class Inland Construction Tenders 4 Dry

WLIC Cosmos Class Inland Construction Tenders 3 Dry

WLIC Anvil and Clamp Classes Inland Construction Tenders 7 Dry

WYTL 65 ft. Class Harbor Tugs 11 Dry

Army

FMS Floating Machine Shops 3 Dry

LSV Frank S. Besson Class Logistic Support Vessels 6 Dry

LCU 2000 Class Utility Landing Craft 48 Dry

LT Inland and Coastal Tugs 25 Dry
Firemain Systems

13

Table 2. Theoretical Upper Bound-Estimate of Annual Wet Firemain Discharge

Class Description Quantity

of Vessels

Flow Rate per

Vessel (GPM)

Days w/in

12 n.m.

Estimated Annual

Volume for Class,

Gal

Navy

CV Forrestal Class Aircraft Carrier 1 1,000 143 205,920,000

CVN Enterprise Class Aircraft Carrier 1 1,000 76 109,440,000

CV Kitty Hawk Class Aircraft Carriers 3 1,000 137 591,840,000

CVN Nimitz Class Aircraft Carriers 7 1,000 147 1,481,760,000

CGN Virginia Class Guided Missile Cruiser 1 250 166 59,760,000

CG Ticonderoga Class Guided Missile Cruisers 27 250 161 1,564,920,000

CGN California Class Guided Missile Cruisers 2 250 143 102,960,000

DDG Kidd Class Guided Missile Destroyers 4 250 175 252,000,000

DDG Arleigh Burke Class Guided Missile Destroyers 18 500 101 1,308,960,000

DD Spruance Class Destroyers 31 250 178 1,986,480,000

FFG Oliver Hazard Perry Guided Missile Frigates 43 250 167 2,585,160,000

LCC Blue Ridge Class Amphibious Command Ships 2 400 179 206,208,000

LHD Wasp Class Amphibious Assault Ships 4 800 185 852,480,000

LHA Tarawa Class Amphibious Assault Ships 5 800 173 996,480,000

LPH Iwo Jima Class Assault Ships 2 600 186 321,408,000

LPD Austin Class Amphibious Transport Docks 3 300 178 230,688,000

LPD Amphibious Transport Docks 2 300 178 153,792,000

LPD Amphibious Transport Docks 3 300 178 230,688,000

LSD Whidbey Island Class Dock Landing Ships 8 300 170 587,520,000

LSD Harpers Ferry Dock Landing Ships 3 300 215 278,640,000

LSD Anchorage Class Dock Landing Ships 5 300 215 464,400,000

MCM Avenger Class Mine Countermeasure Vessels 14 150 232 701,568,000

MHC Osprey Class Minehunter Coastal Vessels 12 100 232 400,896,000

PC Cyclone Class Coastal Defense Ships 13 50 50 46,800,000

Navy Auxiliary

AGF Raleigh Class Miscellaneous Command Ship 1 400 183 105,408,000

AGF Austin Class Miscellaneous Command Ship 1 400 183 105,408,000

AO Jumboised Cimarron Class Oilers 5 200 188 270,720,000

AOE Supply Class Fast Combat Support Ships 3 500 114 246,240,000

AOE Sacramento Class Fast Combat Support Ships 4 600 183 632,448,000

ARS Safeguard Class Salvage Ships 4 100 202 116,352,000

AS Emory S Land Class Submarine Tenders 3 400 293 506,304,000

AS Simon Lake Class Submarine Tender 1 400 229 131,904,000

Military Sealift Command

T-AE Kilauea Class Ammunition Ships 8 300 183 632,448,000

T-AFS Mars Class Combat Stores Ships 8 300 45 155,520,000

Total

Estimated

Annual

Volume,

(gal):

18,623,520,000
Firemain Systems

14

Table 3. Theoretical Upper-Bound Estimate of Annual Dry Firemain Discharge

Class Description Flow

(GPM)

Quantity

of Vessels

Days

within

12 n.m.

Estimated

Annual Volume

(gal)

Navy

SSBN Ohio Class Ballistic Missile Submarines 250 17 183 1,111,071

SSN Sturgeon Class Attack Submarines 250 13 183 849,643

SSN Los Angeles Class Attack Submarines 250 56 183 3,660,000

SSN Narwhal Class Submarine 250 1 183 65,357

SSN Benjamin Franklin Class Submarines 250 2 183 130,714

Navy Auxiliary

AGOR Gyre Class Oceanographic Research Ship 50 1 113 8,071

AGOR Thompson Class Oceanographic Research Ships 100 2 113 32,286

Military Sealift Command

T-ATF Powhatan Class Fleet Ocean Tugs 100 7 127 127,000

T-AO Henry J Kaiser Class Oilers 200 13 78 289,714

T-AGM Compass Island Class Missile Instrumentation Ships 100 2 133 38,000

T-AH Mercy Class Hospital Ships 400 2 184 210,286

T-ARC Zeus Class Cable Repairing Ship 100 1 8 1,143

T-AKR Maesrk Class Fast Sealift Ships 400 3 59 101,143

T-AKR Algol Class Vehicle Cargo Ships 400 8 350 1,600,000

T-AGOS Stalwart Class Ocean Surveillance Ships 200 5 70 100,000

T-AGOS Victorious Class Ocean Surveillance Ship 200 4 107 122,286

T-AG Mission Class Navigation Research Ships 200 2 151 86,286

T-AGS Silas Bent Class Surveying Ships 200 2 44 25,143

T-AGS Waters Class Surveying Ship 200 1 7 2,000

T-AGS McDonnel Class Surveying Ships 200 2 96 54,857

T-AGS Pathfinder Class Surveying Ships 200 4 96 109,714

Coast Guard

WHEC Hamilton and Hero Class High Endurance Cutters 250 12 151 647,143

WMEC Storis Class Medium Endurance Cutter 250 1 167 59,643

WMEC Diver Class Medium Endurance Cutters 250 1 98 35,000

WMEC Famous Class Medium Endurance Cutters, Flight A 250 4 137 195,714

WMEC Famous Class Medium Endurance Cutters, Flight B 250 9 164 527,143

WMEC Reliance Class Medium Endurance Cutters, Flight A 250 5 235 419,643

WMEC Reliance Class Medium Endurance Cutters, Flight B 250 11 149 585,357

WAGB Mackinaw Class Icebreaker 250 1 365 130,357

WAGB Polar Class Icebreaker 250 2 365 260,714

WTGB Bay Class Icebreaking Tugs 250 9 365 1,173,214

WPB Point Class Patrol Craft 50 36 157 403,714

WPB Island Class Patrol Craft 50 49 157 549,500

WLB Juniper Class Seagoing Buoy Tenders 200 16 290 1,325,714
Firemain Systems

15

Class Description Flow

(GPM)

Quantity

of Vessels

Days

within

12 n.m.

Estimated

Annual Volume

(gal)

WLB Balsam Class Seagoing Buoy Tenders, Flight A 200 8 290 662,857

WLB Balsam Class Seagoing Buoy Tenders, Flight B 200 2 220 125,714

WLB Balsam Class Seagoing Buoy Tenders, Flight C 200 13 223 828,286

WLM Keeper Class Coastal Buoy Tenders 100 2 323 92,286

WLM White Sumac Class Coastal Buoy Tenders 100 9 223 286,714

WLI Inland Buoy Tenders 100 6 365 312,857

WLR River Buoy Tenders, 115-foot 100 1 365 52,143

WLR River Buoy Tenders, 75-foot 100 13 365 677,857

WLR River Buoy Tenders, 65-foot 100 6 365 312,857

WIX Eagle Class Sail Training Cutter 50 1 188 13,429

WLIC Inland Construction Tenders, 115 foot 50 1 365 26,071

WLIC Pamlico Class Inland Construction Tenders 50 4 365 104,286

WLIC Cosmos Class Inland Construction Tenders 50 3 365 78,214

WLIC Anvil and Clamp Classes Inland Construction

Tenders

50 27 365 703,929

WYTL 65 ft. Class Harbor Tugs 50 14 350 350,000

Army

FMS Floating Machine Shops 400 3 350 600,000

LSV Frank S. Besson Class Logistic Support Vessel 564 6 180 870,171

LCU 2000 Class Utility Landing Craft 500 48 335 11,485,714

LT Inland and Coastal Tugs 640 25 295 3,371,429

Total

Estimated

Annual

Volume,

(gal):

35,992,385

Note:

 1. Estimates assume that all discharge is due to maintenance or testing. All fire fighting exercises are assumed to occur

at sea beyond 12 n.m. Maintenance is assumed to occur weekly while vessels are in port, with seawater flowing at the

design rate of the pumps for 5 minutes each week.
Firemain Systems

16

Table 4: Summary of Detected Analytes Firemain Systems

Constituent Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Effluent-Influent

Log Normal mean

Mass loading

(lbs/yr)

Seawater Cooling Firemain Influent Seawater Cooling Firemain Effluent

Classicals (mg/L)

ALKALINITY 77.24 3 of 3 72 80 79.12 3 of 3 72 86 1.88 291,179

AMMONIA AS NITROGEN 0.10 2 of 3 BDL 0.18 0.07 1 of 3 BDL 0.11 -0.03 (b)

CHEMICAL OXYGEN DEMAND 132.28 3 of 3 106 179 105.96 2 of 3 BDL 195 -26.32 (b)

CHLORIDE 10497.14 3 of 3 10200 10800 10750.73 3 of 3 9780 12100 253.59 39,276,577

NITRATE/ NITRITE 0.06 2 of 3 BDL 0.34 0.02 1 of 3 BDL 0.4 -0.04 (b)

SULFATE 1273.43 3 of 3 1160 1380 1245.96 3 of 3 1190 1290 -27.47 (b)

TOTAL DISSOLVED SOLIDS- 19705.66 3 of 3 18300 20700 18261.70 3 of 3 16900 19800 -1443.96 (b)

TOTAL KJELDAHL NITROGEN 0.31 2 of 3 BDL 0.95 0.48 3 of 3 0.23 0.84 0.17 26,330

TOTAL ORGANIC CARBON 1.72 2 of 3 BDL 3.2 1.72 2 of 3 BDL 3.2 0 0

TOTAL PHOSPHOROUS 0.15 3 of 3 0.13 0.19 0.15 3 of 3 0.13 0.2 0 0

TOTAL RECOVERABLE OIL AND

GREASE

2.79 3 of 3 0.9 5.6 2.16 2 of 3 BDL 10.9 -0.63 (b)

TOTAL SULFIDE (IODOMETRIC) 7.00 2 of 2 BDL 7 6.54 3 of 3 5 8 -0.46 (b)

TOTAL SUSPENDED SOLIDS 21.09 3 of 3 19 26 20.05 3 of 3 12 28 -1.04 (b)

VOLATILE RESIDUE 9016.50 3 of 3 1920 20200 8755.30 3 of 3 2230 19800 -261.2 (b)

Metals (μg/L)

ALUMINUM

 Dissolved 37.44 1 of 3 BDL 78.1 - - - - - -

 Total 197.35 2 of 3 BDL 732 85.79 1 of 3 BDL 805.5 -111.56 (b)

ANTIMONY

 Dissolved 7.08 1 of 3 BDL 23.7 - - - - - -

ARSENIC

Dissolved 1.79 1 of 3 BDL 5 2.64 2 of 3 BDL 5 0.85 132

Total 1.27 2 of 3 BDL 3.4 2.71 1 of 3 BDL 5 1.44 223

BARIUM

 Dissolved 20.43 3 of 3 16.5 25.6 18.0 3 of 3 13.4 26.5 -2.39 (b)

 Total 21.65 3 of 3 16.1 25.3 23.7 3 of 3 17.7 29.7 2.09 324

BORON

 Dissolved 2109.70 3 of 3 2010 2290 2110 3 of 3 1930 2340 -3.1 (b)

 Total 2076.31 3 of 3 2040 2130 2160 3 of 3 2080 2320 80.8 12,514

CALCIUM

 Dissolved 198376.19 3 of 3 190000 214000 195800 3 of 3 179500 219000 -2560.58 (b)

 Total 196332.23 3 of 3 187000 213000 198600 3 of 3 186000 217000 2242.88 347,382

COPPER

 Dissolved 8.43 2 of 3 BDL 13.3 24.9 2 of 3 BDL 150 16.46 2,549

 Total 16.82 3 of 3 13.1 21.9 62.4 3 of 3 34.2 143 45.59 7,061
Firemain Systems

17

Constituent Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Effluent-Influent

Log Normal mean

Mass loading

(lbs/yr)

Seawater Cooling Firemain Influent Seawater Cooling Firemain Effluent

IRON

 Dissolved - - - - 20.3 1 of 3 BDL 189 20.3 (a) 3,138 (a)

 Total 348.48 3 of 3 161 824 370 3 of 3 95.4 910.5 21.28 3,296

MAGNESIUM

 Dissolved 673065.05 3 of 3 634000 697000 657000 3 of 3 590000 698000 -15948.78 (b)

 Total 674584.89 3 of 3 664000 689000 672000 3 of 3 663000 678000 -2782.22 (b)

MANGANESE

 Dissolved 11.12 3 of 3 9.4 12.5 10.77 3 of 3 7.4 13.3 -0.35 (b)

 Total 17.32 3 of 3 11.4 24.5 19.00 3 of 3 12.2 27.2 1.68 260

MOLYBDENUM

 Dissolved 7.21 2 of 3 BDL 25.5 - - - - - -

 Total 4.51 1 of 3 BDL 6.1 3.29 1 of 3 BDL 10.8 -1.22 (b)

NICKEL

 Dissolved - - - - 13.8 1 of 3 BDL 38.9 13.83 (a) 2,142 (a)

 Total - - - - 15.2 1 of 3 BDL 52.1 15.24 (a) 2,360 (a)

SELENIUM

 Dissolved 16.90 1 of 3 BDL 48.3 14.9 1 of 3 BDL 56.7 -1.96 (b)

SODIUM

 Dissolved 5743515.23 3 of 3 5540000 6140000 5710000 3 of 3 5190000 6160000 -37826.6 (b)

 Total 5782507.24 3 of 3 5500000 6030000 5780000 3 of 3 5585000 6160000 -37.06 (b)

THALLIUM

 Dissolved 6.80 1 of 3 BDL 12.6 6.52 1 of 3 BDL 11.1 -0.28 (b)

 Total 7.15 1 of 3 BDL 14.6 7.27 1 of 3 BDL 15.4 0.12 19

TIN

 Dissolved 7.03 1 of 3 BDL 6.2 - - - - - -

TITANIUM

 Total 7.60 2 of 3 BDL 23.7 7.67 2 of 3 BDL 25.8 0.07 11

ZINC

 Dissolved 15.67 2 of 3 BDL 40.5 24.2 3 of 3 21.2 29.5 8.54 1,323

 Total 22.76 3 of 3 20 25.1 31.3 3 of 3 21.3 44.9 8.55 1,324

Organics (μg/L)

BIS(2-ETHYLHEXYL)

PHTHALATE

- - - - 22.0 1 of 3 BDL 428 22.04 (a) 3,414 (a)

BDL= Below Detection Level

note (a) - No background concentration is given for the parameter - therefore an influent concentration of zero was used to determine a conservative mass loading

note (b) - Mass loading was not determined for parameters for which the influent concentration exceeded the effluent

Log normal means were calculated using measured analyte concentrations. When a sample set contained one or more samples with the analyte below detection

levels (i.e., "non-detect" samples), estimated analyte concentrations equivalent to one-half of the detection levels were used to calculate the mean. For example, if

a "non-detect" sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log normal mean calculation.
Firemain Systems

18

Table 5. Estimated Annual Mass Loadings of Constituents

Constituent* Log-normal Mean

Influent (μg/L)

Log-normal Mean

Effluent (μg/L)

Log-normal Mean

Concentration (μg/L)

Estimated Annual

Mass Loading (lbs/yr)

Bis(2-ethylhexyl)

phthalate

- 22 22.04 3,414

Nitrate/Nitrite 60 20 -40 (a)

Total Kjeldahl

Nitrogen

310 480 170 26,330

Total Nitrogen* 26,330

Copper

 Dissolved 8.43 24.9 16.46 3,111

 Total 16.82 62.4 45.59 8,618

Iron

 Total 348.48 370 21.28 4,022

Nickel

 Dissolved - 13.8 13.8 (b) 2,142 (b)

 Total - 15.2 15.2 (b) 2,360 (b)

* Mass loadings are presented for constituents that exceed WQC only. See Table 4 for a complete listing of mass

loadings.

Notes:

* Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

(a) - Mass loading was not determined for parameters for which the influent concentration exceeded the effluent

(b) - No background concentration is given for the parameter
Firemain Systems

19

Table 6. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Constituents Log-normal

Mean

Effluent

Minimum

Concentration

Effluent

Maximum

Concentration

Effluent

Federal

Chronic WQC

Most Stringent State

Chronic WQC

Classicals (μg/L)

Nitrate/Nitrite 20 BDL 400 None 8 (HI)A

Total Kjeldahl

Nitrogen

480 230 840 None -

Total NitrogenB500 None 200 (HI)A

Organics (μg/L)

Bis(2-ethylhexyl)

phthalate

22 BDL 428 None 5.92 (GA)

Metals (μg/L)

Copper

 Dissolved 24.9 BDL 150 2.4 2.4 (CT, MS)

 Total 62.4 34.2 143 2.9 2.9 (GA, FL)

Iron

 Total 370 95.4 911 None 300 (FL)

Nickel

 Dissolved 13.8 BDL 38.9 8.2 8.2 (CA, CT)

 Total 15.2 BDL 52.1 8.3 7.9 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

BDL-Below Detection Level

CA = California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Firemain Systems

20

Table 7. Data Sources

Data Sources

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents X

4.1 Mass Loadings X

4.2 Environmental Concentrations X X

4.3 Thermal Effects X X

4.4 Potential for Introducing NonIndigenous SpeciesX
Freshwater Layup

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second phase

will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Freshwater Layup
Freshwater Layup

2

2.0 DISCHARGE DESCRIPTION

This section describes the freshwater layup discharge and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Seawater cooling systems on vessels provide cooling water for propulsion plant and

auxiliary system heat exchangers. Heat exchangers remove heat directly from the main

propulsion machinery and the electrical generating plants, and directly or indirectly from all other

equipment requiring cooling. The primary purpose of the main seawater system is to provide the

coolant to condense low pressure steam from the main turbines and the generator turbines.1

When nuclear-powered submarines and aircraft carriers remain for an extended period

and the seawater cooling systems are not circulated, the main condensers are placed in a

freshwater layup.1 The purpose of placing the condensers in a freshwater layup is to prevent the

accumulation of biological growth and the resultant loss of condenser efficiency while the

seawater cooling system is not in use. The propulsion plants of nuclear-powered vessels

generally require a 2- to 3-day cooling down period prior to being laid up.1

The layup is accomplished by blowing the seawater from the main condensers with low

pressure air and isolating the condensers.1 The condensers are then filled with potable water

from port facilities, a process that takes 1 to 2 hours, or more, to complete.2 The potable water

remains in the condensers, uncirculated, for approximately 2 hours. After this period of time, the

potable water fill is blown overboard with low pressure air, which takes approximately an hour to

accomplish.1,2 The condensers are then considered flushed of any residual seawater (seawater or

potable water). The condensers are then refilled with potable water for the actual layup. This

process can be referred to as a double fill and flush cycle.

After 21 days, the initial fill water is discharged overboard and replaced.1 The layup is

discharged and refilled on a 30-day cycle thereafter.1 This process can be referred to as a refill

cycle. The freshwater layup may be terminated at any point during these cycles to support

equipment maintenance or ship’s movement.1

During a ship check and sampling episode aboard USS Scranton (SSN 756), it was

observed that the main seawater condensers were filled indirectly with freshwater from port

facilities.3 The crew filled the forward potable water tank from the pier connection and then

transferred the freshwater to the aft potable water tank. 3 The main condensers were then put in

freshwater layup from the aft potable water tank. 3 The initial freshwater layup process lasted

greater than 5 hours (e.g., from the beginning of initial fill to initiating the low pressure air blow

to remove the initial freshwater flush). 3

The main steam condensers on submarines are constructed either of titanium or 70/30

copper/nickel alloy.4 Aircraft carrier main seawater condensers are constructed of 90/10
Freshwater Layup

3

copper/nickel alloy. The condenser boxes for the 70/30 copper/nickel alloy condensers are

constructed of a nickel/copper alloy and can be lined with a tin/lead solder and have zinc anodes

installed for corrosion control.4 The seawater piping that carries cooling water from the

condensers to overboard discharge is constructed of 70/30 copper/nickel piping.4

2.2 Releases to the Environment

These discharges occur in port at pierside when the submarine’s nuclear power plant has

cooled and the main seawater cooling system is unable to be circulated for more than 3 days.

Also, this discharge can occur if the ship will be in port for greater than 7 days (i.e., It takes 72

hours to cool down a reactor and 72 hours to ramp up a reactor which translates to six days, or

roughly one week.) and the seawater cooling system can not be circulated. The freshwater is

discharged from the seawater cooling piping openings located below the waterline of the ship.

The discharge occurs when the fresh water is pushed out by low pressure air applied to the

seawater cooling piping system. It is expected that this discharge will contain many of the

constituents found in the fresh water (typically supplied by port facilities) used for the layup, as

well as metals leached from the ship’s piping system while the water is held during the layup, and

any residual seawater remaining in the system after the double fill and flush.

2.3 Vessels Producing the Discharge

All attack submarines (SSNs), ballistic missile submarines (SSBNs), and nuclearpowered carriers (CVNs) generate this discharge. A total of 89 SSNs and SSBNs, and eight

CVNs are currently in service in the Navy. While the three existing nuclear guided missile

cruisers (CGNs) also produce this discharge, these are scheduled to be removed from service by

2003/2004, and therefore, will not be considered further. The Navy is the only member of the

Armed Forces that operates nuclear-powered vessels.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

This discharge only occurs when vessels are in port.

3.2 Rate

The volume of the initial fill and flush of a nuclear-powered submarine is approximately

6,000 gallons of freshwater. This 6,000 gallons of freshwater is discharged overboard after a 1-

to 2-hour layup in the main seawater condensers and refilled with an additional 6,000 gallons of
Freshwater Layup

4

freshwater as described in Section 2.1.5 The total volume of freshwater required for the fill,

flush, and refill of the condenser for freshwater layup on nuclear submarines is approximately

12,000 gallons, of which 6,000 gallons is discharged overboard.5 The volume of this discharge

will vary with the volumes of the main steam condensers for each submarine class.5

The amount of time that a submarine is in port, and hence, the number of layup cycles

required, is dependent upon many factors, the most critical being the submarine’s current mission.

Each mission requires varying times in port for preparation, repairs, or modifications to support

the mission specifics. In addition, many submarines undergo overhauls or other maintenance

and/or repair activities that extend their time in port (e.g., must put their seawater systems into a

dry layup condition).

Attack submarines (SSNs) average about 10 layup cycles per year, including five double

fill and flush cycles and five refill cycles.5 Each double fill and flush cycles and each refill cycle

discharges approximately 6,000 gallons of freshwater per evolution. This results in 60,000

gallons of freshwater for each of the Navy’s 72 SSNs per year. Therefore, fleet-wide discharge

for the SSNs is 4,320,000 gallons of freshwater layup discharge per year, of which half is from

the initial fill and half is from the refill cycles, or 2,160,000 gallons for each.

Ballistic missile submarines (SSBNs) have extended layovers of 1 to 1 1/2 months

approximately three or four times per year. The volume of seawater systems in ballistic missile

submarines are comparable to those of attack submarines. These submarines have an estimated

three initial flush and fill cycles per year and approximately six refill cycles per year.5 For an

SSBN, this totals 54,000 gallons per submarine per year. The Navy operates 17 SSBNs.

Therefore, the total freshwater layup discharged for all SSBNs is estimated to be 918,000 gallons

per year, of which 306,000 gallons is from the initial fill and flush and 612,000 gallons is from

refill cycles.

A total estimated volume of 5,238,000 gallons of freshwater layup is discharged in U.S.

ports from the 89 SSN and SSBN hulls. The initial fill cycle accounts for 2,466,000 gallons and

the refill cycles account for 2,772,000 gallons.

Nuclear powered aircraft carriers do establish freshwater layups in their various

condensers, but the effluent is dumped into the bilges of the ship rather than being discharged

directly overboard. Hence, the residual water from the aircraft carriers’ layup is covered under the

Surface Vessel Bilgewater/OWS Nature of Discharge report.

3.3 Constituents

The freshwater used in the freshwater layup can contain disinfectants from potable water

treatment. The most common disinfectant is chlorine. Some municipalities, however, are

switching over to chloramine disinfection to reduce the amount of disinfectant by-products

formed. This switch could be permanent or seasonal, with the chloramines added during the

warmer months when formation of disinfectant by-products are more prevalent. It is noted that
Freshwater Layup

5

the constituent make-up of the freshwater used to conduct the layup will have a significant effect

on the discharge.

The constituents that can be present in freshwater layup from nuclear-powered

submarines include: copper, lead, nickel, chlorine, ammonia, nitrogen (as nitrate/nitrite, and total

kjeldahl nitrogen), phosphorous and related disinfectants, chromium, tin, titanium and zinc.

Chromium, copper, lead, nickel, and zinc are priority pollutants. None of these constituents are

bioaccumulators. The freshwater layup of a single submarine was sampled to determine the

constituents that are present in the discharge.

3.4 Concentrations

The water used to fill the main condensers, the initial layup discharge, and an extended,

21-day discharge were sampled from USS Scranton (SSN 756).3 A total of 17 metals were

measurable in the initial and extended layup discharges from the sampling event. The vast

majority of the metals detected have sources from either the materials within the main steam

condenser or from the domestic water treatment/distribution system. The metals and classical

parameters detected in the discharge are compiled in Table 1. In addition, the mass loadings are

estimated for those constituents that were detected in either the 2-hour or 21-day layup

discharges. Three priority pollutant metals, copper, nickel and zinc, were detected in the

discharge at elevated concentrations. Total chlorine was also detected in the initial layup

discharge (28 μg/L), but not in the discharge after 21 days. The domestic water from the pier

connection was also sampled for total and free residual chlorine levels and contained 1,200 μg/L

and 1,000 μg/L, respectively.3 Nitrogen (as nitrate/nitrite, and total kjeldahl nitrogen), ammonia,

and phosphorous were detected in both the 2-hour layup and the 21-day layup discharges.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Based upon the concentrations of the metals reported for the layup effluents in Table 1

and the estimated discharge volumes in Section 3.2, the mass loadings were calculated using the

estimated volumes of freshwater layup discharge in Table 2 for those constituents that exceeded

either Federal or most stringent state water quality criteria (WQC). Table 3 highlights the

constituents that exceed WQC. The estimated mass loadings, provided in Table 2, are derived by

adding together contributions from both the initial fill volumes and the refill cycle volumes,

because the two portions of the effluent have different concentrations.
Freshwater Layup

6

Based on the sampling data, the total fleet-wide loadings of ammonia, nitrogen, chlorine,

copper, nickel, phosphorous, and zinc from this discharge are approximately 41, 55, 1, 7, 36, 8,

and 29 pounds per year, respectively.

4.2 Environmental Concentrations

The discharge concentrations presented in Table 3 are compared to Federal and most

stringent state WQC.

Copper was present in the fill water from the aft potable water tank, but it is unknown if

copper was present in domestic water from the pier connection. The fill water copper

concentrations exceeded Federal and the most stringent state. Copper is normally present in the

domestic water supply in concentrations that exceed WQC because of the presence of copperconstructed components in drinking water distribution systems. The levels of copper can be

partially attributable to the construction of the potable water systems on board the submarine

through which the domestic water was routed prior to filling the main seawater condensers.

These systems have copper piping and brass valves that can contribute copper to the water.

Table 3 shows the concentrations of the three priority pollutant metals (copper, nickel,

and zinc) that exceed Federal and most stringent state WQC. The chlorine concentration from

the initial 2-hour layup exceeds the most stringent state criterion. Ammonia, total nitrogen (as

nitrate/nitrite, and total kjeldahl nitrogen), and total phosphorous concentrations in the two layup

discharges exceed the most stringent state criterion. The presence of phosphorous in the effluent

appears to be from the domestic water as the effluent concentrations for total phosphorous shows

no increase over the fill water concentrations.

4.3 Potential for Introducing Non-Indigenous Species

There is no movement of the vessel during the layup process and the water used for the

layup is chlorinated domestic water from shore facilities. As such, there is no potential for

transporting non-indigenous species.

5.0 CONCLUSION

Freshwater layup of seawater cooling systems has a low potential of adverse

environmental effects for the following reasons.

1. The mass loadings of chlorine, copper, nickel, and zinc are small although the

concentrations exceed Federal and most stringent state WQC. The mass loadings

of ammonia, nitrogen, and phosphorous are also small, but concentrations exceed

the most stringent state WQC. The total annual mass loadings for ammonia,

(conc. μg/L)(g/1,000,000 μg) (lbs/453.593 g) (annual volume gal/yr) (3.785 l/gal) =

mass loading (lbs/yr)
Freshwater Layup

7

nitrogen, chlorine, copper, nickel, phosphorous, and zinc contribute

approximately 41, 55, 1, 7, 36, 8, and 29 pounds, respectively. The 89 submarines

producing this discharge are geographically dispersed over seven ports.

2. There is no potential for the transfer of non-indigenous species.

6.0 DATA SOURCES AND REFERENCES

Process knowledge and sampling of this discharge were used in preparing this NOD

report. Table 4 shows the sources of data used to develop this NOD report. The specific

references cited in the report are shown below.

Specific References

1. Kurz, Rich, NAVSEA 92T251. UNDS Equipment Expert Meeting Structured Questions.

Main Sea Water System Freshwater Layup. September 5, 1996.

2. Versar Notes, UNDS Freshwater Layup Sampling Meeting. NAVSEA. May 23, 1997.

3. UNDS Phase I Sampling Data Report, Volumes 1 - 13. October 1997.

4. Bredehorst, Kurt, NAVSEA 03L. Materials Within the Seawater Side of Main

Condenser. September 1996. Miller, Robert B, M. Rosenblatt & Son, Inc.

5. Miller, Robert B., M. Rosenblatt & Son, Inc. Personal Communications on Nature of

Discharge Report: Freshwater Layup, Submarine Main Steam Condensers. January

1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR 22230.

May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.
Freshwater Layup

8

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

UNDS Equipment Expert Meeting Minutes. Seawater Cooling Water Overboard. August 27,

1996.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, pg. 15366. March 23, 1995.

Kurz, Rich, NAVSEA 92T251. Submarine Main Steam Condenser Freshwater Layup E-mail.

November 1996. H. Clarkson Meredith, III, Versar, Inc.

Jane's Fighting Ships, Capt. Richard Sharpe, Ed., Jane's Information Group, Sentinel House:

Surrey, United Kingdom, 1996.

UNDS Ship Database, August 1, 1997.
Freshwater Layup

9

Table 1. Summary of Detected Analytes

Constituent Freshwater

Influent

2-Hour

Freshwater

Effluent

21-Day

Freshwater

Effluent

Frequency of

Detection

Mass Loading

Classicals (mg/L) (mg/L) (mg/L) (lbs/yr)

Alkalinity 26 27 46 1 of 1 1,616

Ammonia as Nitrogen 0.17 1.3 0.6 1 of 1 41

Chemical Oxygen Demand (COD) 12 BDL 48 1 of 1 1,108

Chloride 20 63 34 1 of 1 2,078

Nitrate/Nitrite 0.62 0.68 0.4 1 of 1 23

Sulfate 21 22.8 17 1 of 1 861

Total Chlorine 1.2 0.028 BDL 1 of 1 0.58

Total Dissolved Solids 140 232 82 1 of 1 6,657

Total Kjeldahl Nitrogen 0.70 0.63 0.81 1 of 1 32

Total Organic Carbon (TOC) 2.70 2.7 25 1 of 1 633

Total Phosphorous 0.22 0.19 0.19 1 of 1 8.3

Total Recoverable Oil and Grease 1.0 BDL 1.0 1 of 1 23

Total Sulfide (Iodometric) 6 3.0 BDL 1 of 1 62

Volatile Residue 76 165 BDL 1 of 1 3,388

Metals (μg/L) (μg/L) (μg/L) (lbs/yr)

Aluminum

 Dissolved BDL 57.7 BDL 1 of 1 1.19

 Total 109 43.9 BDL 1 of 1 0.90

Arsenic

 Dissolved BDL 0.8 BDL 1 of 1 0.016

Barium

 Dissolved 35.5 27.5 25.6 1 of 1 1.16

 Total 36.2 28.10 26.3 1 of 1 1.19

Beryllium

 Dissolved BDL BDL 0.75 1 of 1 0.017

Boron

 Dissolved BDL 36.8 BDL 1 of 1 0.76

 Total BDL 37.5 BDL 1 of 1 0.77

Calcium

 Dissolved 15700 17050 19800 1 of 1 807

 Total 16000 16750 20400 1 of 1 815

Copper

 Dissolved 135 137 107 1 of 1 5.3

 Total 136 150 148 1 of 1 6.5

Lead

 Dissolved BDL BDL 3.45 1 of 1 0.08

 Total 2.3 2.0 4.75 1 of 1 0.15

Magnesium

 Dissolved 2720 6880 5185 1 of 1 261

 Total 2860 6890 5495 1 of 1 268

Manganese

 Dissolved BDL 19.7 276 1 of 1 6.8

 Total 6.3 21.8 310 1 of 1 7.6

Nickel

 Dissolved BDL 409 1175 1 of 1 35.6
Freshwater Layup

10

 Total BDL 433 1175 1 of 1 36.1

Selenium

 Dissolved BDL BDL 2.45 1 of 1 0.057

 Total BDL BDL 1.60 1 of 1 0.037

Sodium

 Dissolved 10500 39200 17800 1 of 1 1,216

 Total 10500 37550 21400 1 of 1 1,265

Thallium

 Dissolved BDL 0.75 BDL 1 of 1 0.015

 Total 1.3 BDL BDL 1 of 1 (a)

Tin

 Dissolved 5.1 BDL BDL 1 of 1 (a)

 Total 4.2 BDL 2.75 1 of 1 0.06

Zinc

 Dissolved 137 463 784 1 of 1 27.7

 Total 127 451 851 1 of 1 29

Organics (μg/L) (μg/L) (μg/L) (lbs/yr)

Bis(2-ethylhexyl) phthalate 137 BDL BDL 1 of 1 (a)

BDL - Denotes the below the detection for the method and instrument.

(a) No mass loadings are calculated for constituents that were not detected in either the 2-hour or 21-day freshwater

layup discharge.

Log normal means were calculated using measured analyte concentrations. When a sample set contained one or

more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations

equivalent to one-half of the detection levels were used to calculate the mean. For example, if a "non-detect" sample

was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log normal mean

calculation.
Freshwater Layup

11

Table 2: Estimated Annual Mass Loadings for Freshwater Layup Discharge

Analyte

2-hr Layup

Conc.

(μg/L)

Estimated

Mass

Loadings

(lbs/yr)

21-day Layup

Conc.

(μg/L)

Frequency

of

Detection

Estimated

Mass

Loadings

(lbs/yr)

Total Estimated

Loadings,

Freshwater Layup

(lbs/yr) Fleetwide

Annual Volume (gal/yr): 2,466,000 2,772,000

Copper

 Dissolved 137 2.8 107 1 of 1 2.5 5.3

 Total 150 3.1 148 1 of 1 3.4 6.5

Nickel

 Dissolved 409 8.4 1175 1 of 1 27.2 35

 Total 433 8.9 1175 1 of 1 27.2 36

Zinc

 Dissolved 463 9.5 784 1 of 1 18.7 27

 Total 451 9.3 851 1 of 1 19.7 29

Ammonia as Nitrogen 1300 27 600 1 of 1 14 41

Nitrate/Nitrite 680 14 400 1 of 1 9 23

Total Kjeldahl Nitrogen 630 14 810 1 of 1 18 32

Total NitrogenA1310 28 1210 27 55

Total Chlorine 28 0.58 - 1 of 1 - 0.58

Total Phosphorous 190 3.9 190 1 of 1 4.4 8.3

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Freshwater Layup

12

Table 3: Mean Concentrations of Constituents Exceeding Water Quality Criteria

Constituent 2-Hour Layup

Concentration

21-Day Layup

Concentration

Federal Acute

WQC

Most Stringent State

Acute WQC

Metals (μg/L)

Copper

 Dissolved 137 107 2.4 2.4 (CT, MS)

 Total 150 148 2.9 2.5 (WA)

Nickel

 Dissolved 409 1175 74 74 (CA, CT)

 Total 433 1175 74.6 8.3 (FL, GA)

Zinc

 Dissolved 463 784 90 90 (CA, CT, MS)

 Total 451 851 95.1 84.6 (WA)

Classicals (mg/L)

Ammonia as Nitrogen 1.3 0.6 None 0.006 (HI)A

Nitrate/Nitrite 0.68 0.4 None 0.008 (HI)A

Total Kjeldahl Nitrogen 0.63 0.81 None -

Total NitrogenB1.31 1.21 None 0.2 (HI)A

Total Chlorine 0.028 - None 0.010 (FL)

Total Phosphorous 0.19 0.19 None 0.025 (HI)A

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA = California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Freshwater Layup

13

Table 4. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

3Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents X X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Gas Turbine Water Wash

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Gas Turbine Water Wash
Gas Turbine Water Wash

2

2.0 DISCHARGE DESCRIPTION

This section describes the gas turbine water wash and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Shipboard gas turbine systems are used on certain vessels to provide propulsion power,

provide initial mechanical starting power for large gas turbine propulsion systems, and to

generate electricity. Power is generated by combusting fuel in a “gas generator” (commonly

referred to as a “combustor”). The combustor exhaust gas rotates the “power turbine,” providing

the mechanical energy to either drive a propulsion shaft, start a larger turbine, or generate

electricity.1

Over extended periods of operation, residual lubrication oil and hydrocarbon combustion

by-product deposits can form on gas turbine internals. Since naval vessels operate in a marine

environment, salt water introduced with intake air can also lead to salt deposits on the gas turbine

internals. Washing the gas turbine internals periodically with a solution of freshwater and

cleaning compound maintains operating efficiency and prevents corrosion of the metallic

components. The cleaning compound that is currently used for this purpose is a petroleum-based

solvent referred to as “gas path cleaner.”1

Two types of water wash systems exist on vessels with gas turbines. One is a dedicated

“hard-piped” system; the other type requires manual attachment of a hose to a hot water source

and placement of the other hose end into the turbine plenum. Both of these systems are designed

to introduce water wash into the turbine housing while the turbine starter motor is slowly rotated,

(i.e., cranked without combustion). The hard-piped system includes a rinse tank where

distilled/demineralized water and cleaning compound are mixed. The contents of the tank are

sprayed into the gas turbine under pressure, either by using a pump or by pressurizing the tank

with compressed air.1 Immediately following the wash, the engine is sprayed with water.

Gas turbine engines are enclosed in a “module” with floor drains designed to remove

minor leakage of fuel and synthetic lube oil that may occur during normal turbine operation. The

floor drains also remove any water wash introduced into the turbine that is not discharged to the

atmosphere. Water wash from external scrubbing of the gas turbine also flows to these floor

drains. Inadvertent spills of synthetic lube oil that occasionally occur during turbine maintenance

activities are potentially capable of entering the drains; however, standard procedure is for ship

personnel to immediately contain and wipe up any spillage that occurs.1

On most Navy ships, gas turbine water wash effluent and any drainage of residual

material from leaks and spills are collected and held in a dedicated tank system for shore

disposal. The Navy refers to this system as the “Gas Turbine Waste Drain Collecting System.”

The dedicated system includes a centrifugal pump and piping to transfer the water wash to a hose

connection topside. A hose is used to transfer the water wash to a pierside collection facility. On
Gas Turbine Water Wash

3

vessels without this system, the drainage is discharged to the environment as a component of

other UNDS discharges (i.e., Surface Vessel Bilgewater/OWS, Welldeck, and Deck Runoff).1

The wash water effluent discharge from U.S. Coast Guard (USCG) vessel gas turbine

washing operations is to the bilge, from where it is processed as bilgewater (along with other

bilgewater contributors) through the shipboard OWS prior to overboard discharge. The gas

turbine water wash effluent for USCG vessels is addressed as a component of the Surface Vessel

Bilgewater/OWS Discharge NOD Report.

Gas turbine propulsion engines are also used aboard Navy landing craft air cushion

(LCAC) amphibious landing crafts. Two gas turbine auxiliary power units (APUs) are also

installed on LCACs to provide starter air. The LCAC gas turbine washwater discharge is

addressed as a component of the Welldeck Discharges NOD Report.

Water wash cleaning of aircraft gas turbine engines aboard an aircraft carrier is addressed

as a component of the Deck Runoff NOD Report.

2.2 Releases to the Environment

The water wash introduced into Navy propulsion turbines contains water and solventbased gas path cleaner. The discharge could be expected to contain components of the cleaner,

oil and grease (O&G), petroleum-derived fuel and lubricant constituents, synthetic lubricating

oil, constituents introduced into the turbine system with the incoming sea air, hydrocarbon

combustion by-products, and metals leached from gas turbine components. On most gas turbine

Navy and MSC ships, gas turbine washwater is collected in a dedicated tank and not discharged

overboard within 12 n.m. On ships without a dedicated collecting tank, this discharge is a

component of deck Runoff, welldeck runoff, or bilgewater as described in the previous section.

2.3 Vessels Producing the Discharge

Table 1 lists the vessel classes that have shipboard gas turbine systems. Vessel classes

equipped with a Gas Turbine Waste Drain Collecting System are denoted in Table 1. For the

other vessel classes listed in Table 1, the gas turbine water wash is discharged as a component of

another UNDS discharge. The maximum number of vessels with Gas Turbine Waste Drain

Collecting System is 127. Army and Air Force vessels do not have gas turbine engines and do

not generate this discharge.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
Gas Turbine Water Wash

4

3.1 Locality

Vessels with Gas Turbine Waste Drain Collecting Systems collect and store drainage

from normal turbine operations and water wash effluent for pierside disposal. On most gas

turbine Navy and MSC ships, gas turbine washwater is collected in a dedicated collecting tank

and not discharged overboard within 12 n.m. On ships without a dedicated collecting tank, this

discharge is a component of deck Runoff, welldeck runoff, or bilgewater as described in the

previous section.

3.2 Rate

Available information on gas turbine water wash usage rates is contained in gas turbine

design and operations and maintenance documentation.2,3,4 The frequency of water wash

cleanings and the quantity of water wash consumed per washing event is different between

USCG, Navy, and Military Sealift Command (MSC) vessels.

Navy and MSC vessel gas turbines used for propulsion are washed after each 48 hours of

operation or at least once per month.5 Two gallons of the gas path cleaner are initially mixed

with 38 gallons of distilled/demineralized water. Immediately following the wash, the turbine is

spray rinsed with 80 gallons of water. An additional 2 gallons of detergent/water mixture is used

to clean external turbine surfaces, as necessary. Each cleaning of the propulsion turbines

produces 122 gallons of water wash. Therefore a vessel with four propulsion gas turbines each

cleaned once every 48 hours of operation would generate an average of 244 gallons of water

wash per day.

3.3 Constituents

The chemicals used in gas turbine operation and maintenance that could potentially

contribute to contamination of turbine water wash are gas path cleaner, Naval distillate fuel F-76,

gas turbine fuel, JP-5, synthetic lube oil, copper, cadmium, and nickel.6-10

The gas path cleaners used by the Navy include petroleum distillates (aromatic and

aliphatic hydrocarbons), assorted glycols, detergents, soaps, and water.6,7 The composition of

one such cleaner used by the Navy can be found in its material safety data sheet (MSDS).6

According to the MSDS sheet, the cleaner can contain the aromatic hydrocarbon naphthalene at

concentrations of up to 3.9%. Other petroleum distillate hydrocarbon constituents that could be

present include aliphatic volatile organic compounds and other semivolatile compounds that are

priority pollutants. The priority pollutants that are potential constituents of gas turbine water

wash are cadmium, copper, nickel, and naphthalene. None of the constituents is a

bioaccumulator.

3.4 Concentrations

The addition of gas path cleaner containing 3.9% naphthalene to the wash water at a 2%

gas path cleaner concentration yields an estimated water wash naphthalene concentration of 800
Gas Turbine Water Wash

5

milligrams per liter (mg/L). The following shows this calculation.

Because naphthalene is a semivolatile organic compound that is not expected to volatilize

while the water wash is sprayed into the turbine, the maximum water wash effluent naphthalene

concentration is also estimated at 800 mg/L. Other constituents are variable and were not

estimated.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The water wash volume estimate for a Navy ship propulsion turbine cleaning operation

and naphthalene concentration estimate of 800 mg/L were used to estimate the maximum annual

mass loading. The estimate is based on the assumption that one turbine cleaning for each vessel

is performed each day within 12 n.m.

The mass loading of O&G that can be introduced into the water wash effluent from

within the gas turbine depends on (a) the amount of residue present; and (b) the degree to which

the water wash spray removes the residue as it passes through the turbine.

4.2 Environmental Concentrations

Naphthalene Concentration (mg/L) =

(% of cleaner in water)(% of naphthalene in cleaner)(density of naphthalene)

where,

% of cleaner in water = 2

% of naphthalene in cleaner = 3.9

density of naphthalene = (1.0253 g/cm3)(1000 mg/g)(1000 cm3/L) = 1.025 * 106 mg/L

Naphthalene Concentration = (0.02)(0.039)(1.025 * 106) = 800 mg/L

Mass Loading of Naphthalene (lbs/yr) =

(naphthalene conc.)(discharge vol.)(365 days/yr)(# vessels) (3.7854 L/gal) (2.2 lb/kg) (10-6 kg/mg)

(800 mg/L)(244 gal/day)(365 days/yr)(127)(3.7854 L/gal)(2.2 lb/kg)(10-6 kg/mg) = 75,400 lbs/yr
Gas Turbine Water Wash

6

Table 2 shows that the estimated naphthalene concentration exceeds the most stringent

state water quality criteria (WQC) for naphthalene. Concentrations of oil and grease are

expected to exceed WQC because the source of this discharge (gas turbine cleaning) is designed

to dissolve fuel, lubricant, and other hydrocarbon deposits.

4.3 Potential for Introducing Non-Indigenous Species

There is no potential of introduction, transport, or release of non-indigenous species

between different geographical areas, because the water wash system does not use seawater and

therefore does not involve the discharge of seawater originating in another geographical region.

5.0 CONCLUSIONS

If discharged, gas turbine water wash has the potential to cause an adverse environmental

effect within 12 n.m. because:

1) Estimated concentrations of naphthalene exceed and the most stringent state WQC

and the mass loading of this priority pollutant would be significant; and

2) Concentrations of oil and grease are expected to be significant because the source of

this discharge (gas turbine cleaning) is designed to dissolve fuel, lubricants and other

deposits.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from the following sources was obtained to

develop this NOD report. Table 3 shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes. June, 20, 1997.

2. Uniform Maintenance Procedure Card (MPC), WAGB 400 Main Gas Turbine, MPC MC-062, Amendment 3.

3. Uniform Maintenance Procedure Card (MPC), WHEC 378 Main Gas Turbine, MPC MC-017, Amendment 0.

4. Uniform Maintenance Procedure Card (MPC), WHEC 378 Emergency Generator, MPC

A-W-001, Amendment 0.

5. Maintenance Requirement Card (MRC), OPNAV 4790 (Rev. 2-82).
Gas Turbine Water Wash

7

6. Gas Path Cleaner Material Safety Data Sheet, supplied by M. Galecki of DDG 51 Flight

Upgrade Office via facsimile to Malcolm Pirnie (C. Geiling) on June 12, 1997.

7. Military Specification MIL-C-85704, “Cleaning Compound, Turbine Engine Gas Path”.

8 Military Specification MIL-F-16884, “Fuel, Naval Distillate”.

9. Military Specification MIL-F-5624, “Turbine Fuel, Aviation, Grades JP-4, JP-5, and JP10. Military Specification MIL-L-23699, “Lubricating Oil, Aircraft Turbine Engine,

Synthetic Base, NATO Code Number 0-156”.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
Gas Turbine Water Wash

8

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Gas Turbine Water Wash

9

Table 1. Vessels With Gas Turbine Systems

Branch Class No. Vessel Type Comment

Navy AOE 6 3 Fast Combat Support Ship Dedicated collection system

CG 47 27 Guided Missile Cruiser Dedicated collection system

DD 963 31 Destroyer Dedicated collection system

DDG 51 18 Guided Missile Destroyer Dedicated collection system

DDG 993 4 Guided Missile Destroyer Dedicated collection system

FFG 7 43 Guided Missile Frigate Dedicated collection system

MCM 1 14 Mine Countermeasure Vessel Unknown configuration

MSC T-AKR 310 1 Fast Sealift Ship Dedicated collection system

USCG WAGB 399 2 Icebreaker Discharged to bilge

WHEC 378 12 High Endurance Cutter Discharged to bilge

No. = number of vessels in class

Table 2. Comparison of Gas Turbine Water Wash

Estimated Concentration and Water Quality Criteria (μg/L)

Constituent Maximum Estimated

Concentration

Federal Acute

WQC

Most Stringent State

Acute WQC

Naphthalene 800,000 None 780 (HI)

Notes:

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

HI = Hawaii

Table 3. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

Equipment Literature X

2.2 Releases to the Environment OPNAVINST 5090.1B X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate Standard Operating

Procedures

X X

3.3 Constituents MSDS X X

3.4 Concentrations MSDS X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous Species

X
Graywater

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Graywater
Graywater

2

2.0 DISCHARGE DESCRIPTION

This section describes the graywater discharge and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Graywater is defined in section 312(a) of the Clean Water Act as wastewater from

showers, baths and galleys. On vessels of the Armed Forces, drainage from laundry, interior

deck drains, lavatory sinks, water fountains, and miscellaneous shop sinks is often collected

together with graywater. Therefore, this discharge covers graywater as well as mixtures of

graywater with wastewater from these additional sources.1 In this report, the term “graywater”

will be used to describe all of these related discharges. Graywater is distinct from “blackwater”,

the sewage generated by toilets and urinals.

While pierside, most classes of Navy vessels direct graywater to the vessel’s blackwater

Collection, Holding, and Transfer (CHT) tanks, via segregated graywater plumbing drains. Some

recently built ships (such as CVN 73 and CVN 74) do not have segregated blackwater/graywater

drains. These ships collect the blackwater/graywater mixture while inside 3 nautical miles

(n.m.). The blackwater and graywater mixture is then pumped to pierside connections for

treatment ashore. A typical CHT system is shown in Figure 1. Most navy surface vessels

without CHT systems have dedicated graywater tanks and pumps to collect and transfer this

discharge to shore facilities. Some vessels lack the means to collect all the graywater that is

generated while pierside. On these vessels a portion of the graywater plumbing drains run

directly overboard.1-4

While operating away from the pier, most Navy surface vessels that collect graywater in

CHT tanks divert graywater drains overboard to preserve holding capacity for blackwater in the

tanks. Vessels equipped with separate graywater collection and transfer systems are not designed

to hold graywater for extended periods of time and therefore drain or pump their graywater

overboard while operating away from the pier.

Submarines collect their graywater in the ship’s sanitary tank while pierside and within 3

n.m. of land. Pierside, graywater mixed with blackwater is discharged to a shore facility for

treatment; when outside 3 n.m., graywater is discharged directly overboard. Unlike surface

vessels, holding capacity in the submarines’ sanitary tanks is generally sufficient to allow

collection of graywater and blackwater up to 12 n.m. from shore.1

All Military Sealift Command (MSC) vessels are equipped with U.S. Coast Guard

(USCG) certified Marine Sanitation Devices (MSDs) designed to treat sewage to EPA and

USCG standards. On some MSC vessels, graywater can be collected and sent to the MSD for

processing, or diverted overboard. On other MSC vessels, graywater is neither collected nor

treated, but is discharged directly overboard.
Graywater

3

Most USCG vessels are similar to Navy vessels since they can collect graywater while

pierside. However, some USCG vessels currently cannot collect graywater, but continually

discharge it overboard.

The majority of Army vessels collect graywater together with blackwater (sewage)∗ for

treatment by a USCG certified MSD. The MSD effluent is either sent overboard, held in an

effluent holding tank, or discharged to a shore facility.

2.2 Releases to the Environment

Contributions to graywater are described below. Three sources comprise the majority of

graywater flow: Galley and scullery (18% in port, 22% at sea); laundry (22% in port, 33% at

sea); and showers and sinks (60% in port and 45% at sea).5 In addition, other minor sources

include: filter cleaning discharges, deck drains, and medical/dental waste discharges.1

2.2.1 Galley

Food preparation occurs in a vessel’s galley. Large Navy vessels have several galley

compartments. In smaller vessels, the galley can be a shared space with related functions (e.g.,

the scullery), and have a single sink through which wastewater is discharged. Galley discharges

specifically exclude food/garbage grinder wastes. Garbage grinders are required to be secured

inside 3 n.m.6

Wastewater from the galley is generated through food preparation, disposal of cooking

liquids, and cleaning of surfaces (bulkheads, appliances, sinks, and working surfaces). The

generation and discharge are periodic, with the majority of the flow occurring during the hours

preceding meal times. Galley graywater can contain highly biodegradable organics, oil and

grease, and detergent residuals.

2.2.2 Scullery

The scullery can be separate from or integral with the galley and is used for the cleaning

of dishes and cookware. Scullery wastewater also specifically excludes garbage grinder wastes,

as garbage grinders are required to be secured inside 3 n.m.

6

 Scullery graywater can contain food

residuals and detergents.

2.2.3 Showers and Lavatory Sinks

Lavatory sinks and showers drain to the vessel’s graywater system and can contain soap

residues, shampoos, shaving cream, and other products resulting from personal hygiene.

Detergent residuals similar to those used in the galley can also be present.

2.2.4 Laundry

 

∗

 The Army usually refers to bilgewater as “blackwater” and sewage as “sewage”.
Graywater

4

Graywater derived from laundering crew uniforms, linens, and other articles of clothing

can contain laundry detergents, bleaches, oils and greases, and traces of other constituents.

Detergent residuals similar to those used in the galley, lavatory sinks, and showers can also be

present.

2.2.5 Other Discharges

Other minor discharges which are collected with graywater include filter cleaning

discharges, deck drains, and medical/dental waste discharges. These discharges combined

represent less than 1% of the total shipboard generated graywater.5 Filter cleaning discharges

consist of detergents and small amounts of oil from commercial dishwashing machines or sinks

used to wash ship ventilation system air filters. Deck drains contribute small and intermittent

flows which can include detergents used for floor cleaning and other general space cleaning.

Small amounts of medical/dental wastes are collected with graywater on only a few Navy ships

with extensive medical and dental facilities such as aircraft carriers (CV/CVNs) and amphibious

assault ships (LHD/LHA/LPHs). This would include wastes from dental spit sinks and small

blood samples less than 7.5 milliliters (mL).7

2.3 Vessels Producing the Discharge

Vessels in the Navy, MSC, Army, Air Force, and USCG generate graywater. However,

there are some vessels that do not produce a separate and distinct graywater discharge. These are

the vessels not equipped with segregated graywater collection systems. Instead, they collect

graywater together with blackwater for combined treatment with a MSD.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Discharges of graywater incidental to normal operations occur under three circumstances:

(1) at the pier, for the ship classes lacking the means to collect graywater for shore treatment; (2)

between 0 and 3 n.m. for most Navy and USCG vessels and for some MSC vessels; and (3)

outside 3 n.m., where most graywater is discharged overboard.

3.2 Rate

The Navy uses a design figure of 30 gallons per capita-day (gal/cap/day) when designing

graywater collections systems.8
Graywater

5

Table 1 presents estimates of discharge rates by vessel class for Navy, MSC, USCG, and

Army ships. The following assumptions are inherent in the table:

• With the few exceptions noted in Section 2.1 and 2.3, vessels discharge graywater overboard

at all times when not pierside. It is assumed, for purposes of calculation, that USCG, MSC,

and Army vessels also discharge graywater overboard at all times when not pierside.

• A typical vessel is estimated to require about four hours to transit 12 n.m. from shore, with a

per capita average rate of 1.25 gallons/hour (30 gal/cap/day). If this vessel undergoes 20

transits a year and has a crew size of 400, the annual graywater discharge rate while in transit

would be:

(20 transits/year) (4 hours/transit) (1.25 gal/capita-hour) (400 personnel) = 40,000 gallons/year

Some vessels of the USCG and Army operate on a routine basis within 12 n.m. of shore.

Annual graywater discharge rate calculations for these vessels are based, in part, on the number

of days each ship operates within 12 n.m. A vessel’s graywater discharge that results from

operating within 12 n.m. is calculated by using the following general formula:

(personnel) (hours in operation/year) (1.25 gal/capita-hour) = gallons/year

USCG vessels that operate within 12 n.m. include: Mackinaw Class Icebreakers (approx.

150 days/year, 24 hours/day), Bay Class Icebreaking Tugs (approx. 150 days/year, 24 hours/day),

and Balsam Class Seagoing Buoy Tenders (approx. 100 days/year, 24/hours/day). Army vessels

that operate within 12 n.m. include: Logistic Support Vessels (approx. 30 days/year, 10

hours/day) and Landing Craft Utility (approx. 60 days/year, 10 hours/day). Due to the fact that

the majority of Army vessels collect most of their graywater with blackwater, approximately only

10% of the graywater generated is discharged separately.9

As shown in Table 1, the total estimated amount of graywater discharged overboard

annually inside 12 n.m. is 39 million gallons. Of that volume, 15.3 million gallons are

discharged pierside.

3.3 Constituents

In graywater, soaps, shampoos, detergents, and cleaners contribute organics as well as

inorganic compounds such as nitrogen and phosphorous. Food waste will contribute oxygen

demand (as measured by Biochemical Oxygen Demand (BOD) and Chemical Oxygen Demand

(COD)), nutrients, and oil and grease. Metals, pesticides, and organics from adhesives, sealants,

lubricants, and cleaners can also be present in graywater. The constituents that have been

measured in previous graywater studies are shown in Tables 2 and 3. The priority pollutants
Graywater

6

cadmium, chromium, copper, lead, nickel, silver, and zinc were identified. Mercury, a

bioaccumulator, was also identified. It is possible that certain parameters not tested for, and thus

not listed in Tables 2 and 3, could also be present in graywater.

3.4 Concentrations

Table 2 shows the average values measured for classical water quality parameters in

various shipboard streams that contribute to graywater based on samples collected from three

classes of vessels. Data are shown for the following graywater discharge components: wash

basins and showers, food preparation, laundry, and dishwasher and deep sink. The ranges of the

average measured values are: pH (6.74 - 10), total suspended solids (TSS)(94 - 4,695 milligrams

per liter (mg/L)), total dissolved solids (TDS)(225 - 8,064 mg/L), BOD (144 - 2618 mg/L), COD

(304 - 7,839 mg/L), total organic carbon (TOC)(59 - 1,133 mg/L), oil and grease (5 - 1,210

mg/L), methylene blue active substances (MBAS) (0.1 - 4.1 mg/L), ammonia nitrogen (0.17 -

669 mg/L), phosphate (1.03 - 28.2 mg/L), and coliform bacteria (178 - >2,000,000 per 100 mL).

Flow-weighted average concentrations of these constituents are calculated in Table 2, based upon

the data presented therein and the relative contribution of the three major sources of graywater.

Table 3 shows the mean concentrations of metals in various graywater components based

on samples collected from three classes of vessels. Data are shown for the following graywater

components: potable water sink, galley drains, sink, and scullery. The ranges of the average

measured values are: silver (.007 - 0.012 mg/L), cadmium (0.004 - 0.017 mg/L), chromium

(0.002 - 0.03 mg/L), copper (0.25 - 3.4 mg/L), lead (0.042 - 1.56 mg/L), mercury (.0002 - .0095

mg/L), nickel (0.025 - 0.113 mg/L), and zinc (0.19 - 2.36 mg/L). Flow-weighted average

concentrations of these metals are calculated in Table 3, based upon the data presented therein

and the relative contribution of graywater sources involved.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Total flow, and therefore mass loadings, are influenced by the number of personnel

aboard, time spent in transit, and time spent operating within 12 n.m. Total loadings can be

estimated by multiplying concentration data by the total annual flow of graywater. Based on

typical constituent concentrations and the estimated total flow calculated in Table 1, annual

loadings of constituents are presented in Table 4.

4.2 Environmental Concentrations
Graywater

7

Screening for constituents was accomplished by comparing measured levels of

constituents to the lowest applicable water quality criteria. For graywater, the only constituents

for which both data and water quality criteria are available are metals. Parameters such as BOD

and nutrients are at levels that would be expected to cause localized adverse environmental

effects.

As shown in Table 5, concentrations of the priority pollutants copper, lead, nickel, silver,

and zinc (measured as total metals), in one or more graywater components, exceed the most

stringent water quality criteria. The bioaccumulator, mercury, exceeds the most stringent water

quality criteria. Ammonia also exceeds the most stringent water quality criteria.

4.3 Potential for Introducing Non-Indigenous Species

Graywater originates from potable water rather than seawater. Therefore, the potential

for introduction of non-indigenous species is not significant.

5.0 CONCLUSIONS

Graywater has the potential to cause adverse environmental effects because measured

concentrations and estimated loadings of nutrients and oxygen-demanding substances are

significant.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information and assumptions were used to estimate the rate of discharge. Based on this estimate

and on the reported concentrations of constituents, the mass loadings to the environment

resulting from this discharge were then estimated. Table 6 shows the source of the data used to

develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Graywater Discharge. 29 July 1996.

2. Aivalotis, Joyce, USCG. Personal Communication: USCG Photo Labs/Film Processing

and X-ray Capabilities, 14 April 1997, David Eaton, M. Rosenblatt & Son, Inc.

3. Aivalotis, Joyce, USCG. Personal Communication: USCG Ship Description for

Medical/Dental Waste Discharge, 14 April 1997, David Eaton, M. Rosenblatt & Son, Inc.

4. Cassidy, Brian. “Zero Discharge Study.” February 1996.
Graywater

8

5. Whelan, Mary. “Graywater Characterization.” TM-28-89-01. March 1989.

6. Naval Ship’s Technical Manual (NSTM), Chapter 593, Pollution Control (Revision 3),

page 2-2. 1 September 1991.

7. UNDS Equipment Expert Meeting Minutes - Medical/Dental Waste Discharges. 15

October 1996.

8. NAVSEA Design Practices and Criteria Manual for Surface Ship Freshwater Systems,

Chapter 532. NAVSEA T9500-AA-PRO-120. October 1987.

9. SSG Huckabee, U.S. Army 7th Transportation Group, Fort Eustis. Personal

Communication: Information on Army Vessels’ Graywater Discharge, 16 March 1998,

Russell Fisher, Booz, Allen & Hamilton.

10. UNDS Ship Database, August 1, 1997.

11. Pentagon Ship Movement Data for Years 1991 - 1995, Dated March 4, 1997.

12. Talts, A. and D. R. Decker. Naval Ship Research and Development Center. “Nonoily

Aqueous Waste Streams on the USS Sierra (AD18), Volume 1.” Bethesda, Maryland.

Report 4182, April 1974.

13. Naval Ship Research and Development Center. “Nonoily Aqueous Waste Streams on

USS Seattle (AOE 3), Volume I.” Bethesda, Maryland. Report 4192, June 1974.

14. Van Hees, W., D. R. Decker, and A. Talts. Naval Ship Research and Development

Center. “Nonoily Aqueous Waste Streams on USS O’Hare (DD 889), Volume I.”

Bethesda, Maryland. Report 4193, June 1974.

15. Attachment to Letter, Commander, Carderock Division, Naval Surface Warfare Center,

Philadelphia, PA., 9593 Ser 6222/291, December 6, 1993, “Investigation of Metals From

Industrial Processes, Intake Waters & Pipe Corrosion Onboard U.S. Navy Vessels at

Norfolk Naval Base, Norfolk, VA.,” November 22 1993.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.
Graywater

9

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Graywater

10

Table 1. Ships of the Navy, MSC, USCG, and Army; Annual Graywater Discharge

Class Description Vessels10 Crew

Size

Transits

per

Year11

Estimated

Total Time

in Transit

(hr)

Graywater

Discharge, in

Transit

(gal/yr)

Vessels

Discharging

Overboard

at Pier

Days in

Port, per

year11

Graywater

Discharged

Pierside

(gal/yr)

Total Graywater

Generation, 0 to

12 n.m.

(gal/year)

Total

Discharge, 0

to 12 n.m.

(gal/yr)

Navy Ships

CG 47 Ticonderoga Class Cruiser 27 409 24 96 1,325,160 1,325,160 1,325,160

CGN 36 California Class Guided Missile Cruiser 2 603 22 88 132,660 132,660 132,660

CV 62 Forrestal Class Aircraft Carrier 1 5,624 6 24 168,720 168,720 168,720

CVN 65 Enterprise Class Aircraft Carrier 1 5,815 12 48 348,900 348,900 348,900

CV 63 Kitty Hawk Class Aircraft Carrier 3 5,624 14 56 1,181,040 1,181,040 1,181,040

CVN 68 Nimitz Class Aircraft Carrier 7 6,286 14 56 3,080,140 3,080,140 3,080,140

CGN 40 Virginia Class Guided Missile Cruiser 1 600 22 88 66,000 66,000 66,000

DDG 993 Kidd Class Guided Missile Destroyers 4 386 24 96 185,280 185,280 185,280

DDG 51 Arleigh Burke Class Guided Missile Destroyers 18 303 22 88 599,940 599,940 599,940

DD 963 Spruance Class Destroyers 31 396 24 96 1,473,120 4 175 1,663,200 3,136,320 3,136,320

FFG 7 Oliver Hazard Perry Guided Missile Frigates 43 220 26 104 1,229,800 1,229,800 1,229,800

LCC 19 Blue Ridge Class Amphibious Command Ships 2 1,516 16 64 242,560 242,560 242,560

LHD 1 Wasp Class Amphibious Transport Docks 4 3,151 26 104 1,638,520 1,638,520 1,638,520

LHA 1 Tarawa Class Amphibious Assault Ships 5 2,292 18 72 1,031,400 4 173 9,516,384 10,547,784 10,547,784

MCS 12 Iwo Jima Class Assault Ships 2 1,746 18 72 314,280 314,280 314,280

LPD 4 Austin Class Amphibious Transport Docks 3 1,487 22 88 490,710 490,710 490,710

LSD 41 Whidbey Island Class Dock Landing Ships 8 852 26 104 886,080 886,080 886,080

LSD 36 Anchorage Class Dock Landing Ships 5 794 26 104 516,100 516,100 516,100

MCM 1 Mine Countermeasures Ship Avenger Class 14 72 56 224 282,240 282,240 282,240

MHC 51 Mine Countermeasures Ship Osprey Class 12 50 50 200 150,000 150,000 150,000

PC 1 Cyclone Class Coastal Defense Ships 13 4 36 144 9,360 9,360 9,360

SSN 640 Benjamin Franklin Class Attack Submarines 2 120 16 64 0 19,200 0

SSN 671 Narwhal Class Attack Submarine 1 129 16 64 0 10,320 0

SSN 688 Los Angeles Class Attack Submarines 56 120 16 64 0 537,600 0

SSN 637 Sturgeon Class Attack Submarines 13 107 16 64 0 111,280 0

SSBN 726 Ohio-Class Ballistic Missile Submarines 17 136 16 64 0 184,960 0

Navy Auxiliary Ships

AE 28 Kilauea Class Ammunition Ships 8 383 8 32 122,560 26 477,984 600,544 600,544

AO 177 Cimarron Class Oilers 12 135 20 80 162,000 188 1,827,360 1,989,360 1,989,360

AOE 6 Supply Class Fast Combat Support Ships 3 667 12 48 120,060 120,060 120,060

AOE 1 Sacramento Class Fast Combat Support Ship 4 601 22 88 264,440 264,440 264,440

ARS 50 Safeguard Class Savage Ships 4 90 44 176 79,200 79,200 79,200

AS 36 LY Spear and Emory S Land Class Submarine Tenders 3 604 10 40 90,600 90,600 90,600

AS 33 Simon Lake Class Submarine Tenders 1 915 12 48 54,900 54,900 54,900

Military Sealift Command

T-AE Kilauea Class Ammunition Ships 8 187 40 160 299,200 45 403,920 703,120 703,120

T-AFS Mars Class Combat Stores Ships 5 135 40 160 135,000 135,000 135,000

T-AFS Sirius Class Combat Stores Ships 3 165 40 160 99,000 99,000 99,000
Graywater

11

T-ATF Powhatan Class Fleet Ocean Tugs 7 23 40 160 32,200 32,200 32,200

T-AO Henry J Kaiser Class Oilers 12 137 40 160 328,800 45 443,880 772,680 772,680

T-AGM Haskell Class Missile Instrumentation Ship 1 124 40 160 24,800 24,800 24,800

T-AGM Compass Island Class Missile Instrumentation Ship 1 143 40 160 28,600 28,600 28,600

T-AH Mercy Class Hospital Ships 2 1,275 4 16 51,000 51,000 51,000

T-ARC Zeus Class Cable Repairing Ship 1 126 40 160 25,200 25,200 25,200

T-AKR Selandia Class Fast Sealift Ships 3 90 40 160 54,000 54,000 54,000

T-AKR Bob Hope Class Fast Sealift Ships 8 90 40 160 144,000 144,000 144,000

T-AGOS Stalwart Class Ocean Surveillance Ship 4 33 40 160 26,400 26,400 26,400

T-AGOS Victorious Class Ocean Surveillance Ship 4 34 40 160 27,200 27,200 27,200

T-AG Navigation Research Ship 2 204 40 160 81,600 81,600 81,600

T-AGS Silas Bent Class Surveying Ships 2 65 40 160 26,000 26,000 26,000

T-AGS Waters Class Surveying Ships 1 95 40 160 19,000 19,000 19,000

T-AGS McDonnel Class Surveying Ships 2 33 40 160 13,200 13,200 13,200

T-AGS Pathfinder Class Surveying Ships 4 52 40 160 41,600 41,600 41,600

T-AGOR Gyre Class Oceanographic Research Ships 1 32 40 160 6,400 6,400 6,400

T-AGOR Thompson Class Oceanographic Research Ships 2 59 40 160 23,600 23,600 23,600

U.S. Coast Guard

WHEC Hamilton and Hero Class High Endurance Cutters 12 176 26 104 274,560 274,560 274,560

WMEC Storis Class Medium Endurance Cutters 1 92 18 72 8,280 167 92,184 100,464 100,464

WMEC Diver Class Medium Endurance Cutters 1 136 18 72 12,240 98 79,968 92,208 92,208

WMEC Famous Class Medium Endurance Cutters 13 98 18 72 114,660 114,660 114,660

WMEC Reliance Class Medium Endurance Cutters 16 71 18 72 102,240 102,240 102,240

WAGB Mackinaw Class Icebreakers* (150 d, 24 hr/d) 1 85 (3600) (382,500) 150 76,500 459,000 459,000

WAGB Polar Class Icebreakers 2 140 8 32 11,200 11,200 11,200

WTGB Bay Class Icebreaking Tugs* (150 d, 24 hr/d) 9 17 (3600) (688,500) 8 7,344 695,844 695,844

WPB 110 110' Class Patrol Craft 49 10 14 56 34,300 140 411,600 445,900 445,900

WLB Juniper Class Seagoing Buoy Tenders 1 40 36 144 7,200 7,200 7,200

WLB Balsam Class Seagoing Buoy Tenders* (100 d, 24 hr/d) 24 53 (2400) (3,816,000) 3,816,000 3,816,000

WIX Eagle Class Sail Training Cutter 1 245 12 48 14,700 188 276,360 291,060 291,060

U.S. Army **

LSV Logistic Support Vessel* (30 d, 10 hr/d) 6 32 40 160 (300) 3,840

(+7,200)

110,400 11,040

LCU Landing Craft Utility* (60 d, 10 hr/d) 48 13 6 24 (600) 1,872

(+46,800)

486,720 48,672

Total Volume (Gallons): 18,311,950 15,276,684 39,936,114 38,535,346

Notes:

Values in italics are estimated.

At-pier discharge presented only for classes without or with inadequate capability to capture graywater for shore treatment

At-pier discharge based on 20% occupancy by crew.

* Vessel classes that operate within 12 n.m. of U.S. shore on a routine basis (days of operation within 12 n.m. per year and hours per day)

** The majority of Army vessels collect graywater with blackwater. Approximately 10% of the graywater generated is discharged separately.9
Graywater

12

Table 2. Classicals Concentration in Graywater (mg/L)12-14 (Arithmetic Average)

Parameter DD 889 Wash

Basins and

Showers14

DD 889

Comb. Food

Prep14

DD 889

Laundry14

AOE 3 Wash

Basins and

Showers13

AOE 3

Dishwasher and

Deep Sink13

AOE 3

Laundry13

AD 18 Wash

Basins and

Showers12

Galley

Weighted

Average

Sink and Shower

Weighted

Average

Laundry

Weighted

Average

Flow

Weighted

Average**

No. Samples 114 134 28 7 60 20 91

pH 7.3 6.88 9.99 7.12 6.74 8.33 6.86

TSS 404 4,695 221 94 194 176 119 3303 271.4 202.3 802

TDS 1,445 8,064 1,006 237 752 583 225 5803 881.4 829.8 1756

BOD 230 2,618 419 226 503 190 144 1964 193 323.6 540

COD 348 7,839 721 509 2,380 469 304 6150 334.4 616 1443

TOC 70 1,133 165 82 251 59 - 860 70.7 120.8 224

Oil & grease 12.06 1,210 8.11 20.65 82.46 4.56 - 861.3 12.6 6.6 164

MBAS * 0.96 0.09 0.84 0.12 0.14 4.12 - 0.11 0.9 2.2 1.1

N-ammonia 15.4 669 80.48 0.58 0.64 0.17 - 462.3 14.5 47 102.3

N-nitrate 2.73 10.85 1.16 0.89 2.08 0.29 - 8.1 2.6 0.8 3.2

N-nitrite - - - 0.09 0.11 - - - - - -

N-Kjeldahl 187 99.84 164 4.31 4.84 0.43 - 70.5 176.4 95.8 140

P (phosphate) 1.36 20.78 1.3 1.03 6.34 28.25 - 16.3 1.3 12.5 6.5

Total coliforms

(microorg/100mL)

707,000 257,000 178 8,300 2,360,000 3,890 60,600 907,412 406,466 1725 407,593

Fecal coliforms

(microorg/100mL)

178,000 103,000 - 200 1,250,000 21,000 7,900 457,742 99,115 - 141,862

(-) no data reported for this parameter

(*) MBAS - Methylene Blue Active Substances

(**) Weighted averages for galley, showers/sinks, and laundry based on data presented herein. Flow-weighted average for graywater based on in-port contribution of

major graywater sources (galley 18%, showers/sinks 60%, and laundry 22% of total)5
Graywater

13

Table 3. Metals Concentrations in Graywater (mg/L)15 (Mean Values)

Metal

(total)

CVN 73 Potable

Water Sink15

CVN 73 Galley

Drains15

AS 39

Sink15

AD 38 Scullery15 Galley

Weighted

Average

Sink & Shower

Weighted

Average

Flow-Weighted

Average

No. Samples 12 13 8 11

Cadmium 0.004 0.017 0.005 0.004 0.011 0.004 0.006

Chromium* 0.002 0.03 0.007 0.01 0.01 0.004 0.005

Copper 0.754 3.404 0.443 0.250 1.96 0.630 0.936

Lead 0.042 1.560 0.047 0.182 0.928 0.044 0.247

Mercury 0.0003 0.0004 0.0002 0.0095 0.0046 0.0003 .0013

Nickel 0.037 0.113 0.025 0.031 0.075 0.032 0.042

Silver 0.007 0.012 0.008 0.011 0.012 0.007 0.008

Zinc 0.194 2.363 0.305 0.216 1.38 0.238 0.501

Note:

(*) Sample readings below the lower detection limit for chromium were treated as zero. For all the other metals listed above, when samples were measured at <

LDL, the LDL was used in calculating the average.

(**) Weighted averages for galley and showers/sinks based on data presented herein. Flow-weighted average for graywater based on in-port contribution of

graywater sources (galley 23%, showers/sinks 77% of total)
Graywater

14

Table 4. Mass Loadings of Constituents*

Parameter Flow-Weighted Average

Concentration (mg/L)

Loading (lb/yr.)

Copper 0.936 304

Lead 0.247 80.3

Mercury 0.0013 .423

Nickel 0.042 13.7

Silver 0.008 2.60

Zinc 0.501 163

TSS 802 260,900

BOD 540 175,600

COD 1443 469,400

Oil and Grease 164 53,340

MBAS 1.1 358

N-Ammonia 102 33,180

N-NO3 3.2 1,040

N- Kjeldahl 140 45,540

P- Phosphate 6.5 2110

* Based on flow-weighted average constituent concentrations. See Tables 2 and 3.
Graywater

15

Table 5. Comparison of Graywater Concentration Data Versus Acute Water Quality

Criteria (μg/L)

Parameter Concentration* Federal Acute

WQC

Most Stringent State Acute

WQC (State)

Ammonia 102 None 6 (HI)A

Copper 3,404 2.4 2.4 (CT, MS)

Lead 1,559 210 5.6 (FL, GA)

Mercury** 9.5 1.8 0.025 (FL, GA)

Nickel 113 74 8.3 (FL, GA)

Silver 12 1.9 1.2 (WA)

Zinc 2,363 90 84.6 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

A - Nutrient criteria are not specified as acute or chronic values.

CT = Connecticut

FL = Florida

GA = Georgia

MS = Mississippi

WA = Washington

(*) Highest concentration for any individual component from Table 3.

(**) Bioaccumulator

Table 6. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate Data call

responses

X

3.3 Constituents X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous Species

X
Graywater

16

Figure 1. A Typical Collection, Holding, and Transfer System
Hull Coating Leachate

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Hull Coating Leachate
Hull Coating Leachate

2

2.0 DISCHARGE DESCRIPTION

This section describes the hull coating leachate discharge and includes information on the

coating systems used and how they function (Section 2.1), a general description of the

constituents of the discharge (Section 2.2), and the vessels that produce this discharge (Section

2.3).

2.1 System Description and Operation

Underwater hull coating systems typically include a base anticorrosive (AC) coating

covered by an antifouling (AF) coating. The function of the AC coat, in conjunction with

cathodic protection (described in the Cathodic Protection NOD report), is to prevent hull

corrosion. The AC coat also provides bonding between the hull and the AF topcoats. Since the

AC coating is not exposed directly to the seawater, unless the AF coating has been damaged, the

AC coatings do not leach. The AF topcoat inhibits the development of marine growth on the

hull. Marine fouling is undesirable because it increases drag and fuel consumption, while

decreasing vessel speed.1

2.1.1 Types of AF Topcoats

Several different types of AF topcoats, qualified to MIL-PRF-24647 or MIL-P-15931, are

used on the hulls of the Armed Forces vessels.2,3 Within MIL-PRF-24647, they are categorized

by:

• action;

• type of substrate;

• volatile organic compound (VOC) content of the coating; and

• service life requirement and color.

Action - The coating may work through ablative (Type I) or nonablative (Type II) action.

An ablative coating thins as it erodes or dissolves. Through this action, a fresh layer of

antifouling agent (e.g., copper) is exposed, maintaining the antifouling properties of the paint.

Type II nonablative AF coatings do not thin during service. Some of these coatings function by

leaching metals that prevent marine fouling.1

Type of Substrate - Most hulls of major vessels in the Armed Forces are steel. Hulls of

smaller vessels and some specialty vessels (e.g., minesweepers and minehunters) are often

constructed of alternate materials such as aluminum, fiberglass sheathing, glass reinforced plastic

(GRP), rubber, or wood. The coating system applied will vary with the hull material. For

instance, steel, fiberglass, GRP, and wood hulls are typically coated with copper-based coatings,

and aluminum hulls with tributyltin (TBT) or biocide-free silicone-based coatings.1,4 Rubber

craft are left unpainted and, therefore, do not contribute to this discharge.
Hull Coating Leachate

3

VOC Content - Coatings are classified into four grades based on their maximum VOC

content. The upper limits for each grade are 3.4 pounds per gallon (lbs/gal), 2.8 lbs/gal, 2.3

lbs/gal, and zero lbs/gal.2

Service Life Requirement and Color - Coatings are also classified based on the desired

service life of the coating system and their color. A vessel’s coating system may have a five-,

seven-, or ten-year service life. Vessels also may use either red, black, or gray coatings (and

white on some smaller craft). Therefore, there are a number of different coating combinations,

based on service life and color.1

2.2 Releases to the Environment

AF topcoats control biological growth by ablating and/or releasing antifouling agents into

the surrounding water. This release is gradual and continuous. The release rate depends on the

type of paint, water temperature, vessel speed, frequency of vessel movement in and out of port,

and coating age. The type of material released is dependent on the type of topcoat employed.

Most hulls use copper-based coatings; therefore, copper and zinc (another biocide commonly

found in antifouling paints) are the most common releases. Those aluminum-hulled vessels with

TBT-containing coatings will release TBT and small amounts of zinc, and may release copper,

depending on the TBT coating formulation.1

2.3 Vessels Producing the Discharge

Most vessels of the Armed Forces use AC paints or AC/AF coating systems. Selected

boats and craft may not be coated with AF paint if they spend most of their time out of the water.

The Navy, Military Sealift Command (MSC) and United States Coast Guard (USCG) use paint

systems qualified to MIL-PRF-24647. The Army uses paint systems with AF topcoats qualified

to MIL-P-15931. Additional guidance for Navy vessels is contained in Naval Ships’ Technical

Manual (NSTM) Chapter 631.5,6 It should be noted that paint types and applications vary for

each vessel, depending on where the vessels are docked and the port in which they are painted,

which influences paint availability.

2.3.1 Copper-Based Coatings

Most Navy, MSC, USCG, and Army ships have steel hulls with copper-based AF

coatings. The Navy ships that do not have steel hulls are the mine countermeasure vessels

(MCM 1 and MHC 51 Classes), consisting of 26 ships. MCM 1 Class vessels have wood hulls

sheathed with fiberglass and MHC 51 Class vessels have GRP hulls.7 However, these vessels are

still protected with AC coats and copper ablative AF paints similar to those applied to steel

vessels.1

MSC vessels use two types of Navy-approved copper-based AF paints, ablative and

nonablative. Approved MSC underwater hull coatings are listed in MSC Instruction 4750.2C.8

The USCG utilizes Navy-approved hull coating systems qualified to MIL-PRF-24647, as listed

in the USCG Coatings and Color Manual.9 The Air Force uses copper ablative paints similar to
Hull Coating Leachate

4

those used by the Navy.10 AF topcoats used on Army watercraft are qualified to MIL-P-15931,

as listed in Department of the Army Technical Bulletin TB 43-0144.3

2.3.2 TBT-Based Coatings

The predominant use of TBT-based coatings in the Armed Forces has been on aluminumhulled vessels. Copper-based AF paints can accelerate the rate at which aluminum hulls corrode,

especially if defects or damage to the AC coating are present. Currently, all Navy ships with

aluminum hulls (i.e., hydrofoils) have been decommissioned.1 However, the Navy does have

approximately 280 small boats and craft with aluminum hulls. Approximately 10-20% of the

aluminum-hulled small boats and craft in the Navy (28-56 vessels; e.g., special warfare patrol

craft) could still have TBT-based hull coatings.11 The USCG estimates that 50 aluminum-hulled

small boats and craft are coated with AF paint containing TBT.12 The MSC has no vessels with

aluminum hulls.13 The Air Force has six large vessels with aluminum hulls, the MR Class

missile retrievers. These vessels are coated with TBT-free, copper-based coatings.7,10 The Air

Force also has approximately 50 small craft that may have TBT-containing coatings. The Army

has approximately 11 small boats and craft that may have TBT coatings.13 The numbers of

vessels from the respective Armed Forces branches estimated to have TBT coatings are listed

below.

• Navy - 56

• USCG - 50

• MSC - 0

• Air Force - 50

• Army - 11

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

This discharge occurs within harbors, rivers, and coastal waters from every surface vessel

and submarine, as well as most boats and craft. This discharge is continuous and will occur any

time a painted vessel is waterborne.

3.2 Rate

This discharge is not a flow; rather, it is the release of AF agents from hull coatings into

the surrounding water. This rate of release, which is the combined effect of ablation and

leaching, has been the subject of previous Navy studies.14 In these studies, painted panels were
Hull Coating Leachate

5

submerged in San Diego Bay and copper and zinc release rates were calculated for two of the

most frequently used ablative copper AF paint systems.

Dynamic exposure tests included intervals of simulated vessel movement (cruising) at 17

knots followed by periods of no movement, in order to simulate actual vessel operations. The

calculated long-term average release rates (from both test coatings) for simulated vessel

operation exposures were 17.0 micrograms per square centimeter-day ((μg/cm2)/day) for copper

and 6.7 (μg/cm2)/day for zinc. Release rates were highest at the initial stages of the exposures,

when the coatings were new.14

Long-term average release rates for panels remaining in a static position (no simulated

movement) for the entire test were 8.9 (μg/cm2)/day for copper and 3.6 (μg/cm2)/day for zinc.14

It is assumed that the static tests underestimate the actual average release rate from vessels

because they do not account for vessel movement and the resulting ablation effects.

A comparison of the above dynamic and static release rates shows that dynamic

conditions resulted in increased release of copper and zinc. The higher release rates are

presumably caused by continuous re-exposure of fresh copper and zinc. The dynamic tests may,

however, overestimate actual conditions for some vessels, as the dynamic intervals used in the

test may have been more aggressive than in actual practice.

In-situ release rates of TBT from vessels in Pearl Harbor were collected by the Navy in

1987 and 1988.15 These studies reported an average steady-state TBT release rate of 0.38

(μg/cm2)/day.

3.3 Constituents

The primary antifouling agent in most AF topcoats is copper. Because copper is toxic to

marine organisms, it inhibits their accumulation and growth on the hull. Other than copper

compounds, the constituents that can be released from approved, underwater hull paint systems

include acrylate (in ablative coatings), vinyls (in non-ablative coatings), rosin, zinc compounds,

and anticorrosive compounds.16,17 The discharge from aluminum-hulled vessels may also

contain TBT. Of the known constituents in AF coatings; copper, zinc, TBT, and ethyl benzene

are priority pollutants, and there are no known bioaccumulators.

3.4 Concentrations

Most copper-based AF coatings contain 40 to 50 weight percent (wt%) cuprous oxide.16

Some ablative AF paints also contain as much as 20 wt% zinc, which may act as a mild cobiocide.16 Concentrations within TBT-based AF coatings range from less than 5 wt% to 25 wt%

for TBT compounds and 25-50 wt% for copper. Some TBT-based coating formulations contain

1-10 wt% ethyl benzene.18

4.0 NATURE OF DISCHARGE ANALYSIS
Hull Coating Leachate

6

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

4.1.1 Copper and Zinc Loadings

The mass loadings for copper and zinc were calculated for Navy, MSC, USCG, Army,

and Air Force vessels based on the reported release rates.14 Loading for a single vessel was

calculated by the following equation:

The wetted surface area of the vessels were either taken directly from a naval manual or

were estimated by the following formula presented in the same source:19

Calculations were performed for each vessel class. A sample calculation of the mass

loading of copper from a destroyer is provided in Calculation Sheet 1 at the end of the report.

From actual vessel movement data compiled for 1991 through 1995, the sum of the average

number of days in port, the average number of transits, and time of operation within 12 n.m. was

determined for each vessel class.20 The number of vessels in each class are listed in conjunction

with the total calculated loadings per vessel class in Table 1. A total annual copper loading of

216,657 lbs (98,257 kilograms (kg)) and a total annual zinc loading of 85,389 lbs (38,725 kg)

were calculated. The mass loadings calculated represent the worst-case conditions.

The approach used overestimates the mass loading for the following reasons:

Copper Loading = (release rate)(surface area)(time)

where: release rate = dynamic release of copper and zinc (Section 3.2)

surface area = wetted surface area of vessel

time = number of days vessel is within 12 nautical miles (n.m.)

S = 1.7(L)(d) + (V/d)

where: S = wetted surface area (ft2)

L = length between perpendiculars (ft)

d = molded mean draft at full displacement (ft)

V = molded volume of displacement (for seawater, 35 ft3 per ton displacement)
Hull Coating Leachate

7

• Calculations were based on the dynamic release rate, and vessels are not in motion

while pierside.

• All vessels were assumed to be deployed at ports within the jurisdiction of the United

States, while many are actually deployed overseas.

• All vessels are assumed to be fully operational; that is, no reduction was made to

account for the number of vessels which may be in dry dock during the year.

• All small workboats and utility craft were assumed to be in the water at all times,

when they may actually be stored on land.

• Amphibious assault craft of both the Army and Navy, which are capable of being

transported or otherwise held within larger amphibious ships, were assumed to be in

the open water at all times.

4.1.2 TBT Loadings

Table 2 presents mass loadings of TBT from Navy, USCG, Army, and Air Force vessels,

based on the study of TBT concentration measurements from five vessels in Pearl Harbor.15 The

average release rate measured during this study was 0.38 (μg/cm2)/day. The mass loading value

was estimated to be 24 lbs/yr (11 kg/yr) based on the following assumptions:

• Small boats and craft were estimated to be within 12 n.m. at all times and to spend

10% of the year out of the water. This assumption leads to an overestimate of the

mass loadings for TBT because many small boats and craft spend much more than

10% of their time out of the water.

• Twenty percent of the Navy’s aluminum-hulled small boats and craft were assumed to

still have TBT-based AF coatings, although the actual number may be as low as 10%.

• All of the 50 Air Force and 11 Army small craft were assumed to be painted with

TBT coatings.

Use of these assumptions also overestimates the potential TBT loading since the use of

TBT coatings is being phased out, and the number of TBT coated craft in the Armed Forces is

continually declining.

4.2 Environmental Concentrations

The estimated quantities of constituents released to the environment are shown in Tables

1 and 2. Using the mass loadings and a tidal prism model for analyzing mixing within specific

harbors, the resulting concentration of constituents in the environment were estimated in the

manner described below.

4.2.1 Copper and Zinc Concentrations

Table 3 lists the Federal and most stringent state water quality criteria for the constituents

of the hull coating leachate discharge. Using the annual copper and zinc loadings and annual

tidal excursion volumes, the average copper and zinc concentrations caused by these vessels were

calculated for each port. The approach used to estimate concentrations uses a simplified dilution
Hull Coating Leachate

8

model based on tidal flow in three major Armed Forces ports and hereafter referred to as the

“tidal prism” approach. The tidal prism approach uses the mass of the constituent generated by

vessels and mixes this mass with a volume of water. The mass is calculated by determining the

number of vessels in a particular homeport, the wetted surface area of each vessel’s hull, and the

number of hours each vessel spends in port (both pierside and in transit). Together, these factors

are used to calculate an annual loading to the harbor. The water volume used is the sum of all

outgoing tides over a year times the surface area of the harbor. The sum of outgoing tides is

called the “annual tidal excursion.” This can be calculated by subtracting the annual mean low

tide from the annual mean high tide and multiplying the difference by the number of days in the

year. Annual tidal excursion data is readily available from the National Oceanographic and

Atmospheric Agency (NOAA) and the 1996 data 21 was used for these calculations. The

following is the equation used to estimate concentrations of copper and zinc contributed to

harbors by hull coating leachate:

Concentration increase = Annual load / Annual tidal prism volume

where: annual load = (kg/yr)/(109μg/kg) = (μg/yr)

annual tidal prism volume = (m3/yr) (103 L/m3) = (L/yr)

Concentration increase = μg/L

The three ports used for the tidal prism model are Mayport, FL, San Diego, CA, and Pearl

Harbor, HI. These ports were selected because they have minimal river inflow, small but welldefined harbor areas, and a high number of vessels of the Armed Forces. Each of these factors

will tend to provide higher concentrations of copper and zinc, either due to less volume of water

or higher numbers of potential sources. Other major ports, such as Norfolk (VA) and Bremerton

(WA), were considered, but not included because of large river effects and very large harbor

areas. The 1996 annual tidal volumes (annual tidal excursion times the harbor surface area) for

the three ports are shown below:

• San Diego, CA, 3.78 x 1010 m3 per year;

• Mayport, FL, 6.7 x 108 m3 per year; and

• Pearl Harbor, HI, 3.42 x 109 m3 per year.

The tidal prism model assumes steady-state conditions, where copper and zinc are

completely mixed with the harbor water and are removed solely by discharge from the port

during ebb tides. The outgoing tidal volumes are assumed to be carried away by long-shore

currents (i.e., those moving parallel to shore) and do not re-enter the harbor. The tidal prism

model also does not assume removal or concentration by other factors such as river flow,

precipitation, evaporation, or sediment exchange. By not accounting for removal or dilution due

to river flow, precipitation, and sediment exchange, the results depict a higher water column

concentration than expected. The effect of evaporation could be to increase concentration due to

water loss, or the effect could be neutral since water loss by evaporation is replaced by

(additional) water inflow from the sea. While the model assumes complete mixing, there will be

areas in the harbors with higher concentrations, primarily near the source vessels, along with

areas of lower concentration.
Hull Coating Leachate

9

To estimate the annual load for the same three ports, the number and types of vessels in

each of these locations were obtained.22 The ratios of Navy vessels at each of these ports to the

total number of vessels per respective ship class were multiplied by the copper and zinc mass

loadings of Table 1 and summed. The estimated contribution of Armed Forces’ AF paint to the

existing copper and zinc concentrations in each port is provided in Table 4. The actual annual

load attributable to hull coating leachate for each of these ports should be smaller than estimated

for two reasons. First, the calculated mass loadings are based upon dynamic release rates, yet the

vessels in port are primarily static. Also, the mass loadings of copper and zinc were determined

using the total amount of time that the vessels are within 12 n.m., not just in port. Therefore, the

actual concentrations in port will be lower than stated.

The calculated copper concentration increases are shown in Table 5 and range from 0.19

μg/L at San Diego to 3.0 μg/L at Mayport, the latter of which exceeds Federal and state water

quality criteria. Copper from AF paint adds to the ambient copper concentrations from other

sources. In other words, these concentrations represent the ambient copper concentration if hull

coating leachate were the only source of copper in each harbor. Ambient copper concentrations

in San Diego Harbor have been reported to average near 3.7 μg/L, with locally impacted areas

near vessels at twice the average.23

As demonstrated by Table 5, the estimated copper contributions from hull coating

releases are a significant contributor to total copper levels within the Navy ports analyzed. In

addition, some of these ports are already near or above ambient water quality criteria levels for

copper. Therefore, dilution of copper to levels below the water quality criteria cannot be

expected. By contrast, the three ports analyzed were all well below the water quality criteria for

zinc, and estimated zinc concentration increases were not large enough to cause the zinc levels in

these ports to approach the zinc water quality criteria.24

4.2.2 TBT Concentrations

As discussed in Section 2.3.2, only small boats and craft of the Armed Forces still use

TBT-containing coatings. A tidal prism approach can also be used to estimate TBT

concentrations, assuming that the TBT loading in each harbor is proportional to the copper

loading, as might be the case if the locations of small boats and craft parallel that of larger

vessels. As shown in Calculation Sheet 2, TBT is estimated to range from 0.02 nanograms per

liter (ng/L) to 0.30 ng/L in the harbors analyzed. TBT does not have specific Federal water

quality criteria at the present; however, criteria have been proposed.25 Table 3 lists the proposed

Federal and most stringent state water quality criteria for TBT.

4.3 Potential for Introducing Non-Indigenous Species

Although it is possible for non-indigenous species to be transported on vessel hulls, AF

coatings reduce the amount of marine growth on vessel hulls. The discharge itself (released

components of AF coatings) does not provide the opportunity for transport of non-indigenous

species.
Hull Coating Leachate

10

5.0 CONCLUSIONS

Hull coating leachate has the potential to cause an adverse environmental effect because

estimated mass loadings of copper from hull coatings are significant and could cause

environmental copper concentrations to exceed water quality criteria in some ports.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained, reviewed,

and analyzed. Process information and assumptions were used to estimate the rates of discharge.

Table 6 shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Hull Coating Leachate, 20 August 1996.

2. Military Specification, MIL-PRF-24647B, Paint System, Anticorrosive and Antifouling,

Ship Hull, August 1994.

3 . Department of the Army Technical Bulletin, Painting of Watercraft, TB 43-0144, 5

October 1990.

4. Material Safety Data Sheets for Courtaulds Coatings Inc. International Paint Intersleek

Tie Coat BXA 386/BXA 390/BXA 391 and Intersleek Finish BXA 816/BXA 821/BXA

822, June 1992.

5. Naval Ships’ Technical Manual (NSTM) Chapter 631, Vol. 3, Preservation of Ships in

Service, Section 8, Shipboard Paint Application, 1 November 1992.

6. Naval Sea Systems Command (NAVSEA), Advance Change Notice (ACN) No. 3/A, to

Naval Ships’ Technical Manual Chapter 631, S9086-VD-STM-030, Preservation of Ships

in Service. September 1996.

7. Polmar, N. The Naval Institute Guide to the Ships and Aircraft of the U.S. Fleet,

Sixteenth Edition. Naval Institute Press, Annapolis, MD, 1997.

8. Commander Military Sealift Command, COMSC Instruction 4750.2C, Preservation

Instructions for MSC Ships, Appendix A, 3 November 1989.

9. United States Coast Guard, Coatings and Color Manual, Commandants Instruction

M10360.3A, August 1995.

10. Department of the Air Force, HQUSAF/ILTV, Memo to M. Rosenblatt and Son, Inc., 21

August 1997.
Hull Coating Leachate

11

11. Holmes, B. S., Naval Sea Systems Command. Vessels with TBT Coatings based on

conversations with Fleet representatives, June 1997, K. Thomas, M. Rosenblatt and Son,

Inc.

12. Aivalotis, J., USCG, TBT on USCG Ships, 28 May 1997, L. Panek, Versar, Inc.

13. UNDS Ship Database, 1 August 1997.

14. Marine Environmental Support Office, Naval Command, Control & Ocean Surveillance

Center, RDT&E Division (NRaD), UNDS Hull Coating Evaluation, 28 February 1997.

15. Naval Command, Control & Ocean Surveillance Center (NRaD). “Butyltin

Concentration Measurements in Pearl Harbor, Hawaii, April 1986 to January 1988, Pearl

Harbor Case Study,” April 1989.

16. Material Safety Data Sheets for the following products:

Product/Trade Name: BRA 640 Interviron, Red Antifouling Paint

Manufacturer: Courtaulds Coatings

Product/Trade Name: 283S5772 ABC #3 - Red Ablative Antifouling Paint

Product Number 406940

Manufacturer: Ameron Protective Coatings Group

Product/Trade Name: 283S5773 ABC #3 - Black Ablative Antifouling Paint

Product Number 407150

Manufacturer: Ameron Protective Coatings Group

Product/Trade Name: Epoxy Adhesives 2216 B/A Gray, 2216 B/A Tan NS, and 

2216 B/A Translucent

Manufacturer: 3M Scotch-WeldTM, March 1995

Product/Trade Name: Epoxy Adhesives

Manufacturer: 3M Innovation, March 1996

17. Qualified Products List (QPL-15931-14) of Products Qualified Under Military

Specification MIL-P-15931, Paint, Antifouling, Vinyl (Formulas No. 121, 121A, 129, and

129A). January 1995.

18. Material Safety Data Sheets for International Paint Intersmooth Hisol Plum BFA254,

November 1996; and Devoe Coating Company ABC #2 Red Ablative Antifouling

Coating, September 1995.

19. Naval Ships’ Technical Manual (NSTM) Chapter 633, Section 4.3.1 and Table 633-5.

Cathodic Protection. 1 August 1992.
Hull Coating Leachate

12

20. Pentagon Ship Movement Data for Years 1991-1995, Dated 4 March 1997.

21. National Oceanic and Atmospheric Administration, 1997.

22. United States Navy, List of Homeports, Effective 30 April 1997.

23. Valkirs, A.O., B.M. Davidson, L.L. Kear, R.L. Fransham, A.R. Zirino, and J.G.

Grovhoug; Naval Command, Control and Ocean Surveillance Center, RDT&E Division.

“Environmental Effects from In-Water Hull Cleaning of Ablative Copper Antifouling

Coatings.” Tech. Doc. 2662. 1994.

24. U.S. Environmental Protection Agency, Office of Wetlands, Oceans and Watersheds,

Assessment and Watershed Protection Division, Retrieval from STORET Database,

1997.

25. Proposed Water Quality Criteria, 62 Federal Register 42554, 7 August 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
Hull Coating Leachate

13

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Naval Command, Control and Ocean Surveillance Center, RDT&E Division, San Diego, CA.

“Dynamic and Static Exposure Tests and Evaluations of Alternative Copper-Based

Antifouling Coatings.” September 1993.

Military Specification, MIL-PRF-15931, Paint, Antifouling, Vinyl, January 1995.

Qualified Products List (QPL-24647-3) of Products Qualified Under Military Specification MILPRF-24647, Paint System, Anticorrosive and Antifouling, Ship Hull. 2 April 1996.

Aivalotis, J., United States Coast Guard, USCG Ship Movement, 27 May 1997, L. Sesler,

Versar, Inc.

UNDS Equipment Expert Round 2 Meeting Minutes - Hull Coating Leachate, 1997.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Table 1. Navy, MSC, and USCG, Army, and Air Force Mass Loadings for Ships, and Small Boats and Craft

Ship Class Ship Class Description

Quantity of 

Ships per 

Class

Days in Port 

per Year

Number of 

Transits per year 

(each is a transit in 

and out)T

Days of 

Operation 

within 12 

n.m.

Ship's Wetted 

Surface Area (sq 

ft)

*Copper 

Loading per 

ship class 

(kg/yr)

**Zinc 

Loading per 

ship class 

(kg/yr)

NAVY

AC Area Command Cutter 2 305 0 60 539 6 2

AP Area Point System Search Craft 6 305 0 60 343 12 5

AR Aircraft Rescue 6 305 0 60 2,127 74 29

AT Armored Troop Carrier 21 305 0 60 362 44 17

BH Boom Handling 8 305 0 60 189 9 3

BT Bomb Target 4 305 0 60 94 2 1

BW Boston Whaler 4 305 0 60 94 2 1

CA Catamaran 1 305 0 60 207 1 0

CC Cabin Cruiser (Commercial) 4 305 0 60 411 9 4

CM Landing Craft, Mechanized 151 305 0 60 4,275 3,721 1,467

CRRC Combat Rubber Raiding Craft (USMC) 418 305 0 60 57 137 54

CT Craft of Opportunity Coop Trainers 14 305 0 60 411 33 13

CU Landing Craft, Utility 40 305 0 60 3,860 890 351

DB Distribution Box 4 305 0 60 704 16 6

DT Diving Tender 1 305 0 60 813 5 2

DW Dive Workboat 7 305 0 60 539 22 9

HH Hawser Handling 7 305 0 60 400 16 6

HL Hydrographic Survey Launch 3 305 0 60 342 6 2

LA Landing Craft, Assault 1 305 0 60 2,745 16 6

LCM(3) Mechanized Landing Craft 2 305 0 60 not available -- --

LCM(6) Mechanized Landing Craft 60 305 0 60 990 342 135

LCM(8) Mechanized Landing Craft 100 305 0 60 1,603 924 364

LCPL Landing Craft Personnel 130 305 0 60 332 249 98

LCVP 10 305 0 60 not available -- --

LH Line Handling 3 305 0 60 400 7 3

MC Mine Countermeasure Support Craft 2 305 0 60 343 4 2

ML Motor Launch 3 305 0 60 256 4 2

MM Marine Mammal Support Craft 5 305 0 60 331 10 4

MW Motor Whaleboat 121 305 0 60 256 179 70

NM Noise Measuring 1 305 0 60 800 5 2

NS Non-Standard (commercial) 120 305 0 60 540 374 147

PE Personnel 211 305 0 60 352 428 169

PF Patrol Craft, Fast 3 305 0 60 539 9 4

PK Picket Boat 1 305 0 60 366 2 1

PL Landing Craft, Personnel Light 147 305 0 60 332 281 111

PR Plane Personnel and Rescue 8 305 0 60 392 18 7

PT Punt 266 305 0 60 83 127 50

SB Sound/Sail 1 305 0 60 350 2 1

SC Support Craft 6 305 0 60 400 14 5

SS Swimmer Support 12 305 0 60 400 28 11

ST Sail Training Craft 21 305 0 60 350 42 17

TC Training Craft 19 305 0 60 580 64 25

TD Target Drone 2 305 0 60 580 7 3

UB Utility Boat 793 305 0 60 398 1,819 717

VP Landing Craft, Vehicle Personnel 12 305 0 60 332 23 9

WB Workboat 263 305 0 60 620 940 370

WH Wherry 12 305 0 60 400 28 11

T

Zero entered for number of transits per year when no further information was available.

nsp = not self-propelled

N/A = Not enough information available to calculate a wetted surface area.
Table 1. Navy, MSC, and USCG, Army, and Air Force Mass Loadings for Ships, and Small Boats and Craft

Ship Class Ship Class Description

Quantity of 

Ships per 

Class

Days in Port 

per Year

Number of 

Transits per year 

(each is a transit in 

and out)T

Days of 

Operation 

within 12 

n.m.

Ship's Wetted 

Surface Area (sq 

ft)

*Copper 

Loading per 

ship class 

(kg/yr)

**Zinc 

Loading per 

ship class 

(kg/yr)

WT Warping Tug 1 305 0 60 2,662 15 6

YFRN Refrigerated/Covered Lighter 3 305 0 60 not available -- --

YL Yawl 7 305 0 60 400 16 6

YTM Medium Harbor Tug (self-propelled) 11 305 0 60 3,170 201 79

AFDB 4 Large Auxiliary Floating Dry Dock 1 305 0 60 not available -- --

AFDB 8 Large Auxiliary Floating Dry Dock 1 305 0 60 not available -- --

AFDL 1 Small Auxiliary Floating Dry Docks 2 305 0 60 47,645 549 216

AFDM 14 Medium Auxiliary Floating Dry Dock 1 305 0 60 not available -- --

AFDM 3 Medium Auxiliary Floating Dry Docks 4 305 0 60 47,645 1,099 433

AGER 2 1 305 0 60 not available -- --

AGF 11 Raleigh Class Miscellaneous Command Ships 1 183 12 0 41,595 123 48

AGF 3 Austin Class Miscellaneous Command Ship 1 183 12 0 51,830 153 60

AGOR 21 Gyre Class Oceanographic Research Ships 1 113 11 0 8,834 16 6

AGOR 23 Thompson Class Oceanographic Research Ships 2 113 11 0 13,960 51 20

AGSS 555 Dolphin Class Submarine 1 305 0 60 9,130 53 21

AO 177 Jumboised Cimarron Class Oilers 5 188 10 0 63,185 955 376

AOE 1 Supply Class Fast Combat Support Ships 4 114 6 0 93,821 688 271

AOE 6 Sacramento Class Fast Combat Support Ship 3 183 11 0 103,520 916 361

APL Barricks Craft (nsp) 16 305 0 60 13,775 1,270 501

ARD 2 Auxiliary Repair Dry Docks 1 305 0 60 40,750 235 93

ARDM Medium Auxiliary Repair Dry Docks 3 305 0 60 47,645 824 325

ARS 50 Safeguard Class Savage Ships 4 208 22 0 13,299 181 71

AS 33 Emory S Land Class Submarine Tenders 1 293 6 0 59,630 278 109

AS 39 Simon Lake Class Submarine Tenders 3 229 6 0 59,630 653 257

ASDV 2 305 0 60 not available -- --

CG 47 Ticonderoga Class Guided Missile Cruisers 27 166 12 0 37,840 2,743 1,081

CGN 36 California Class Guided Missile Cruiser 2 143 11 0 40,260 187 74

CGN 38 Virginia Class Guided Missile Cruiser 1 161 11 0 42,390 110 43

CV 59 Forrestal Class Aircraft Carrier 1 143 6 0 141,470 324 128

CV 63 Kitty Hawk Class Aircraft Carrier 3 137 7 0 141,470 934 368

CVN 65 Enterprise Class Aircraft Carrier 1 76 6 0 156,990 193 76

CVN 68 Nimitz Class Aircraft Carrier 7 147 7 0 159,500 2,633 1,038

DD 963 Spruance Class Destroyers 31 178 12 0 35,745 3,185 1,255

DDG 51 Arleigh Burke Class Guided Missile Destroyers 18 101 11 0 31,769 945 373

DDG 993 Kidd Class Guided Missile Destroyers 4 101 11 0 31,769 210 83

DSRV-1 Deep Submergence Rescue Vehicles 2 305 0 60 not available -- --

DSV 1 Deep Submergence Vehicles 3 305 0 60 not available -- --

FFG 7 Oliver Hazard Perry Guided Missile Frigates 43 167 13 0 19,850 2,310 910

IX 308 Unclassified Miscellaneous 2 305 0 60 5,180 60 24

IX 501 Unclassified Miscellaneous 1 305 0 60 8,365 48 19

IX 35 Barrick Ships 2 305 0 60 not available -- --

EX YFU Harbor Utility Craft 1 305 0 60 4,160 24 9

SES 200 High Performance Test Platform (ex- USCG Dorado) 1 305 0 60 not available -- --

LCC 19 Blue Ridge Class Amphibious Command Ships 2 179 8 0 51,250 294 116

LCU 1610 1600 Class Landing Craft Utility 40 200 6 0 3,915 500 197

LHA 1 Tarawa Class Amphibious Assault Ships 5 173 9 0 94,325 1,311 517

LHD 1 Wasp Class Amphibious Transport Docks 4 185 13 0 88,965 1,064 419

LPD 14 Amphibious Transport Docks 2 178 11 0 51,830 297 117

T

Zero entered for number of transits per year when no further information was available.

nsp = not self-propelled

N/A = Not enough information available to calculate a wetted surface area.
Table 1. Navy, MSC, and USCG, Army, and Air Force Mass Loadings for Ships, and Small Boats and Craft

Ship Class Ship Class Description

Quantity of 

Ships per 

Class

Days in Port 

per Year

Number of 

Transits per year 

(each is a transit in 

and out)T

Days of 

Operation 

within 12 

n.m.

Ship's Wetted 

Surface Area (sq 

ft)

*Copper 

Loading per 

ship class 

(kg/yr)

**Zinc 

Loading per 

ship class 

(kg/yr)

LPD 4 Austin Class Amphibious Transport Docks 3 178 11 0 51,830 446 176

LPD 7 Amphibious Transport Docks 3 178 11 0 51,830 446 176

LPH 2 Iwo Jima Class Amphibious Assault Ships 2 186 11 0 49,945 299 118

LSD 36 Anchorage Class Dock Landing Ships 5 215 13 0 45,405 786 310

LSD 41 Whidbey Island Class Dock Landing Ships 8 170 13 0 51,020 1,124 443

LSD 49 Harpers Ferry Dock Landing Ships 3 215 13 0 41,595 432 170

LST 1179 Tank Landing Ships 3 178 11 0 34,650 298 118

MCM 1 Avenger Class Mine Countermeasures Vessels 14 232 28 0 8,410 449 177

MHC 51 Osprey Class Coastal Minehunters 12 232 28 0 6,418 294 116

PC Cyclone Class Coastal Defense Ships 13 105 18 0 3,704 84 33

SLWT Side Loadable Warping Tugs 24 305 0 0 not available -- --

SSBN 726 Ohio Class Ballistic Missile Submarine 17 183 6 0 74,575 3,704 1,460

SSN 640 Sturgeon Class Attack Submarine 13 183 6 0 27,075 1,028 405

SSN 688 Los Angeles Class Attack Submarine 56 183 6 0 34,765 5,688 2,242

SSN 671 Narwhal Class Submarines 1 183 6 0 29,135 85 34

SSN 637 Benjamin Franklin Class Submarines 2 183 6 0 44,061 257 101

YC Open Lighters (nsp) 254 305 0 60 6,475 9,480 3,736

YCF Car Float (nsp) 1 305 0 60 not available -- --

YCV Aircraft Transportation Lighters (nsp) 9 305 0 60 not available -- --

YD Floating Cranes (nsp) 63 305 0 60 12,875 4,676 1,843

YDT Diving Tenders 3 305 0 60 8,885 154 61

YFB Ferryboat or Launch (nsp) 2 305 0 60 3,895 45 18

YFN Covered Lighters (nsp) 157 305 0 60 6,680 6,046 2,383

YFNB Large Covered Lighters (nsp) 11 305 0 60 15,955 1,012 399

YFND Dry Dock Companion Craft (nsp) 2 305 0 60 not available -- --

YFNX Lighter - Special Purpose (nsp) 8 305 0 60 4,760 220 87

YFP Floating Power Barges (nsp) 2 305 0 60 15,590 180 71

YFRT Covered Lighters - Range Tender (self propelled) 2 305 0 60 5,490 63 25

YFU 83 Harbor Utility Craft (self propelled) 1 305 0 60 3,915 23 9

YFU 91 Harbor Utility Craft (self propelled) 1 305 0 60 3,915 23 9

YGN 80 Garbage Lighters (nsp) 3 305 0 60 not available -- --

YLC Salvage Lift Crane (nsp) 1 305 0 60 not available -- --

YM Dredges (self propelled) 2 305 0 60 not available -- --

YMN Dredge (nsp) 1 305 0 60 not available -- --

YNG Gate Craft (nsp) 2 305 0 60 4,760 55 22

YO 65 Fuel Oil Barges (self propelled) 3 305 0 60 10,205 176 70

YOG 5 Gasoline Barges (self propelled) 2 305 0 60 10,205 118 46

YOGN Gasoline Barges (nsp) 12 305 0 60 8,512 589 232

YON Fuel Oil Barges (nsp) 48 305 0 60 8,512 2,355 928

YOS Oil Storage Barges (nsp) 14 305 0 60 8,512 687 271

YPD Floating Pile Drivers (nsp) 4 305 0 60 not available -- --

YR Floating Workshops (nsp) 25 305 0 60 7,350 1,059 417

YRB Repair and Berthing Barges (nsp) 4 305 0 60 4,320 100 39

YRBM Repair, Berthing and Messing Barges (nsp) 39 305 0 60 10,180 2,289 902

YRDH Floating Dry Dock Workshop (Hull) (nsp) 1 305 0 60 not available -- --

YRR Radiological Repair Barges (nsp) 9 305 0 60 6,405 332 131

YRST Salvage Craft Tenders (nsp) 3 305 0 60 10,965 190 75

YSD 11 Seaplane Wrecking Derrick (self propelled) 1 305 0 60 3,845 22 9

T

Zero entered for number of transits per year when no further information was available.

nsp = not self-propelled

N/A = Not enough information available to calculate a wetted surface area.
Table 1. Navy, MSC, and USCG, Army, and Air Force Mass Loadings for Ships, and Small Boats and Craft

Ship Class Ship Class Description

Quantity of 

Ships per 

Class

Days in Port 

per Year

Number of 

Transits per year 

(each is a transit in 

and out)T

Days of 

Operation 

within 12 

n.m.

Ship's Wetted 

Surface Area (sq 

ft)

*Copper 

Loading per 

ship class 

(kg/yr)

**Zinc 

Loading per 

ship class 

(kg/yr)

YSR Sludge Removal Barges (nsp) 14 305 0 60 not available -- --

YTB 752 Large Harbor Tug (self propelled) 1 305 0 60 3,170 18 7

YTB 756 Large Harbor Tugs (self propelled) 3 305 0 60 3,265 56 22

YTB 760 Large Harbor Tugs (self propelled) 68 305 0 60 3,265 1,280 504

YTL 422 Small Harbor Tug (self propelled) 1 305 0 60 1,015 6 2

YTT 9 Torpedo Trails Craft (self propelled) 3 305 0 60 not available -- --

YWN Water Barges (nsp) 6 305 0 60 not available -- --

MILITARY SEALIFT COMMAND

T-AE Kilauea Class Ammunition Ships 8 26 4 0 54,240 187 74

T-AFS Mars Class Combat Stores Ships 8 148 7 0 46,930 891 351

T-AG Mission Class Navigation Research Ship 2 151 10 0 59,126 288 114

T-AGM Compass Island Class Missile Instrumentation Ship 1 133 4 0 47,791 101 40

T-AGOS Stalwart Class Ocean Surveillance Ship 5 70 4 0 10,987 62 24

T-AGOS Victorious Class Ocean Surveillance Ship 4 107 5 0 14,679 101 40

T-AGS Silas Bent Class Surveying Ships 2 44 6 0 13,913 20 8

T-AGS Waters Class Surveying Ships 1 7 1 0 36,590 4 2

T-AGS John McDonnell Class Surveying Ships 2 96 6 0 10,085 31 12

T-AGS Pathfinder Class Surveying Ships 4 96 6 0 19,383 120 47

T-AH Mercy Class Hospital Ships 2 184 2 0 123,862 722 285

T-AKR Algol Class Vehicle Cargo Ships 8 109 3 0 111,650 1,552 612

T-AKR Maersk Class Fast Sealift Ships 3 59 9 0 107,028 314 124

T-AO Henry J Kaiser Class Oilers 13 78 6 0 44,511 731 288

T-ARC Zeus Class Cable Repairing Ship 1 8 2 0 41,176 6 2

T-ATF Powhatan Class Fleet Ocean Tugs 7 127 16 0 11,398 167 66

COAST GUARD

WAGB Polar Class Icebreakers 2 148 4 100 36,132 285 112

WAGB Mackinaw Class Icebreakers 1 215 4 150 19,167 111 44

WHEC Hamilton and Hero Class High Endurance Cutters 12 151 13 0 17,339 510 201

WIX Eagle Class Sail Training Cutter 1 188 7 150 12,264 66 26

WLB Juniper Class Seagoing Buoy Tenders 16 190 18 100 10,357 775 305

WLB Balsam Class Buoy Tender WLB 180A 8 190 18 100 6,751 252 100

WLB Balsam Class Buoy Tender WLB 180B 2 120 5 100 6,751 47 19

WLB Balsam Class Buoy Tender WLB 180C 13 123 16 100 6,751 316 125

WLI Inland Buoy Tender WLI 100A 1 160 0 205 2,432 14 6

WLI Inland Buoy Tender WLI 100C 1 160 0 205 2,068 12 5

WLI Inland Buoy Tender WLI 65303 2 160 0 205 1,037 12 5

WLI Inland Buoy Tender WLI 65400 2 160 0 205 1,142 13 5

WLIC Inland Construction Tender 115 1 160 0 205 2,796 16 6

WLIC 100 Cosmos Class Inland Construction Tenders 3 160 0 205 2,432 42 17

WLIC 75A Anvil Class Construction Tenders 2 160 0 205 1,753 20 8

WLIC 75B Inland Construction Tenders 3 160 0 205 1,753 30 12

WLIC 75D Clamp Class Inland Construction Tenders 2 160 0 205 1,753 20 8

WLIC 115 Inland Construction Tenders 1 160 0 205 2,796 16 6

WLIC 160 Pamlico Class Inland Construction Tenders 4 160 0 205 5,113 118 46

WLM White Sumac Class Coastal Buoy Tenders 9 123 16 200 4,648 217 85

WLM Keeper Class Coastal Buoy Tenders 14 123 16 200 6,408 465 183

T

Zero entered for number of transits per year when no further information was available.

nsp = not self-propelled

N/A = Not enough information available to calculate a wetted surface area.
Table 1. Navy, MSC, and USCG, Army, and Air Force Mass Loadings for Ships, and Small Boats and Craft

Ship Class Ship Class Description

Quantity of 

Ships per 

Class

Days in Port 

per Year

Number of 

Transits per year 

(each is a transit in 

and out)T

Days of 

Operation 

within 12 

n.m.

Ship's Wetted 

Surface Area (sq 

ft)

*Copper 

Loading per 

ship class 

(kg/yr)

**Zinc 

Loading per 

ship class 

(kg/yr)

WMEC Diver Class Medium Endurance Cutters 1 98 9 0 8,954 14 6

WMEC Storis Class Medium Endurance Cutters 1 167 11 0 9,498 26 10

WMEC Reliance Class Medium Endurance Cutters 5 235 13 0 10,976 207 82

WMEC Reliance Class Medium Endurance Cutters 11 149 9 0 10,976 290 114

WMEC Famous Class Medium Endurance Cutters 4 137 6 0 10,976 96 38

WMEC Famous Class Medium Endurance Cutters 9 164 7 0 10,976 259 102

WPB Island Class Patrol Craft A 16 135 6 200 2,171 185 73

WPB Island Class Patrol Craft B 21 135 6 200 2,171 243 96

WPB Island Class Patrol Craft C 12 135 6 200 2,171 139 55

WPB Point Class Patrol Craft B 1 135 6 200 1,243 7 3

WPB Point Class Patrol Craft C 28 135 6 200 1,243 185 73

WPB Point Class Patrol Craft D 8 135 6 200 1,243 53 21

WTGB Bay Class Icebreaking Tugs 9 215 1 150 4,869 253 100

WYTL 65 ft. Class Harbor Tugs A 3 50 6 300 1,083 18 7

WYTL 65 ft. Class Harbor Tugs B 3 50 6 300 1,083 18 7

WYTL 65 ft. Class Harbor Tugs C 3 50 6 300 1,083 18 7

WYTL 65 ft. Class Harbor Tugs D 2 50 6 300 1,083 12 5

ARMY

BCDK Barge, conversion deck enclosure kit 3 305 0 60 3,376 58 23

BD 89 Ton Derrick Barge (nsp) 12 335 0 30 10,442 722 285

BK Cargo Barge (nsp) 2 335 0 30 1,947 22 9

BPL Barge, pier, self-elevating 1 305 0 60 N/A -- --

FB 3 305 0 60 N/A -- --

FMS Floating Machine Shop 3 305 0 60 3,775 65 26

J-BOAT Workboat, Picket Boat 6 305 0 60 771 27 11

LARC-LX Lighter, Amphibious, Resupply, Cargo 23 305 0 60 1,209 160 63

LCM-8 Landing Craft, Mechanized 104 305 0 60 1,603 961 379

LCU-1600 1600 Class Landing Craft Utility 13 305 0 60 3,557 267 105

LCU-2000 2000 Class Landing Craft Utility 35 275 3 60 6,646 1,234 486

LSV Landing Ship, Vehicle 6 150 20 30 17,470 309 122

LT Large Tug (100'-128') 16 305 0 60 3,026 279 110

Q-BOAT Workboat (over 50') 1 305 0 60 -- --

ST-65 65 ft Small Tug 11 305 0 60 1,381 88 35

AIR FORCE

B Barge 4 305 0 60 N/A -- --

DT 2 305 0 60 N/A -- --

MR Missile Retrievers 6 305 0 60 1,954 68 27

TG Small Tug 2 305 0 60 721 8 3

TR Torpedo Retriever 3 305 0 60 2,127 37 14

Total Loading 98,257 38,725

* = Based on a dynamic copper leaching rate of 17 ug/cm2/day.

** = Based on a dynamic zinc leaching rate of 6.7 ug/cm2/day.

NOTES:

1) A transit includes inbound and outbound legs of 4 hours between the 12 n.m. limit and port.

2) Small boats and craft of the Navy were assumed to spend 365 days per year within 12 n.m. and 

60 of those days underway within 12 n.m.

T

Zero entered for number of transits per year when no further information was available.

nsp = not self-propelled

N/A = Not enough information available to calculate a wetted surface area.
Table 1. Navy, MSC, and USCG, Army, and Air Force Mass Loadings for Ships, and Small Boats and Craft

Ship Class Ship Class Description

Quantity of 

Ships per 

Class

Days in Port 

per Year

Number of 

Transits per year 

(each is a transit in 

and out)T

Days of 

Operation 

within 12 

n.m.

Ship's Wetted 

Surface Area (sq 

ft)

*Copper 

Loading per 

ship class 

(kg/yr)

**Zinc 

Loading per 

ship class 

(kg/yr)

3) Number of workboats estimated

4) Tank Landing Ships (LST) assumed to have similar operations to other amphibious assault ships

5) All vessels of the Army and Air Force assumed to have movement characteristics

similar to coastal vessels of the Navy

6) Italicized ship class descriptions are assumed, since only the ship class (letter) designation and quantity were provided.

T

Zero entered for number of transits per year when no further information was available.

nsp = not self-propelled

N/A = Not enough information available to calculate a wetted surface area.
Table 2. Estimated TBT Mass Loadings within 12 n.m. from Small Boats and Craft

Class Description Quantity Total Wetted Surface Area 

per Class (sq ft)

Navy Small Boats and Craft

PB Mark III Patrol Boats 11 1,835 20,185

PB Mark IV Patrol Boat 3 2,368 7,104

PBR Stinger Class River Patrol Boat 25 410 10,250

ATC Mini Armored Troop Carrierb

20 810 16,197

TR Torpedo Retrievers 22 2,127 46,794

HS Harbor Security Boat 70 189 13,230

LARC-LX Lighter Amphibious Resupply Cargo 23 1,214 27,922

WB Boom Handling Workboat 25 340 8,499

WB 35ft Workboatb.c 50 620 30,990

YP 654 Patrol Craft, Training 1 1,302 1,302

YP 676 Patrol Craft, Training 27 2,302 62,154

Total Number of Small Boats and Craft 277 Net Surface Area 244,627

Small Boats and Craft w/TBT Coatings 55 TBT Coated Area 48,572

Coast Guard Small Boats and Craft

Motor Lifeboats 6 535 3,213

Small Boats 44 513 22,576

TBT Coated Area 25,789

Army Small Boats and Craft

PB-HS Patrol Boat, High Speed 10 189 1,890

T-BOAT Small Freight (under 100') 1 not available

TBT Coated Area 1,890
Table 2. Estimated TBT Mass Loadings within 12 n.m. from Small Boats and Craft

Class Description Quantity

Vessel Wetted 

Surface Area (sq ft)a

Total Wetted Surface Area 

per Class (sq ft)

Air Force Small Boats and Craft

U

h Utility Craft j

47 398 18,706

P

i

Patrol Boat j3 1,235 3,704

TBT Coated Area 22,410

Total Surface Area of all Vessels with TBT Coatings (sq. ft) 98,661

Total Surface Area of all Vessels with TBT Coatings (sq. cm) 91,656,090

Loading (kg/yr) with 20% of Navy small boats and craft having TBT paint = 12.7

Final total (kg/yr) after adjusting for time spent out of water 11.4

Sample Calculation for TBT Loading per Vessel Class (kg/yr):

Quantity of Vessels x Vessel Wetted Surface Area (ft2) x TBT Leaching Rate (μg/cm2)/day... 

 ...x (0.90 x 365 days/yr) x (6.452 cm2/in2) x (144 in2/ft2) x (10-9 kg/mg)

Notes:

a) Where available, beam measurements are at the waterline.

b) This craft or boat is rectangular.

c) No information was available regarding quantities of workboats by class. The quantities listed are not reliable.

d) TBT Loadings based on all operations per ship occurring within 12 n.m. and applying a 10% factor to subtract the time

 that some small boats and craft spend completely out of water.

e) The steady state TBT leaching rate was taken from a Naval Command, Control & Ocean Surveillance Center RDT&E Division 

 Hull Coatings Discharge Evaluation on Butyltin Concentrations Measurements in Pearl Harbor, Hawaii from

 April 1986 to January 1988.

f) Steady-state TBT release rate assumed to be (0.38 μg/cm2)/day.

g) 20% of all Navy small boats and craft are assumed to have TBT coated hulls.

h) Air Force "P" designators are assumed to have similar size as the Coast Guard Point Class Patrol Craft.

i) Air Force "U" designator is assumed to have a similar size to the Navy utility boat.

j) Italicized ship class descriptions are assumed, since only the ship class (letter) designation and quantity were provided.
Table 3. A Comparison of Estimated Concentrations Versus Water Quality Criteria

Constituent

Estimated Environmental

Concentration (μg/L)a

Federal Chronic Water

Quality Criteria (μg/L)

Most Stringent State Chronic

Water Quality Criteria (μg/L)

Copper

 (dissolved)

0.19-3.0 2.4 2.4 (CT, MS)

Zinc

 (dissolved)

5.0-12.8 81 76.6 (WA)

TBT 0.00002 - 0.0003 0.01b0.001 (VA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

CT - Connecticut

MS - Mississippi

VA= Virginia

WA- Washington

a

 Range is for three high use Navy ports: San Diego, CA; Mayport, FL; and Pearl Harbor, HI.

b Proposed water quality criteria, August 7, 1997
Table 4. Copper and Zinc Loading into San Diego, Pearl Harbor, and Mayport for Use in 

Concentration Estimate

Ship Class Ship Class Description Quantity of Ships 

per Class

*Copper Loading 

per year (kg/yr)

*Zinc Loading 

per year (kg/yr)

SAN DIEGO HARBOR

CG 47 Ticonderoga Class Guided Missile Cruisers 8 813 320

CV 63 Kitty Hawk Class Aircraft Carrier 2 623 245

DD 963 Spruance Class Destroyers 6 616 243

DDG 51 Arleigh Burke Class Guided Missile Destroyers 5 263 104

LHA 1 Tarawa Class Amphibious Assault Ships 2 524 207

LHD 1 Wasp Class Amphibious Transport Docks 2 532 210

LPD 4 Austin Class Amphibious Transport Docks 5 743 293

LSD 41 Whidbey Island Class Dock Landing Ships 2 281 111

LSD 49 Harpers Ferry Dock Landing Ships 1 144 57

PC Cyclone Class Coastal Defense Ships 4 26 10

FFG 7 Oliver Hazard Perry Guided Missile Frigates 11 590 233

SSN Los Angeles Class Attack Submarines 9 914 360

SSN Sturgeon Class Attack Submarine 1 79 31

LSD Anchorage Class Dock Landing Ships 3 472 186

AGF Raleigh Class Miscellaneous Flagship 1 123 48

AS Emory S Land Class Submarine Tender 1 278 109

LPH Iwo Jima Class Assault Ship 1 150 59

Total Loading = 7,171 2,826

PEARL HARBOR 

AO 177 Jumboised Cimarron Class Oilers 2 382 150

ARS 50 Safeguard Class Savage Ships 2 91 36

CG 47 Ticonderoga Class Guided Missile Cruisers 3 305 120

DD 963 Spruance Class Destroyers 4 411 162

DDG 51 Arleigh Burke Class Guided Missile Destroyers 3 158 63

FFG Oliver Hazard Perry Guided Missile Frigates 2 107 42

SSN Los Angeles Class Attack Submarine 15 1,524 601

SSN Sturgeon Class Attack Submarine 4 316 125

SSN Benjamin Franklin Class Submarines 1 129 51

Total Loading = 3,423 1,350

MAYPORT HARBOR

CG 47 Ticonderoga Class Guided Missile Cruisers 5 508 200

CV 63 Kitty Hawk Class Aircraft Carrier 1 311 123

DD 963 Spruance Class Destroyers 5 514 202

DDG 51 Arleigh Burke Class Guided Missile Destroyers 2 105 41

FFG Oliver Hazard Perry Guided Missile Frigates 10 537 212

Total Loading = 1,975 778
Table 5. Estimated Copper and Zinc Contributions to Some Ports of the Armed Forces

Port Ambient Cu

Concentration

(μg/L)

Cu from Hull

Coating Leachate

(μg/L)

Ambient Zn

Concentration

(μg/L)a

Zn from Hull

Coating Leachate

(μg/L)

San Diego 3.7b0.19 11.3 0.074

Mayport Unknownc 3.0 5.0 1.16

Pearl Harbor 1.76a1.0 12.8 0.39

a

 Information from STORET database.

b For San Diego Bay, information from prior Navy Studies.

c

 Available STORET information was insufficient to make estimate.

Table 6. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents MSDS X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Copper Loading = (release rate)(surface area)(Number of ships)(time), where:

release rate = daily dynamic release rate of copper kg/cm2

surface area = wetted surface area of a DD 963 Class ship (cm2)

Number of ships = total number of ships in DD 963 Class

time = {∑ (time in port + time in transit + time in operation within 12 n.m.)}(number of DD 963 Class

ships)(number of days within 12 n.m. each year per ship)

1) Daily dynamic release rate of copper (From NRaD study)

= 17 (μg/cm2)/day = (17 (μg/cm2)/day) (1 kg / 1,000,000,000 μg) = 17 x 10-9 (kg/cm2)/day

2) Wetted surface area of a DD 963 Class ship in cm2 (From NSTM Chapter 633)

= (35,745 ft2) (929 cm2/ft2) = 33,207,105 cm2/ship

3) Number of DD 963 Class ships = 31 ships (From ship inventory database)

4) Number of days within 12 n.m. each year per ship (From ship movement database)

= days in port/year + [(transits/year) (2 legs/transit) (4 hrs/leg) (1 day/24 hours)] + days operation within 12 n.m./yr

= 178 days/yr + [(12 transits/yr) (2 legs/transit) (4 hrs/leg) (1 day/24 hrs)] + 0 days/yr = 182 days/yr

Thus:

Copper Loading = (17 x 10-9 (kg/cm2)/day )(33,207,105 cm2/ship)(31 ships)(182 days/yr)

= 3,185 kg/yr = 7,007 lbs/yr

Calculation Sheet 1. Mass Loading of Copper from DD 963 Class Vessels
Calculation Sheet 2. Estimates of Contributed TBT Concentrations by Harbor

Copper loading in San Diego = 7,171 kg/yr (See Table 4)

Copper loading in Pearl Harbor = 3,423 kg/yr (See Table 4)

Copper loading in Mayport = 1,975 kg (See Table 4)

Total copper loading = 98,257 kg/yr (See Table 1)

Proportion of copper loading in each harbor to the total copper loading:

San Diego = (7,171 kg/yr) / (98,257 kg/yr) = 0.073 (or 7.3%)

Pearl Harbor = 0.035 (or 3.5%)

Mayport = 0.020 (or 2%)

Total estimated TBT loading = 11.4 kg/yr (See Table 2)

Estimated TBT loading in each harbor = (copper proportion) (total TBT loading):

San Diego = (0.073) (11.4 kg/yr) = 0.8 kg/yr

Pearl Harbor = (0.035) (11.4 kg/yr) = 0.4 kg/yr

Mayport = (0.020) (11.4 kg/yr) = 0.2 kg/yr

Proportion of copper concentration in each harbor (Table 5) to annual copper loading

 in the respective harbor:

San Diego = (0.19 x 10-6 g/L Cu) / (7,171 x 103 g Cu) = 2.7 x 10-14

Pearl Harbor = (1 x 10-6 g/L Cu) / (3,423 x 103 g Cu) = 2.9 x 10-13

Mayport = (3 x 10-6 g/L Cu) / (1,975 x 103 g Cu) = 1.5 x 10-12

Estimated TBT concentration in each harbor is proportional to copper ratio:

San Diego: (0.19 μg/L Cu) / (7,171 kg Cu) = (X μg/L TBT) / (0.8 kg TBT)

 X = (2.7 x 10-14 ) ( 0.8 x 103 g TBT) = 2.2 x 10-5 μg/L TBT

 Pearl Harbor: X = (2.9 x 10-13 ) (0.4 x 103 g TBT) = 1.2 x 10-4 μg/L TBT

Mayport: X = (1.5 x 10-12 ) (0.2 x 103 g TBT) = 3.0 x 10-4 μg/L TBT
Hull Coating Leachate MPCD Analysis

1

HULL COATING LEACHATE

MARINE POLLUTION CONTROL DEVICE (MPCD) ANALYSIS

Several alternatives were investigated to determine if any reasonable and practicable

MPCDs exist or could be developed for controlling discharges from hull coatings. An MPCD is

defined as any equipment or management practice, for installation or use onboard a vessel,

designed to receive, retain, treat, control, or eliminate a discharge incidental to the normal

operation of a vessel. Phase I of UNDS requires several factors to be considered when

determining which discharges should be controlled by MPCDs. These include the practicability,

operational impact, and cost of an MPCD. During Phase I of UNDS, an MPCD option was

deemed reasonable and practicable even if the analysis showed it was reasonable and practicable

only for a limited number of vessels or vessel classes, or only on new construction vessels.

Therefore, every possible MPCD alternative was not evaluated. A more detailed evaluation of

MPCD alternatives will be conducted during Phase II of UNDS when determining the

performance requirements for MPCDs. This Phase II analysis will not be limited to the MPCDs

described below and may consider additional MPCD options.

MPCD Options

Hull coating leachate refers to the transfer by diffusion or ablation of coating constituents

from the underwater portion of a vessel’s hull into the water. The anticorrosive (AC) and

antifouling (AF) coating system minimizes adhesion and propagation of marine fouling organisms

on the hull surface which increase drag, and prevents costly structural damage to the hull (metal

or material loss) which would otherwise result from long-term exposure to seawater. Without

effective antifouling coatings, ships’ hulls would have to be cleaned or dry docked and repainted

much more frequently; thereby expending time, money, and manpower, while compromising

operational readiness.

To determine the practicability of mitigating the potentially adverse environmental effects

of hull coating leachate, three potential MPCD options were investigated. The purpose of these

MPCDs would be to reduce or eliminate the release of antifouling agents, specifically copper and

tributyltin, from antifouling hull coatings. The MPCD options were selected based on initial

screenings of alternate materials, equipment, pollution prevention options, and management

practices. They are listed below with brief descriptions of each:

Option 1: Use Less Toxic Fouling Release Coatings - This option would require that

hulls be coated with less toxic paints that may initially foul, but readily release fouling

organisms when the vessel reaches a target speed.

Option 2: Control the Maximum Allowable AF Release Rate - This option would set

limits on the maximum allowable release rate of copper from fouling resistant coatings to a

level known to effectively control fouling but not cause an excess of copper to be released.
Hull Coating Leachate MPCD Analysis

2

Option 3: Limit or Eliminate Use of Tributyltin (TBT) Paints - The goal of this

option is to further reduce or eliminate the use of TBT paints on Armed Forces vessels.

MPCD Analysis Results

Table 1 shows the results of the MPCD analysis. It contains information on the elements

of practicability, effect on operational and warfighting capabilities, cost, environmental

effectiveness, and a final determination for each option. Based on these findings, Option 2 –

establishing the maximum release rate of copper in AF coatings, and Option 3 – further restricting

the application of TBT paints on vessels of the Armed Forces, offer the best combination of these

elements and are each considered to represent a reasonable and practicable MPCD.
Hull Coating Leachate MPCD Analysis

3

Table 1. MPCD Option Analysis and Determination

MPCD Option Practicability Effect on Operational &

Warfighting Capabilities

Cost Environmental

Effectiveness

Determination

Option 1. Use Less

Toxic Fouling Release

Coatings

Since 1993, the Navy has

been investigating nonpolluting antifouling hull

coatings and, as part of this

program, silicone-based

coatings are being tested on

Navy ships. When the tests

are completed, the coating

must demonstrate a five to

twelve year service life, ease

of self and mechanical

cleaning, good adhesion to

various hull substrates, and

overall durability. The

coating may not be suitable

for low speed ships.

If the new coating does not

perform on Navy ships as

well as the current coatings,

marine fouling will

increase, detrimentally

affecting the ship’s acoustic

signature, vessel speed,

endurance, maneuverability,

and fuel consumption.

Costs for this option include

research and development

costs and an estimated fourfold increase in paint costs.

If the self-cleaning coating

is not as effective at biofouling prevention as

current hull coating

technologies, maintenance

costs will increase and fuel

costs could increase by

15%.1 If the self-cleaning

coating is effective,

maintenance costs will

decrease. Disposal costs

will decrease because

hazardous waste is no

longer generated.

Use of less toxic coatings

would significantly reduce

the amount of copper and

zinc discharged from

antifouling hull paints.

Using less toxic fouling

release coatings would

reduce toxic discharge

levels, but may not

effectively prevent hull

fouling which would

adversely affect ship

capabilities and increase

fuel and maintenance costs.

The technology has not yet

been proven aboard vessels

of the armed forces.

Option 2. Control the

Maximum Allowable AF

Release Rate

This option could be

implemented by

establishing a maximum

copper release rate that is

near the release rate of the

lowest acceptable release

rate. The Navy has tested

ablative copper paints

containing 28-32% cuprous

oxide, as opposed to the

standard 40-50%.2 These

trial formulations of AF

coatings did not prevent

fouling. Setting the release

rate below what is

determined to be effective

Ship capabilities will not be

affected if limits are set

near current copper release

rates. If the maximum

copper release rate is set

below what is effective in

preventing hull fouling then

noise emissions will

increase, affecting acoustic

signature; maximum speed

will decrease; and the

frequency of hull cleanings

will increase, affecting ship

mobility and availability.

In order to accurately define

minimum copper release

rates, it would cost an

estimated $300K to $500K.

If hull fouling is not

adequately prevented, there

will be an increase in fuel

and maintenance costs.

This option would prevent

future increases in ambient

water concentrations of

copper from hull coatings,

and would potentially

reduce copper discharge

quantities.

Establishing a maximum

copper release rate: 1) can

be implemented, 2) would

be inexpensive to institute,

and 3) would prevent future

increases in copper

loadings. This MPCD

warrants further

consideration in Phase II.
Hull Coating Leachate MPCD Analysis

4

MPCD Option Practicability Effect on Operational &

Warfighting Capabilities

Cost Environmental

Effectiveness

Determination

Option 2 (continued)

would be impractical

because of the potential for

excess fouling and

increased rates of hull

cleaning.

Option 3. Limit or

Eliminate Use of TBT

Paints

The Armed Forces have

been phasing out the use of

TBT paints since 1988, and

replacing them with copperor silicone-based coatings.

Copper-based AF paints

accelerate corrosion of

aluminum substrates.

Newer silicone-based

coatings are only effective

when the vessel reaches a

minimum effective speed,

which some Navy and

USGS vessels are unable to

attain. Exceptions could be

provided for critical use

vessels.

No AF alternative as

effective as TBT selfpolishing copolymer paint

has been found so, without

the use of TBT, underwater

hull fouling is expected to

increase causing a negative

impact on acoustic

signature, maximum ship

speed, hull cleaning

frequency, and ship

readiness.

Assuming TBT paint is

replaced by silicone-based

easy release coatings,

material costs could

increase by $91K for all

remaining small boats, fuel

costs will increase, and

maintenance costs may

increase if ships have to be

recoated more frequently,

yet disposal costs will

decrease since TBT is a

hazardous waste.

Prohibiting the use of TBT

as an antifouling hull

coating for non-critical

Navy and USCG small

boats will be effective in

reducing TBT loadings.

Approximately 80% of the

estimated 11 kg (24 lbs) of

TBT released annually by

the Armed Forces could be

eliminated. If replaced by

copper-based AF coatings,

total copper loading from

hull coatings will increase

slightly.

Further restricting the use

of TBT paints is: 1)

reasonable to implement, 2)

not cost prohibitive, and 3)

will significantly reduce

TBT loadings in the

environment. Therefore,

this MPCD option warrants

further consideration.
Hull Coating Leachate MPCD Analysis

5

REFERENCES

1

 Naval Ships’ Technical Manual S9086-CQ-STM-010 R3 Chapter 081, Waterborne Underwater

 Hull Cleaning of Navy Ships. 4 August 1997. Page 1-1.

2

 EPA and the Secretary of the Navy. “Congressional Report on Alternatives to Organotin

Antifoulants and Alternative Antifoulant Research.” December 1996. Pages 8, 29.
Mine Countermeasures Equipment Lubrication

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Mine Countermeasures Equipment Lubrication
Mine Countermeasures Equipment Lubrication

2

2.0 DISCHARGE DESCRIPTION

This section describes the mine countermeasures discharge and includes information on:

the equipment that is used and its operation (Section 2.1), general description of the constituents

of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

The Navy is the only branch of the Armed Forces with a mine countermeasures mission.

To accomplish this mission, mine countermeasures vessels use towed sonar and video arrays,

cable cutters, and mine detonation equipment. During training exercises, the mine

countermeasures equipment is deployed and towed behind the ship as it practices sweeping the

area for mines.

Specific types of mine countermeasures equipment are:

• devices to detonate acoustic mines, such as acoustic hammers and vibrating

diaphragms;

• robotic devices (mine neutralization vehicles) which locate and destroy mines;

• devices which generate magnetic fields to explode magnetic mines;

• minehunting sonar; and

• cables fitted with mechanical or explosive cutters to cut the cables of moored

mines.

Mine countermeasures equipment is normally located at the stern or fantail portion of

mine countermeasures vessels. Most equipment is non-magnetic, and winches and cranes are

hydraulically powered. Brief descriptions of the specific mine countermeasures equipment used

by the Navy are presented below:1

A-MK4-V and A-MK6-B mine detonators use vibrating diaphragms and

acoustic hammers, respectively, to generate noise and detonate acoustic mines.

When deployed, both types of acoustic detonators are towed astern on buoyant

1,600-foot-long cables. Both types of detonators are not deployed simultaneously

but rather, one detonator type is selected for a given minesweeping event,

depending on the type of mine targeted.

Magnetic minesweeping cables float, are trailed astern of the ship, and generate

large electric currents through the water. This creates a magnetic field around the

cable which detonates magnetic mines. Several cable configurations are used and

all are carried on a common cable reel drum with three sections. Cable lengths

range from 450 to 1,800 feet for the various configurations.

AN/SLQ-48 mine neutralization vehicles (MNVs) are cable-controlled,

unmanned robotic devices used to locate and destroy mines. They contain closedcircuit television cameras and close-range sonar for locating mines, that are then
Mine Countermeasures Equipment Lubrication

3

destroyed using cable cutters or small explosive charges. A crane with a lifting

cable is used to deploy and recover the AN/SLQ-48 MNV on some vessels. A

5,000-foot-long cable is used to supply power.

AN/SQQ-32 sonar tow cables and reels are used to tow and supply power to

AN/SQQ-32 variable-depth, mine-hunting sonars.

AN/SQQ-30 sonar tow cable and reels are used to tow and supply power to

older, less-capable mine hunting sonars used on some ships. These systems will

eventually be replaced with AN/SQQ-32 sonars.

O-type mechanical gear is used to sweep moored mines. It consists of wire

cables towed through the water at depths where it can strike the mine’s mooring.

The mooring slides along the cable until it contacts mechanical or explosive

cutters, which sever the mooring. The mines then bob to the surface where they

are detonated by gunfire.

A typical layout of mine countermeasures equipment on the fantail of a mine

countermeasures ship is provided in Figure 1. Figure 2 shows a schematic of an O-type setup

used to sweep moored mines.1

2.2 Releases to the Environment

This discharge consists of the lubricating grease and oil removed by the mechanical

action of seawater as the equipment is towed. Greases and oils are used externally on wetted

equipment (e.g., blocks, swivels, and cutters) to minimize wear and to prevent the mine

countermeasures equipment from binding as it is deployed.2 Tow cables are made of stainless

steel and are not lubricated, with the exception of the lifting cable on the crane of MHC 51 Class

vessels, which is grease-lubricated.3,4 Grease and oil application procedures are discussed in

Section 3.

Lubricants used on mechanical components inside the water-tight compartments of towed

acoustic and electromagnetic devices are not released from the devices to the sea. Neither are

leaks and spills of lubricants to the deck from non-wetted, on-board mine countermeasures

equipment; these are cleaned-up and contained using rags or other sorbents.5

2.3 Vessels Producing the Discharge

Mine countermeasures equipment is found on only two classes of Armed Forces vessels:

the Navy’s Osprey (MHC 51) Class, and the Navy’s Avenger (MCM 1) Class.1 The nine MHC

51 Class coastal minehunters perform harbor clearing, channel clearing, and deep-water coastal

mine countermeasures. The MCM 1 Class has 14 vessels designed to locate and destroy mines

that cannot be countered by conventional minesweeping techniques. Table 1 shows the vessels

producing the mine countermeasures equipment lubrication discharge.1
Mine Countermeasures Equipment Lubrication

4

Both the MCM and the MHC classes are equipped with a hull-mounted, variable-depth

sonar (VDS) (either a SQQ-30 or a newer SQQ-32) as their primary means of mine detection,

and a cable-controlled and powered SLQ-48 Mine Neutralization Vehicle (MNV) for the

examination and clearing of mines.

MHC 51 Class vessels are equipped only with the SLQ-48 MNV and the SQQ-32 sonar. 

The SQQ-32 is retained in its hull-mounted position unless the vessel is actually engaged in

minehunting, when it may be towed. An MHC conducts minehunting operations at speeds of five

to seven knots. At these speeds, depending upon its deployed depth, the 7,846-pound towed body

of the SQQ-32 tows directly beneath or sometimes slightly astern of the MHC.6 To sweep or

neutralize mines, the SLQ-48 is deployed. It is a self-propelled vehicle, controlled and powered

through a 5,000-ft cable, and is remotely ‘piloted’ by an operator on the MHC.

In addition to a SQQ sonar and a SLQ-48 MNV, MCM 1 class vessels are equipped with

the O-type mechanical gear, magnetic minesweeping cables, and A-MK4-V and A-MK6-B mine

detonators described in Section 2.1.7 Like the MHCs, MCMs retain their SQQ sonar in the hullmounted position unless the vessel is engaged in minehunting. MCMs generally deploy their gear

based on the type of mine being targeted: the SLQ-48 MNV for deep bottom mines, O-type

mechanical sweep gear for shallow moored mines, and acoustic and magnetic detonators for

acoustic and magnetic mines.

The SQQ sonar is mostly operated in the hull-mounted position. It is not towed while any

of the sweeping gear is deployed. The MNV is usually deployed by itself. However, because it is

controlled and can remain clear of streamed gear whenever it must be deployed, it can be deployed

with any of the other gear.6 Although they may be streamed together, the O-type and magneticacoustic gear are usually streamed individually. The O-type gear fans out when streamed (see

Figure 2), while the magnetic-acoustic gear streams directly astern in the absence of current. The

only chance for interference between O-type and magnetic-acoustic gear, when streamed together,

is during ship’s turns, which must be wide and slow.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Discharges from mine countermeasures equipment incidental to normal operations occur

only during training exercises usually held between five and 12 n. m. from shore, and sometimes

as far as 20 to 50 n. m. from shore.8
Mine Countermeasures Equipment Lubrication

5

3.2 Rate

This discharge is not a flow; rather, it is the release of lubricant to the surrounding

seawater by mechanical erosion or dissolution when equipment is towed. During training

exercises, the conventional mine countermeasures equipment is deployed and towed behind the

ship as it sweeps the area.2 Based on information from the Naval Undersea Warfare Center and

on planned maintenance system (PMS) requirements, small amounts of lubricants are applied to

various parts of the towed equipment.2,9 Thus, there is a potential for these lubricants to be

released to the surrounding waters.

Due to differences in equipment and mission assignments between the two vessel classes,

the discharges produced by the MHC 51 and MCM 1 Class vessels are different. For this reason,

the two vessel classes are discussed individually, and producing the greatest discharge scenarios are

developed for each vessel class. Calculations are based on all mine countermeasures vessels

operating in U.S. waters (i.e., none are under repair or deployed overseas).

3.2.1 MHC 51 Class Vessels

An MHC 51 Class vessel averages about five training days per month, with a maximum of

four two-hour exercises each training day.10 Thus, for a given ship, the total number of exercises

per year is equal to:

(5 days/month)(4 exercises/day)(12 months/year) = 240 exercises per year for each ship

For the nine existing MHC 51 Class vessels (Section 2.3), this is a total of 2,160 exercises

per year.

MHC 51 Class vessels are equipped with SQQ-32 sonar and the SLQ-48 MNV. The sonar

has no lubricated areas exposed to seawater during operation and, as discussed in Section 2.2, tow

cables are not greased. Therefore, there is no potential for grease being released during SQQ sonar

deployment.

The SLQ-48 MNV has two arms which are controlled by a remote operator, or “pilot”, to do

work. Each arm has a cavity which receives approximately 2 ounces of DOD-G-24508 grease to

prevent equipment binding.11 A conservative assumption, however, is that all of the grease in the

cavities is washed out during deployment (i.e., 4 ounces per deployment).

The lifting cable used for deploying the SLQ-48 MNV is lubricated with approximately 3

ounces of MIL-G-18458 grease. This cable is in contact with the water only during the vehicle's

launching and recovery, during which time the vessel is stationary. Equipment experts estimate

that during deployment this cable is in the water less than 1 minute, and during recovery for 3 to

5 minutes.12 Therefore, the total amount of time the lift cable is in contact with seawater is

approximately 5 minutes during each exercise.

The specification for the lift cable grease requires conformance with several chemical and
Mine Countermeasures Equipment Lubrication

6

physical standards, one of which is an adhesion test. In this test, grease is applied to a concave

disk of known weight. The greased disk is then weighed to determine the weight of grease

applied. The disk is submerged in 151°F water for 15 minutes, and then rotated at approximately

150 revolutions per minute for an additional 15 minutes. The disk is then weighed to determine

the quantity of grease which has either eroded or dissolved. To pass this test, a minimum of 95%

of the applied grease must remain on the disk as determined by the final weight of the disk after

the test.13

For the deployment of the SLQ-48 MNV, the grease on the lift cable is exposed to

comparatively milder conditions. The water temperature will be lower, the exposure time will be

less, and because the vessel is stationary, there will be little or no mechanical erosion. The

maximum estimate of the grease discharged from the lift cable is 5 percent of the applied grease.

This would be equal to 0.15 ounces of grease discharged per deployment.

3.2.2 MCM 1 Class Vessels

MCM 1 Class vessel training exercises consist either of a sweeping or a hunting task, and

the dimensions of the exercise area vary with each exercise. For example, an assigned area may

measure as much as 30 by 90 miles. Each MCM is assigned one sweeping and one hunting task

each month. Thus, as a conservative estimate, each MCM on average deploys various

combinations of its countermeasures equipment 24 times a year, and performs each type of

operation 12 times per year. Unless some problem is experienced with the equipment while

deployed, it remains in the water for the duration of the exercise, which may last 24 hours a day for

up to 5 days.10,11

For minehunting, the MCM Class 1 vessels use the same equipment as the MHC 51 Class

vessels; the SQQ sonar and the SLQ-48 MNV. However, the MCMs use non-greased nylon lifting

cables when launching and recovering the SLQ-48 MNV, so no potential exists for the release of

cable grease to the surrounding water.12

The MCM mine neutralization vehicle hoist arrangement provides three weight-bearing

cables to handle the 2,750 pound vehicle. This allows nylon cables to handle the load. The crane

of the MHC 51 Class vessel attaches to the vehicle with only a single cable, which precludes the

use of a nylon cable.

Neither the SQQ-30 nor the SQQ-32 sonar expose lubricants to the surrounding seawater.

As noted previously, the largest discharge is a four ounce discharge of DOD-G-24508 grease from

the arms of the SLQ-48 MNV during each of the 12 exercises conducted annually.

For minesweeping operations, either O-type gear is deployed, or magnetic and acoustic

detonators are deployed. For the 12 sweeping exercises conducted annually, operational experience

shows that O-type gear is deployed half of the time (six out of 12) and magnetic and acoustic

detonators are deployed half of the time (six out of 12). In an O-type gear double sweep array, there

are cables, chains, and wires, which are not lubricated. In addition, there are eight cutters, two

snatch blocks, three shackles, and 13 swivels that are lubricated. The swivels have fittings through
Mine Countermeasures Equipment Lubrication

7

which MIL-G-23549 grease is applied; each swivel is then wiped clean. Only the threads of the

shackles are greased. The bearing surfaces of the snatch block rollers are given a light coat of MILL-3150 oil. Since the bearing surfaces are recessed within the block, they are minimally exposed to

seawater turbulence while being towed. The cutters are fabricated of a non-ferrous alloy. When

retrieved, they are washed with freshwater, dried, and given a light coat of MIL-L-9000 oil before

being stowed. No additional lubrication is applied before they are re-deployed.14

An estimate of the amount of lubricant (combined oil and grease) that is discharged is 1

ounce for each component, or 26 ounces during each of the six exercises using O-type gear.

8 cutters + 2 snatch blocks + 3 shackles + 13 swivels = 26 components total

For the six magnetic and acoustic exercises conducted each year, the MCM streams the

magnetic minesweeping cable and either a high frequency A-MK4-V or a low frequency A-MK6-B

acoustic detonator.6 The only lubricant exposed to the turbulence of the seawater while streaming

the magnetic and acoustic detonators is on the 30-inch diaphragm of the A-MK4-V detonator,

which is coated with about 4 ounces of DOD-G-24508 grease.8,15 The A=-MK6-B low frequency

detonator does not have a diaphragm that requires grease. The magnetic minesweeping cable and

the power cable to the acoustic detonators are buoyant; however, the streamed acoustic detonator

does require a large O-type float in order to stream properly. A wire pendant of the desired length

secures each acoustic detonator to its large float by a swivel whose zerk fitting has about 1 ounce of

MIL-G-23549 grease pumped into it.10 Therefore, when a high frequency acoustic detonator is

streamed with the magnetic minesweeping cable, approximately five ounces of grease (four from

the diaphragm and one from the swivel) are exposed to the sea. When the low frequency acoustic

detonator is used, the amount of grease that could be released is one ounce (from the detonator’s

swivel to its buoy float).

3.3 Constituents

Several types of lubrication oils and greases are used on wetted mine countermeasures

equipment based on information in maintenance requirements cards. Table 2 shows a list of the

lubricant types and the lubrication schedules for the mine countermeasures equipment.9 The

greases are made from lubricating stocks generated during petroleum fractionation. These

fractions contain organic compounds each generally having more than seventeen carbon atoms.

Lubricating oils are composed of aliphatic, olefinic, naphthenic (cycloparaffinic), and aromatic

hydrocarbons depending on their specific use. Lubricating oil additives include antioxidants,

bearing protectors, wear resistors, dispersants, detergents, viscosity index improvers, pourpoint

depressors, and antifoaming and rust-resisting agents.16

Until recently, lead was contained in the MIL-G-18458B grease procured by the Navy to

lubricate the MHC’s lift cable which deploys and recovers the SLQ-48 MNV. However,

Amendment 5 to MIL-G-18458B dated 26 March, 1996, prohibits heavy metals (including lead)

and salts of heavy metals as constituents of MIL-G-18458B grease.13 As such, the Navy is no

longer procuring grease containing lead or any heavy metals for use in lubricating mine

countermeasures equipment. Consequently, lead will not be considered a constituent of this
Mine Countermeasures Equipment Lubrication

8

discharge.

There are no known bioaccumulators in this discharge.

3.4 Concentrations

Table 3a shows the percentages of the constituents in oils and greases used on the mine

countermeasures wetted equipment. The total of the base constituents of oils and greases (i.e.,

the hydrocarbons -- mineral oils through the asphalts and waxes (e.g., the heavy paraffinic

distillates)) range in concentration from approximately 25% to greater than 90%, with additives

making up the balance of these lubricants. Tables 3b through 3d show the maximum

concentrations from SLQ-48 arms, O-gear and cutters, and acoustic and magnetic devices,

respectively.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality standards. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The estimated annual lubricant mass loading shown in Table 4 is based upon the

discharge scenarios described in Section 3.2, the number of exercises performed annually, and

the number of vessels involved.

4.2 Environmental Concentrations

The estimated quantities of lubricant released to the environment during each mine

countermeasures training exercise are shown in Table 4. The concentration after dilution in the

environment can be estimated using the mass loadings from Table 4 and estimates of the

volumes of water through which the equipment is towed during various exercises. These

estimates are provided in Sections 4.2.1 through 4.2.4 for each of the source/vessel combinations

identified in Section 3.2 and Table 4. Section 4.2.5 provides information on applicable water

quality standards.

4.2.1 SLQ-48 MNV Arms

As shown in Table 4 and discussed in Section 3.2, the estimated maximum amount of

grease discharged from the SLQ-48 MNV is 4 ounces (0.25 pounds (lbs)). This assumes that the

screws that seal both cavities come unscrewed and fallout undetected, allowing all of the applied

grease to be released. While this is based on equipment failure and does not reflect typical
Mine Countermeasures Equipment Lubrication

9

operating conditions, it does provide a conservative assumption regarding the amount of grease

released during operations.

For MHC 51 Class vessels, minehunting operations are performed at a speed of 5 knots

(30,381 feet per hour (ft/hr)) for a duration of 2 hours.14 The calculated concentration of

lubricant in the environment from SLQ-48 MNV arms assumed that:

• the SLQ 48 MNV creates a nine square feet (three feet by three feet) area of turbulence in

the wake of the vehicle, as determined by dimensions of the vehicle’s cross-sectional

area;

• the discharge rate of grease is uniform throughout the exercise;

• the grease is uniformly dispersed throughout the traversed water volume

Based upon operational experience, it was determined that the SLQ-48 MNV generates a

wake in the same manner as a surfaced submarine. Thus the frontal area of the vehicle, as

determined by the dimensions of its cross-sectional area, creates a ninesquare feet (three feet by

three feet) area of turbulence17 where complete mixing occurs. Therefore, an area of nine square

feet was used in the following formula to calculate the mixing and dispersion of oil and grease

caused by the turbulence of the vehicle’s wake rather than the frontal area of the arms.

The volume of water through which the equipment operates during a single exercise was

calculated using the following formula:

Based on the assumptions listed above and the volume of water through which the

equipment operates, the lubricant concentration in the environment was estimated as follows:

The calculated value of 7.3 μg/L is three orders of magnitude less than the most stringent

state water quality criteria of 5,000 μg/L (Florida).

4.2.2 SLQ-48 MNV Lift Cable

From Table 4 and the discussion in Section 3.2.1, the maximum amount of grease

released from the lift cable during each deployment of the SLQ-48 MNV is 0.15 ounce (0.0094

Volume = (Area)(Time)(Speed)

Volume = (9 square feet)(2 hours)(30,381 ft/hr)

Volume = 546,858 cubic feet (ft3) of water

 Mass lubricant = (0.25 lbs lubricant)(453.6 grams (g)/lb)(1000 milligrams/g)

= 113,400 milligrams (mg) lubricant

 Volume of water = (546,858 ft3)(28.32 liters (L)/ft3) = 15,487,019 L

 Concentration = 113,400 mg lubricant/15,487,019 L

= 0.0073 mg/L, or 7.3 micrograms per liter (μg/L)
Mine Countermeasures Equipment Lubrication

10

lbs). The grease would be released to the water in the immediate vicinity of the lift cable during

deployment/retrieval of the SLQ-48 MNV since the vessel is stationary. The potential for

environmental impact from this operation was estimated by determining the volume of water into

which the grease would have to be dispersed to attain a concentration equal to the most stringent

state water quality criteria: Florida’s criteria of 5,000 μg/L, or 5 mg/L.

The calculated volume required for dilution of lubricant in the environment from the

SLQ-48 MNV lift cable was based on the following assumptions:

• the top of the vehicle is covered by one foot of water during launching;

• the grease released is directly above the vehicle; and

• the lubricant disperses only in the horizontal plane; that is, the body of the vehicle

prevents vertical dispersion

Based on these assumptions, the distance from the source beyond which the concentration

is less than the most stringent water criteria (Florida), was estimated as follows:

At a distance of approximately 3 feet beyond the lifting cable, the concentration of the

grease is less than the most stringent water quality criteria.

4.2.3 O-type Mechanical Gear

From Table 4 and the discussion in Section 3.2, the maximum amount of lubricant

released from O-type mechanical gear is 26 ounces (1.63 lbs). Each lubricated component (26

total components) of the O-type gear is a separate discharge point, has a cross-section of 48 in2

(0.33 ft2), and sweeps a volume of water equal to its cross-section multiplied by the distance

towed through the water at seven knots. Operations with O-type gear deployed are limited to

speeds of 7 to 8 knots (42,533 to 48,609 ft/hr).14

The equipment may remain deployed for several days (Section 3.2). Thus, the lubricants

that are released from the equipment to the environment during minesweeping exercises with Otype mechanical gear will be dispersed over several miles.

An estimate of the concentration of lubricant in the environment was made based on the

following assumptions:

• the equipment is deployed for 1 day; or 24 hours

• the rate of lubricant discharge is uniform throughout the exercise;

• the lubricant is uniformly dispersed throughout the traversed water volume

1) (0.0094 lbs grease)(453.6 g/lb) = 4.3 g; equal to 4300 mg grease

2) 4300 mg ÷ (Vol.) = 5.0 mg/L; Vol. = 860 L required

3) (860 L)(1 ft3/28.32 L) = 30.36 ft3

4) 30.36 ft3 = (1 ft)(π)(r2); rearranging and solving for r, r = 3.1 feet
Mine Countermeasures Equipment Lubrication

11

At 7 knots (42,533 feet per hour), the volume of water swept by the equipment during the

training exercise was estimated as follows:

Volume = (# of components)(Cross-sectional area of each component)(Time)(Speed)

Volume = (26)(0.33 square feet)(24 hours)(42,533 ft/hr)

Volume = 8.76 x 106 cubic feet (ft3) of water

Based on the assumptions listed above and the volume of water through which the

equipment is towed, the lubricant concentration in the environment was estimated as follows:

This concentration is three orders of magnitude less than Florida’s discharge standard of

5,000 μg/L and is based on the conservative assumption that the equipment is in the water for

only 24 hours.

4.2.4 Acoustic and Magnetic Mine Detonators

From Table 4 and the discussion in Section 3.2, the maximum amount of lubricant

released from acoustic and magnetic mine detonation devices is five ounces (0.3125 pound).

Operations are usually performed at speeds of 7 to 8 knots (42,533 to 48,609 ft/hr).14 As with the

O-type mechanical gear, the equipment may remain deployed for several days. Thus, any

lubricant removed from the equipment will be dispersed into a large volume of water.

An estimated lubricant concentration was made based on the following assumptions:

• the equipment is deployed for 1 day; or 24 hours

• the rate of lubricant discharge is uniform throughout the exercise;

• the lubricant is uniformly dispersed throughout the traversed water volume;

• the acoustic device has a frontal area equivalent to a 36-inch diameter disk (7.07

square feet) (this assumption is based on allowing space for the housing around

 Mass lubricant = (1.625 lbs lubricant)(453.6 g/lb)(1000 mg/g)

= 737,100 mg lubricant

 Volume of water = (8.76 x 106 ft3)(28.32 L/ft3) = 2.48 x 108 L

 Concentration = 737,100 mg/2.48 x 108 L

= 2.97 x 10-3 mg/L; or 2.97 μg/L in a 24-hour period

Volume = (Number of components)(Cross-sectional area of each

component)(Time)(Speed)

Volume = (26 components)(0.33 ft)(24 hours)(42,533 ft/hr)

Volume = 8.76 x 106 ft3 of water
Mine Countermeasures Equipment Lubrication

12

the acoustic device), plus a 2- by 4-inch (0.055 ft2) swivel.

At 7 knots (42,533 ft/hr), the volume of water swept by the equipment during the training

exercise was estimated as follows:

Based on the assumptions listed above and the volume of water through which the

equipment is towed, the lubricant concentration in the environment was estimated as follows:

This estimated concentration of 0.688 μg/L is three orders of magnitude below the most

stringent water quality criteria.

4.2.5 Water Quality Criteria and Discharge Standards

Table 5 shows water quality criteria and discharge standards that are relevant to the mine

countermeasures equipment lubrication discharge and the estimated environmental

concentrations of the constituents of the discharge.

4.3 Potential for Introducing Non-indigenous Species

Mine countermeasures operations do not result in water being transported from one

geographical region to another. Any non-indigenous species which may become attached to

countermeasures equipment while deployed are removed during equipment retrieval operations

or subsequent preventive maintenance activities. For example, automatic cable layers remove

virtually all of the water from the cable(s) as they are retrieved, and maintenance procedures

require freshwater washdowns of the retrieved equipment such as cutters and swivels. Further, it

is unlikely that any attached aquatic species would survive while the countermeasures equipment

is stored on deck. Therefore, there is no significant potential for transporting non-indigenous

species.

5.0 CONCLUSIONS

Mine countermeasures equipment lubrication discharge has little potential for causing

Volume = (Area)(Time)(Speed)

Volume = (7.07 + 0.055 square feet)(24 hours)(42,533 ft/hr)

Volume = 7.27 x 106 ft3 of water

Mass lubricant = (0.3125 lbs lubricant)(453.6 g/lb)(1000 mg/g)

= 141,750 mg lubricant

Volume of water = (7.27 x 106 ft3)(28.32 L/ft3) = 205,886,400 L

Concentration = 141,750 mg/205,886,400 L

= 6.88 x 10-4 mg/L; or 0.688 μg/L
Mine Countermeasures Equipment Lubrication

13

adverse environmental effects because the small amounts of lubricants that are released disperse

into very large volumes of water. The resulting concentrations are below the most stringent

water quality criteria.

Further, most discharges from mine countermeasures equipment occur beyond 5 n.m.

from shore in high-energy waters (i.e., those with significant wave energy to rapidly and widely

disperse releases) and are unlikely to affect more sensitive coastal environments.

This conclusion is based on estimated environmental concentrations of lubricants

resulting from each of the mine countermeasures operations. For each operation, the estimated

concentration was below the most stringent water quality criteria. Estimates were based on either

the volume of water through which mine countermeasures equipment operates, or the volume

required to dilute the discharge to levels below the most stringent water quality criteria.

Finally, for mine countermeasures operations there is no potential for transporting nonindigenous species.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained, reviewed,

and analyzed. Process information and assumptions were used to estimate the rates of discharge.

Based on these estimates, the concentrations of lubricants in the environment resulting from this

discharge were then estimated. Table 6 shows the sources of data used to develop this NOD

report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Mine Countermeasures Equipment

Lubrication. 5 September 1996.

2. BM2 Hamilton , USS Champion (MCM 4), Information on Oil and Grease Lubrication

Procedures, 23 July 1997, Jim O’Keefe, MR&S.

3. CDR Burdon, OPNAV Mine Warfare Branch (N852), Information on Mine

Countermeasure Training Areas and Operations, 6 August 1997, Jim O’Keefe, MR&S.

4. UNDS Round 2 Equipment Expert Meeting Minutes, Mine Countermeasures Equipment

Lubrication, 6 March 1997.

5. LCDR Sentlinger, XO on an MCM 1 Class Ship Based in Ingleside, TX, Information on

Lubrication Procedures, 19 March 1997, Sanjay Chandra, Versar Inc.

6. LCDR Shaun Gillilland, OPNAV, Mine Warfare Branch, Information on SQQ Sonars

and Acoustic Detonator Operations, 20 January 1999, Jim O’Keefe, MR&S.
Mine Countermeasures Equipment Lubrication

14

7. Polmar, Norman. The Naval Institute Guide to the Ships and Aircraft of the U.S. Fleet,

16th ed., Naval Institute Press, 1997, Chapter 22.

8. Andy Tatem, Naval Undersea Warfare Center, Panama City, FL, Information on Oil and

Grease Lubrication Procedures, 24 July 1997, Jim O’Keefe, MR&S.

9. Maintenance Requirements Cards (MRCs) for Minesweeping Systems 4761.

a. MRC Control No. 47 8GGD N - Clean, inspect, and lubricate snatch blocks.

b. MRC Control No. 47 8GGE N - Clean, inspect, and lubricate swivels.

c. MRC Control No. 47 8GGF N - Clean, inspect, and lubricate shackles.

d. MRC Control No. 47 4MNR N - Inspect A Mk 4 (V) acoustic device diaphragm.

e. MRC Control No. 86 2WTT N - Clean cutter assembly.

f. MRC Control No. 86 2WTR N - Clean, inspect, and lubricate cutter.

g. MRC Control No. 86 2WTQ N - Clean and inspect cutter assembly.

10. STG1 Kelly, Fleet Liaison Office, Naval Surface Warfare Center (NSWC), Coastal

Systems Station, Panama City, Florida, Information on Oil and Grease Lubrication

Procedures, 12 August 1997, Jim O’Keefe, MR&S.

11. William Coffman, NSWC, Coastal Systems Station, Panama City, Florida, Information

on Mine Neutralization Vehicle, 12 August 1997, Jim O’Keefe, MR&S.

12. CDR Piper, OPNAV Mine Warfare Branch (N852), Information on Mine Neutralization

Vehicle, 6 August 1997, Jim O’Keefe, MR&S.

13. Military Specification MIL-G-18458B; “Grease Wire Rope, and Exposed”; March 1981,

Revision B, Amendment 5; and March 1996 Revision B.

14. STG1 Kelly, Fleet Liaison Office, NSWC, Coastal Systems Station, Panama City,

Florida, Information on Oil and Grease Lubrication Procedures, 13 August 1997, Jim

O’Keefe, MR&S.

15. Andy Tatem, NSWC, Coastal Systems Station, Panama City, Florida, Information on Oil

and Grease Lubrication Procedures, 23 July 1997, Jim O’Keefe, MR&S.

16. Patty’s Industrial Hygiene and Toxicology, Volume IIB, 3rd. ed., John Wiley & Sons,

1981, pp. 3369, 3397.

17. Quang Tran, NAVSEA Equipment Expert, Information on Mine Neutralization Vehicle,

20 August 1997, George Heiner, Malcolm Pirnie Inc.
Mine Countermeasures Equipment Lubrication

15

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.
Mine Countermeasures Equipment Lubrication

16

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Mine Countermeasures Equipment Lubrication

17

Figure 1. Mine Countermeasures Equipment on Deck
Mine Countermeasures Equipment Lubrication

18

Figure 2. Overview of “O”-Type Minesweeping Operations

 Cutters

Sweep Wire

Depressor Wire

1500 feet

Float

80 feet

 Profile View

 Plan View
Mine Countermeasures Equipment Lubrication

19

Table 1. Vessels Producing Mine Countermeasures Equipment Lubrication Discharge

Ship Class Mission Number of Vessels

MHC 51 (Osprey) Harbor and channel clearing; deep water coastal

minehunting

9

MCM 1 (Avenger) Non-conventional minesweeping and detonation 14

Table 2. Lubricant Type and Schedule for Wetted Mine Countermeasures Equipment

Component

Applicable

Ship Classes

Lubricant Mil

Standard

Lubrication Schedule

Cutters MCM 1 Class MIL-L-9000 After each use

Snatch blocks MIL-L-3150 Prior to and after each use

Swivels MIL-G-23549 Quarterly, and prior to and after each use

Shackles MIL-G-23549 Quarterly, and prior to and after each use

Towed acoustic device

(diaphragm)

DOD-G-24508 Quarterly, after each streaming, or as a

result of a sound measuring test

Multi-purpose crane lift wire

for handling the SLQ-48 MNV

MHC 51 Class MIL-G-18458B Annually, or as required

SLQ-48 MNV arms MHC 51 and

MCM 1 Class

DOD-G-24508 Prior to each use

*G = grease, L = lubrication oil
Mine Countermeasures Equipment Lubrication

20

Table 3a. Percentage of Constituents of Military Specification Oils and Greases

Component

MIL-G-18458B

wire rope

greasea

MIL-L-9000

engine oil

DOD-G-24508

ball and roller

bearing greaseb

DOD-G-24508

ball and roller

bearing greasec

MIL-G-23549

general purpose

grease

MIL-L-3150

general purpose

lube oil

Base Constituents

asphalt 25

hydrocarbons 45-50

mineral oil (unspecified) 80 25 30-60

polyalphaolefins 70-80

solvent refined, hydrotreated heavy

paraffinic distillate

55-70

solvent refined, hydrotreated residual

oil

20-30 51

Additives

1-naphthaleneamine, n-phenyl <2

4-hydroxy-3, 5-di-tertbutylphenylpropionic acid

thioclycolate

<1

benzenepropanoic acid, 3,5-bis(1,1-

dimethyl)-4-hydrooxyoctadecyl ester <2

calcium acetate <5 <3

calcium phenate <15

calcium sulfonate 4

clay 5-10 <10

Lithium Soaps >54

p,p-dioctyldiphenlamine <2

pentaerythritol 1

polymers (unspecified) <1

sodium chromate, tetrahydrate <1

sodium nitrate <2 1

sodium phosphate, tribasic <1

Source: Ingredients/Identity Information section of lubricant-specific material safety data sheets from DoD

Hazardous Materials Information System

 

a

 Amendment 5 to MIL-G-18458B, March 26, 1996, prohibits heavy metals (including lead) and salts of heavy

metals as constituents of MIL-G-18458B grease.

b As manufactured by Royal Lubricants Company Inc.

c

 As manufactured by Mobil Oil Company Inc.
Mine Countermeasures Equipment Lubrication

21

Table 3b. Maximum Concentrations from SLQ-48 Arms

TOTAL RELEASE PER EXERCISE: 4 oz.

GREASE RELEASED: DOD-G-24508 (100%)

ESTIMATED TOTAL MAXIMUM CONCENTRATION: 7.3 μg/L

Component

DOD-G-24508 ball and

roller bearing greasea

DOD-G-24508 ball and

roller bearing greaseb

Maximum

Concentration (μg/L)

Base Constituents

mineral oil (unspecified) 80 5.8

polyalphaolefins 70-80 5.8

Additives

1-naphthaleneamine, n-phenyl <2 0.15

benzenepropanoic acid, 3,5-bis(1,1-

dimethyl)-4-hydrooxyoctadecyl ester

<2 0.15

calcium acetate <5 <3 0.37

clay 5-10 <10 0.73

p,p-dioctyldiphenlamine <2 0.15

pentaerythritol 1 0.07

sodium chromate, tetrahydrate <1 0.07

sodium nitrate <2 1 0.15

sodium phosphate, tribasic <1 0.07

Table 3c. Maximum Concentrations from O-Gear and Cutters

TOTAL RELEASE PER EXERCISE: 26 oz.

GREASE RELEASED: MIL-G-23549 (53.8%); MIL-L-3150 (7.7%); MIL-L-9000 (30.8%)

ESTIMATED TOTAL MAXIMUM CONCENTRATION: 2.97 μg/L

Component

MIL-L-9000

engine oil

MIL-G-23549

general purpose

grease

MIL-L-3150

general purpose

lube oil

Maximum

Concentration

(μg/L)

Base Constituents

hydrocarbons 45-50 0.11

mineral oil (unspecified) 25 30-60 0.14

solvent refined, hydrotreated heavy

paraffinic distillate

55-70 0.64

solvent refined, hydrotreated residual oil 20-30 51 1.09

Additives

4-hydroxy-3, 5-di-tertbutylphenylpropionic acid thioclycolate<1 0.02

calcium phenate <15 0.14

calcium sulfonate 4 0.06

 

a

 As manufactured by Royal Lubricants Company Inc.

b As manufactured by Mobil Oil Company Inc.
Mine Countermeasures Equipment Lubrication

22

Table 3d. Maximum Concentrations from Acoustic and Magnetic Devices

TOTAL RELEASE PER EXERCISE: 6 oz.

GREASE RELEASED: DOD-G-24508 (67%), MIL-G-23549 (33%)

ESTIMATED TOTAL MAXIMUM CONCENTRATION: 0.688 μg/L

Component

DOD-G-24508

ball and roller

bearing greasea

DOD-G-24508

ball and roller

bearing greaseb

MIL-G-23549

general purpose

grease

Maximum

Concentration

(μg/L)

Base Constituents

mineral oil (unspecified) 80 25 0.425

Polyalphaolefins 70-80 0.369

solvent refined, hydrotreated residual oil 51 0.116

Additives

1-naphthaleneamine, n-phenyl <2 0.009

4-hydroxy-3, 5-di-tertbutylphenylpropionic acid thioclycolate<1 0.002

benzenepropanoic acid, 3,5-bis(1,1-

dimethyl)-4-hydrooxyoctadecyl ester

<2 0.009

calcium acetate <5 <3 0.037

calcium sulfonate 4 0.009

clay 5-10 <10 0.092

p,p-dioctyldiphenlamine <2 0.009

pentaerythritol 1 0.005

sodium chromate, tetrahydrate <1 0.005

sodium nitrate <2 1 0.014

sodium phosphate, tribasic <1 0.005

 

a

 As manufactured by Royal Lubricants Company Inc.

b As manufactured by Mobil Oil Company Inc.
Mine Countermeasures Equipment Lubrication

23

Table 4. Estimated Annual Lubricant Mass Loading

Source

Quantity per

Exercise (oz)

Yearly Number

of Exercises

Number of

Vessels

Total Release

(oz/yr)

Total Release

(lbs/yr)

MHC 51 Class

SLQ-48 MNV arms 4 240 9 8,640 540

SLQ-48 MNV Lift

Cable

0.15 240 9 324 20

MCM 1 Class

SLQ-48 MNV arms 4 12 14 672 42

O-gear, cutters 26 6 14 2,184 137

Acoustic and Magnetic 5 6 14 420 26

Total Mass Loading 12,240 765

Table 5. Water Quality Criteria and Discharge Standards

Source and

Constituent

Environmental

Concentration

(μg/L)

Federal Discharge

Standards (μg/L)

Most Stringent State Acute

Water Quality Criteriaa

(μg/L)

SLQ-48 arms

oil and grease 7.3b Visible sheen* /15,000** 5,000 (FL)

SLQ-48 MNV Lift Cable

oil and grease 30 ft3 c Visible sheen* /15,000** 5,000 (FL)

O-gear, cutters

oil and grease 2.97 Visible sheen* /15,000** 5,000 (FL)

Acoustic and Magnetic

oil and grease 0.688 Visible sheen* /15,000** 5,000 (FL)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

* Discharge of Oil. 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen

on receiving waters.

** International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as

implemented by the Act to Prevent Pollution from Ships (APPS).

 

a

 FL = Florida

b Estimated

c Volume required to disperse to most stringent water quality standard
Mine Countermeasures Equipment Lubrication

24

Table 6. Data Sources

Data Source

NOD report Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents PMS Cards X

3.4 Concentrations MSDS

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Motor Gasoline (MOGAS) Compensating Discharge

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Motor Gasoline (MOGAS) Compensating Discharge
Motor Gasoline (MOGAS) Compensating Discharge

2

2.0 DISCHARGE DESCRIPTION

This section describes the MOGAS discharge and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3). This

discharge may be referred to as “Motor Gasoline (MOGAS) and Compensating Overboard

2.1 Equipment Description and Operation

MOGAS is commercial gasoline identical to that supplied to gas stations for automobile

use. It is carried aboard certain Navy, U.S. Coast Guard (USCG), Military Sealift Command

(MSC), and Army vessels as fuel for vehicles, special warfare operational craft, portable bomb

hoists, crash saws, and any other gasoline-operated, ship-support equipment.

The USCG, MSC, Air Force, and Army have no vessels with fixed MOGAS storage.

Most vehicles and equipment are brought aboard fully loaded with fuel, and additional MOGAS

is carried in portable drums or containers. On some Navy vessels, additional MOGAS is stored

for replenishment purposes in permanently installed seawater-compensated tanks as shown in

Figure 1. Compensating seawater is supplied at a pressure sufficient to force gasoline to the

suction side of the gasoline pumps, and keep the tank full to prevent potentially explosive

gasoline vapors from forming. Several methods are used to supply seawater to the tanks.

Aboard amphibious transport dock (LPD 4 Class) ships, two dedicated seawater pumps take

suction directly from the sea chest. On amphibious assault (LHA 1 Class) ships, seawater can be

supplied one of two ways: 1) a compensating tank with a capacity of 8,000 to 10,000 gallons of

seawater is installed such that water drains by gravity to the fuel tank as necessary; or 2) booster

pumps located in the pump room supply seawater to the fuel tanks.

Immediately before a major overhaul, and in accordance with existing management

practices, ships with permanently installed seawater-compensated MOGAS tanks will unload any

remaining fuel to tanker trucks on the pier and transit out to beyond 50 nautical miles (n.m.).

Using seawater pumps, the MOGAS tanks and system piping are flushed with three tank volumes

of seawater. Air pressure is used to force the seawater out of the tank, after which steam is used

to clean the tank and “cook-off” any remaining fuel remnants. The MOGAS tanks are then filled

with seawater and the ship returns to port for the overhaul.

After overhaul and before re-deployment (approximately once a year) the vessel receives

MOGAS from pierside tanker trucks. MOGAS that is on-loaded displaces the compensating

seawater in the tank, pushing it overboard. Several management practices are in place to ensure

that MOGAS is not discharged overboard during refueling operations. Without these

management practices, there is a potential to cause an oil sheen in the surrounding waters. First,

the MOGAS tanks are filled to no more than 80% of capacity.1 The amount of fuel needed is

calculated before loading, and the tanker truck is only filled with a volume of MOGAS such that

completely filling a MOGAS tank with the entire contents of the truck would not cause the tank

to overflow. Additionally, watch personnel are stationed at strategic locations on and around the
Motor Gasoline (MOGAS) Compensating Discharge

3

ship and pier to observe refueling operations and report any abnormalities. Containment devices

are placed around all refueling hose connections to contain any fuel spills or leaks, and

containment booms are placed in the water around the ship being refueled.

An additional management practice controls the rate at which MOGAS is supplied from

the tanker trucks. Small-diameter hoses (usually two inches) are used to deliver fuel at a flow

rate of 50 gallons per minute (gpm) or less, that, in conjunction with diffusers built into the tank

filling system piping, reduces turbulence and minimizes mixing of gasoline and seawater.

2.2 Releases to the Environment

The discharge consists of seawater used to replace, or compensate for, the space created

in MOGAS tanks as the fuel is consumed. This seawater is discharged overboard as the

MOGAS tank is refilled with gasoline. It is possible that this compensating seawater discharge

overboard could contain traces of dissolved gasoline constituents.

2.3 Vessels Producing the Discharge

The USCG, MSC, Air Force, and Army have no vessels with fixed MOGAS storage, and

therefore do not contribute to this discharge.2,3,4 Eight LPD 4 Class, and five LHA 1 Class ships

currently have installed MOGAS storage tanks that discharge compensating water during

refueling. One LPD and one LHA Class ship are homeported overseas.

The most significant difference between LPD 4 and LHA 1 Class ships is MOGAS

capacity. LPDs have a capacity to carry 26,000 gallons of MOGAS. LHAs have a capacity to

carry 11,400 gallons of MOGAS.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Refueling always takes place pierside, and compensating seawater is discharged directly

overboard as oncoming fuel displaces the seawater.

3.2 Rate

Tanker trucks with small diameter hoses (usually two inches) are used to deliver MOGAS

to ships. The fill rate from these trucks is normally limited to 50 gpm or less. With the MOGAS

tanks always full of seawater and fuel, compensating water is displaced directly overboard at the
Motor Gasoline (MOGAS) Compensating Discharge

4

same rate as the incoming fuel.

The estimated amounts of compensating seawater discharged annually from ships with

MOGAS storage tanks are presented in Table 1. The values in Table 1 are based on the

operational experience of one refueling per ship per year, with a maximum of 80% of the tank

capacity being displaced overboard by onloaded fuel.1

3.3 Constituents

MOGAS is a hydrocarbon based unleaded fuel containing over 150 individual

compounds. The types of compounds found in gasoline include alkanes, alkenes, aromatics,

metals, and additives. Most of these compounds are a very small fraction (less than 2%) of

gasoline. The compounds that individually comprise at least 2% of gasoline include butane,

pentane, hexane, isopentane, methylpentane, dimethylpentane, trimethylpentane,

trimethylhexane, benzene, toluene, xylene, methyl-3-ethylbenzene, trimethylbenzene, and

ethylbenzene. The exact composition of gasoline is unknown because gasoline manufacturers

constantly adjust their product to meet performance, emissions, and cost demands.5 Due to the

variable composition and the different water solubilities of the individual components of

gasoline, it is difficult to determine the solubility of MOGAS.

To identify the constituents in this discharge, two studies that determined the water

soluble components of gasoline, as well as their solubilities, were used. The first study was

conducted by the Naval Biosciences Laboratory in 1983, and the second was conducted in 1992

for a workshop on petroleum hydrocarbons.5,6 Both studies measured the water soluble

constituents of gasoline by placing gasoline on top of water, agitating the water, allowing

equilibrium to be established, and analyzing the water through gas chromatography. In these

analyses, a water fuel interface was established very similar to the interface within MOGAS

tanks. In both cases, the water was removed from the bottom of the container to be analyzed,

ensuring that emulsified fuel was not being measured. Since gasoline composition has changed

over the years, the study performed in 1992 is considered to be more representative of current

MOGAS constituents. The constituents identified in this study that are soluble in water are listed

in Table 2.5 Benzene, toluene, ethylbenzene, phenol, and naphthalene are priority pollutants.

None of these compounds are bioaccumulators.

3.4 Concentrations

The concentrations of the water soluble gasoline constituents in the MOGAS

compensating discharge are estimated from the studies performed to determine the solubility of

gasoline components in water. The 1983 study reported a range of constituent concentrations

based on the source of the gasoline. Benzene concentrations ranged from 19.1 to 42.5 milligrams

per liter (mg/L), toluene from 17.3 to 61.4 mg/L, and xylenes from 9.5 to 27.7 mg/L.6 The 1992

study provided a more detailed account of the concentrations, which all fell within the ranges

reported in the 1983 study.5 The estimated concentrations of MOGAS components present in the

compensating overboard discharge are shown in Table 2.
Motor Gasoline (MOGAS) Compensating Discharge

5

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

are compared with the water quality criteria. In Section 4.3, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

Using the fleet wide MOGAS compensating water annual discharge volumes presented in

Table 1, and the estimated constituent concentrations in Table 2, the total mass loadings for the

priority pollutants present in this discharge were calculated using the following formula:

Mass Loading (lbs/yr) =

(Concentration (mg/L))(Volume (gal/yr))(3.785 L/gal)(2.2 lbs/kg)(10-6 kg/mg)

Table 3 provides the resulting mass loadings on a maximum discharge per event basis and

on a total annual fleetwide basis.

4.2 Environmental Concentrations

As identified in Section 3.3, the constituents of concern are benzene, toluene,

ethylbenzene, xylene isomers, phenol, and naphthalene. The estimated constituent

concentrations in MOGAS compensating water discharges, and the corresponding most stringent

state water quality criteria (WQC), are presented in Table 4. Benzene, toluene, ethylbenzene,

phenol, and naphthalene concentrations exceed the most stringent state WQC. There are no

relevant Federal or state WQC for xylene isomers.

4.3 Potential for Introducing Non-Indigenous Species

In those instances where vessels receive MOGAS prior to deployment and no overhaul

period is pending, the possibility of non-indigenous species transport exists. Water from

different ports could have entered the tanks during the previous deployment to compensate for

consumed fuel. When shipboard MOGAS tanks are emptied of fuel, flushed, steam-cleaned, and

then filled with seawater while in deep water before returning to port for overhaul, there is no

significant possibility of non-indigenous species transport. Therefore, depending on the

operational procedures and the deployment of the vessels, there may be a potential for the

transfer of non-indigenous species.

5.0 CONCLUSIONS

MOGAS compensating discharge has the potential to cause an adverse environmental
Motor Gasoline (MOGAS) Compensating Discharge

6

effect because there is a potential to cause an oil sheen in the waters surrounding the ship.

Additionally, the possibility exists for the transfer of non-indigenous species, depending on the

operational procedures of a particular vessel and the deployment schedule.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information was used to estimate the volume of discharge. Table 5 shows the source of the data

used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes. Motor Gasoline (MOGAS) Storage and

Compensated Overboard Discharge. October 23, 1996.

2. Personal Communication Between LT Joyce Aivalotis (U.S. Coast Guard) and David

Ciscon (M. Rosenblatt & Son). May 28, 1997.

3. Personal Communication Between Penny Weersing (Military Sealift Command Central

Technical Activity) and Don Kim (M. Rosenblatt & Son). October 24, 1996.

4. US Army Input to Equipment Expert Meeting, Motor Gasoline (MOGAS) Storage and

Compensated Overboard Discharge. February 7, 1997.

5. Bruya, James E., Petroleum Hydrocarbons: What are they? How much is present? Where

do they go? Friedman & Bruya, Inc., Seattle, WA. April 1992.

6. Guard, Harold E. and Roy B. Laughlin, Jr., Characterization of Gasolines, Diesel Fuels &

Their Water Soluble Fractions. Naval Biosciences Laboratory, Oakland, CA., September

1983.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Motor Gasoline (MOGAS) Compensating Discharge

7

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Motor Gasoline (MOGAS) Compensating Discharge

8

FIGURE 1

SEAWATER COMPENSATED 

MOGAS

STOWAGE TANK

GASOLINE LINE

SEA

CHEST

COFFERDAM

GASOLINE

SEAWATER LINES

SEAWATER

OUTER TANK

GASOLINE

DRAIN OFF

TANK
Motor Gasoline (MOGAS) Compensating Discharge

9

Table 1. Estimated Total Amounts of MOGAS Compensating Seawater Displaced

Overboard Annually by Vessel Class in U.S. Ports

Vessel

Class

No. of

Vessels in

U.S.

MOGAS Tank

Capacity Per

Vessel (gal)

Total Tank

Capacity (gal)

Volume of Compensating

Seawater Discharged

Overboard Per Yeara

LPD 7 26,000 182,000 145,600

LHA 4 11,400 45,600 36,480

Estimated Total: 182,080

a Based on one complete in-port refueling per year per vessel, and a maximum of 80% of the tank capacity being

displaced overboard by onloaded fuel

Table 2. Estimated Constituent Concentrations in MOGAS Compensating

Overboard Discharge5

Compound Concentration (mg/L)

Methyl-t-butyl ether (MTBE) 116

Benzene 29.5

Toluene 42.6

Xylene Isomers (3) 14.7

Ethylbenzene 2.4

C5 and C6 Alkenes and Alkadienes 0.5

C1 to C4 Phenols 1.2

C3 to C5 Benzenes 6.8

C0 to C3 Anilines 3.7

C0 to C2 Thiophenes 1.3

C0 to C2 Indanes and Indenes 1.2

C0 to C2 Naphthalenes 1.2

C0 to C2 Pyridines 0.4

C0 to C2 Indoles 0.3
Motor Gasoline (MOGAS) Compensating Discharge

10

Table 3. Estimated Annual Mass Loadings

Constituent Estimated

Concentration In

Discharge (mg/L)

Maximum Discharge

Event Mass Loading*

(lbs)

Total Fleetwide

Mass Loading** (lbs)

Benzene 29.5 5.1 45

Toluene 42.6 7.4 65

Xylene Isomers (3) 14.7 2.5 22

Ethylbenzene 2.4 0.4 4

Phenols 1.2 0.2 2

Naphthalenes 1.2 0.2 2

* Based upon a maximum discharge event volume of 20,800 gallons from an LPD 7 (assuming a maximum of 80%

of the 26,000 gallon tank capacity being displaced overboard by onloaded fuel)

** Based upon a total annual discharge volume of 182,080 gallons

Table 4. Comparison of Estimated Discharge Concentrations with Water Quality Criteria

Constituent Concentration

(mg/L)

Federal Acute

WQC (mg/L)

Most Stringent State Acute

WQC (mg/L)

Benzene 29.5 None 0.07128 (FL)

Toluene 42.6 None 2.1 (HI)

Ethylbenzene 2.4 None 0.14 (HI)

Phenols 1.2 None 0.17 (HI)

Naphthalenes 1.2 None 0.78 (HI)

Notes:

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

FL = Florida

HI = Hawaii
Motor Gasoline (MOGAS) Compensating Discharge

11

Table 5. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X X

3.2 Rate X X

3.3 Constituents X X X

3.4 Concentrations X X X

4.1 Mass Loadings X X

4.2 Environmental Concentrations X X

4.3 Potential for Introducing NonIndigenous SpeciesX
Non-oily Machinery Wastewater

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Non-oily Machinery Wastewater
Non-oily Machinery Wastewater

2

2.0 DISCHARGE DESCRIPTION

This section describes the non-oily machinery wastewater and includes information on:

the equipment that is used and its operation (Section 2.1), general description of the constituents

of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

The primary purpose of the non-oily machinery wastewater system is to segregate

machinery wastewater from the wastes that collect in bilges so that non-oily machinery

wastewater can be directly discharged overboard. This reduces the amount of bilgewater that

needs to be treated with oil water separators (OWS) prior to discharge. Dedicated drip pans,

funnels, and deck drains comprise the non-oily machinery wastewater system and collect nonoily machinery wastewater that is generated below the ship’s waterline in machinery spaces.

Non-oily machinery wastewater from systems and equipment located above a ship’s waterline is

often drained directly overboard. By separately collecting and preventing non-oily machinery

wastewater from mixing with oily wastewater, non-oily wastewater is discharged without going

through an OWS system.

For the systems below the waterline, non-oily machinery wastewater drains into the nonoily machinery wastewater drain tanks (generally one per machinery space) which have dedicated

pumps that discharge directly overboard. These pumps normally operate automatically under

control of high- and low-level sensors. Non-oily machinery wastewater tanks range in size from

100 gallons for smaller ships to 2,500 gallons for aircraft carriers. Figure 1 is a diagram of a

typical non-oily machinery wastewater system.

The main sources of water to the non-oily machinery wastewater are:

• distilling plants start-up

discharge,

• bleed air system leaks,

• chilled water condensate drains,

• fresh and saltwater pump

drains,

• potable water tank overflows,

• leaks from propulsion shaft

seals,

• low & high pressure air compressor

condensate,

• leaks from valve stems and manifolds,

• seawater and freshwater relief valve

leaks,

• leaks from pump packing gland seals,

• seawater duplex strainer leaks,

• propulsion engine jacket water cooler

drains.
Non-oily Machinery Wastewater

3

In limited cases, steam condensate is combined with non-oily machinery wastewater in the nonoily machinery wastewater drain tank. The combined wastewater are discharged overboard

below the waterline. Information on steam condensate is provided in the steam condensate NOD

report.

Of these listed non-oily machinery wastewater sources, distilling plants may be the major

source of non-oily machinery wastewater. Distilling plants desalinate seawater to produce

potable, boiler feed, and equipment cooling water. The freshwater initially produced by the

distilling plants during start-up is normally discharged either overboard or to the non-oily

machinery wastewater system until acceptable specified salinity levels are achieved. This period

normally lasts about 15 minutes, at which time the discharge is discontinued. Also, the quality of

the water produced during the normal operation of the distiller plants may occasionally be

unsatisfactory; this water is discharged in the same manner as during start-up.

2.2 Releases to the Environment

The constituents of this discharge include potable water and seawater, metals from

contact with tanks and piping, and other constituents associated with the construction and

operation of the non-oily machinery wastewater system and equipment served by the system.

The discharge either drains directly overboard continuously as it is produced, or is pumped

overboard intermittently from non-oily machinery wastewater tanks.

2.3 Vessels Producing the Discharge

Non-conventionally powered Navy surface vessels and all newly constructed and some

older conventionally-powered vessels have dedicated non-oily machinery wastewater systems.

Most Military Sealift Command vessels and some of the older conventionally powered Navy

ships do not have a separate non-oily machinery wastewater system, so the non-oily wastewater

drains to the bilge.1 U.S. Coast Guard vessels and small boats and craft of the Armed Forces do

not have any dedicated non-oily machinery wastewater collection systems; instead, the non-oily

machinery wastewater, which is mixed with bilgewater, is generally collected for shore side

treatment as bilgewater. In addition, Army and Air Force vessels do not have separate non-oily

machinery wastewater systems; this type of wastewater is drained directly to the bilge.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

This discharge occurs in port, during transit, and at sea.
Non-oily Machinery Wastewater

4

3.2 Rate

The generation rate and discharge frequency of non-oily machinery wastewater varies

considerably according to the mode of ship operation and its equipment operating status. This

was demonstrated by the results of the recent flow characterization study of non-oily machinery

wastewater onboard the following vessels: CVN 74, DDG 67, LHD 5, and LSD 44.2 A

cumulative discharge flow rate of 97,057,740 gallons/year was estimated for the vessel classes

that these vessels represent. Non-oily machinery wastewater flow rates by vessel class were

established by using the following formula:

Vessel Class Flow Rate = (# vessels/ship class)(flow rate)(# of days in port/ year)

CVN 68 Class = (7 vessels)(41,200 gal/day)(147 days in port/year) = 42,394,800 gal/year

Machine-specific non-oily machinery wastewater sources can generate volumes ranging

from a few drips per minute in the case of small pumps and valves, to several thousand gallons

per hour (gph) in the case of distilling units releasing their output during plant start-up. The

volume of distillate directed to the non-oily machinery wastewater system during start-up ranges

from less than 100 gph to about 4,000 gph depending on the size of the plant.

3.3 Constituents

Non-oily machinery wastewater discharge samples were obtained from four Navy ships.

Samples were collected aboard an aircraft carrier (CVN 74), an amphibious assault ship (LHD 1),

a dock landing ship (LSD 51) and a guided missile destroyer (DDG 57).3 See Table 1 for the

concentrations of constituents detected in shipboard non-oily machinery wastewater discharge

samples. Table 2 lists a bioaccumulator and constituents that were detected in the non-oily

machinery wastewater samples at concentrations that exceed Federal and/or state ambient water

quality criteria (WQC). The priority pollutants bis(2-ethylhexyl) phthalate, copper, nickel, silver,

and zinc were identified as being present in concentrations exceeding WQC. The only

bioaccumulator identified in the discharge was mercury.

3.4 Concentrations

Concentrations of constituents detected in non-oily machinery wastewater samples

collected from an aircraft carrier (CVN 74), an amphibious assault ship (LHD 1), a dock landing

ship (LSD 51) and a guided missile destroyer (DDG 57) are presented in Table 1.

Concentrations of a known bioaccumulator and the constituents that exceeded Federal and/or

most stringent state WQC are presented in Table 2.
Non-oily Machinery Wastewater

5

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The mass loadings and

the concentrations of discharge constituents after release to the environment are discussed in

Sections 4.1 and 4.2, respectively. In Section 4.3, the potential for the transfer of non-indigenous

species is discussed.

4.1 Mass Loadings

Non-oily machinery wastewater discharge volumes (recorded by pump running time

meters/event counters) were recorded daily aboard four ships from different ship classes over

periods of time ranging from 22 to 29 consecutive days.2 These were the same four ship classes

that were sampled. The discharge flow data and log-normal mean concentrations were used to

estimate mass loadings for those analytes detected. Mass loadings of all constituents detected are

presented in Table 1. Table 2 shows mass loadings for constituents with log-normal mean

concentrations that exceed water quality criteria and for the loan bioaccumulator detected,

mercury. A sample calculation of the estimated mass loading for copper is shown below:

Mass Loading for Copper (Total):

Mass Loading = (Log-normal mean concentration)(Flow Rate)

= (599.96 mg/L)(97,057,740 gal/yr)(3.785 L/gal)(1kg/109mg)(2.2 lb/1 kg)

= 485 lbs/yr

Mass loadings were determined using log-normal averages because the concentration data

are expected to follow a log-normal distribution.

4.2 Environmental Concentrations

The log-normal mean discharge concentrations are compared to the Federal and most

stringent state WQC in Table 3. Copper, nickel, silver, zinc, bis(2-ethylhexyl) phthalate,

ammonia, nitrogen (as nitrate/nitrite and total kjeldahl nitrogen), and total phosphorous were

present in shipboard non-oily machinery wastewater discharge samples, with log-normal mean

concentration levels in excess of the most stringent established water quality criteria. Mercury

was detected in two of four shipboard samples, but the log-normal mean concentration did not

exceed WQC.

4.3 Potential for Introducing Non-Indigenous Species

The discharge from freshwater non-oily machinery wastewater originates from the

potable water system and therefore, cannot introduce, transport, or release non-indigenous

species. Non-oily machinery wastewater of seawater origin is pumped overboard in the same

geographical area in which the seawater was taken. Therefore, transporting aquatic species from

one geographic area to another as a result of this discharge is unlikely.
Non-oily Machinery Wastewater

6

5.0 CONCLUSION

It is not clear whether non-oily machinery wastewater has the potential to cause an

adverse environmental effect. Copper, nickel, silver, zinc, bis(2-ethylhexyl) phthalate, ammonia,

nitrogen, and phosphorous exceed federal or most stringent state water quality criteria. However,

flow rate data are not adequate for estimating the fleetwide generation rate for this discharge, and

consequently, the mass loadings of these constituents for the fleet could not be calculated.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information and assumptions were used to estimate the discharge volume. Based on this estimate

and on the reported concentrations of constituents, the mass loadings to the environment

resulting from this discharge were then estimated. Table 4 shows the source of the data used to

develop this NOD report.

Specific References

1. Point Paper, “Supplemental Information for Miscellaneous UNDS Discharge Streams”, P.

Weersing, Military Sealift Command Central Technical Activity, Code N72PC1, January

9, 1997.

2. Uniform National Discharge Standards Non-Oily Machinery Wastewater (NOMWW)

Flow Characterization Report, CDNSWC-TM-63-98/62, March 1998.

3. UNDS Phase 1 Sampling Data Report, Volumes 1 - 13, October 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.
Non-oily Machinery Wastewater

7

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

UNDS Equipment Expert Meeting Minutes - Non-oily Machinery Wastewater. 12 September

1996.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.

UNDS Ship Database, August 1, 1997.

Pentagon Ship Movement Data for Years 1991-1995, Dated March 4, 1997.
Non-oily Machinery Wastewater

8

FIGURE 1

TYPICAL NON-OILY MACHINERY

WASTEWATER SYSTEM

NON-OILY MACHINERY

WASTEWATER TANK

FUNNELS

PUMP

FUNNELS

OVERFLOWS

A / C

POTABLE

WATER

TANK

DRIP PANS

SHIP'S

HULL

SHIP'S

HULL

CONDENSER DRAINS

RELIEF

VALVES

VALVE

STEMS

PUMP PACKING

GLANDS

OVERBOARD HIGH/ON

LOW/OFF

DISTILLER

PLANT
Non-oily Machinery Wastewater

9

Table 1. Summary of Detected Analytes

Constituent Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Mass Loading

CLASSICALS (mg/L) (mg/L) (mg/L) (lbs/yr)

Alkalinity 13.96 4 of 4 6 62 11284

Ammonia as Nitrogen 0.34 4 of 4 0.1 1 275

Biochemical Oxygen Demand 4.76 1 of 3 BDL 12 3696

Chemical Oxygen Demand 63.89 3 of 4 BDL 285 49608

Chloride 94.29 4 of 4 2 3050 73213

Hexane Extractable Material 5.02 1 of 4 BDL 40.5 3898

Nitrate/Nitrite 0.38 4 of 4 0.19 0.56 295

SGT-HEM 5.91 1 of 3 BDL 33 4589

Sulfate 139.13 4 of 4 9.8 1710 112457

Total Dissolved Solids 431.32 4 of 4 46 6300 348630

Total Kjeldahl Nitrogen 1.05 4 of 4 0.55 2.3 8.49

Total Organic Carbon (TOC) 4.27 3 of 4 BDL 21 3451

Total Phosphorous 1.03 4 of 4 .14 11 833

Total Recoverable Oil and

Grease

4.73 4 of 4 .6 19.75 3823

Total Sulfide (Iodometric) 6.45 4 of 4 2 16 5213

Total Suspended Solids 11.34 3 of 4 BDL 46 9166

Volatile Residue 287.25 4 of 4 54 6350 232180

MERCURY (ng/L) (ng/L) (ng/L) (lbs/yr)

Mercury 4.48 2 of 4 BDL 2135 0.0036

METALS (μg/L) (μg/L) (μg/L) (lbs/yr)

Aluminum

 Dissolved 30.83 1 of 4 BDL 68 24.92

 Total 53.47 1 of 4 BDL 372.5 43.22

Antimony

 Dissolved 2.81 1 of 4 BDL 7.55 2.27

 Total 2.57 1 of 4 BDL 5.5 2.08

Arsenic

 Dissolved 0.94 1 of 4 BDL 1.8 0.760

 Total 0.57 1 of 4 BDL 1.2 0.461

Barium

 Dissolved 5.17 3 of 4 BDL 21.8 4.18

 Total 7.03 3 of 4 BDL 34.95 5.68

Boron

 Dissolved 80.88 3 of 4 BDL 754 65.4

 Total 89.19 3 of 4 BDL 833 72.1

Cadmium

 Dissolved 2.78 1 of 4 BDL 5.2 2.25

 Total 2.80 1 of 4 BDL 5.4 2.26

Calcium

 Dissolved 3587.66 4 of 4 131.5 74650 2900

 Total 4117.59 4 of 4 173 97950 3328

Copper

 Dissolved 148.76 4 of 4 34.35 1065 120

 Total 599.96 4 of 4 34.2 3045 485
Non-oily Machinery Wastewater

10

Iron

 Dissolved 20.90 2 of 4 BDL 89.15 16.9

 Total 110.28 3 of 4 BDL 2505 89.1

Lead

 Dissolved 4.59 1 of 4 BDL 19.3 3.71

 Total 5.10 1 of 4 BDL 29.35 4.12

Magnesium

 Dissolved 7775.80 4 of 4 316 196500 6285

 Total 9258.79 4 of 4 455 251500 7484

Manganese

 Dissolved 7.40 3 of 4 BDL 26.15 6.0

 Total 9.91 3 of 4 BDL 69.05 8.0

Molybdenum

 Dissolved 2.47 1 of 4 BDL 17.2 2.0

 Total 2.79 1 of 4 BDL 31 2.26

Nickel

 Dissolved 76.10 3 of 4 BDL 237 61.5

 Total 92.63 3 of 4 BDL 404 74.9

Silver

 Total 5.41 1 of 4 BDL 54.85 4.37

Sodium

 Dissolved 69616.18 4 of 4 3365 1750000 56270

 Total 62604.54 4 of 4 1948.75 1955000 50602

Thallium

 Dissolved 4.72 3 of 4 BDL 15.7 3.82

 Total 1.43 1 of 4 BDL 1.6 1.16

Tin

 Total 4.14 1 of 4 BDL 36.7 3.35

Titanium

 Total 4.05 2 of 4 BDL 9.75 3.27

Zinc

 Dissolved 140.24 4 of 4 23 847 113

 Total 621.47 4 of 4 90.85 6125 502

ORGANICS (μg/L) (μg/L) (μg/L) (lbs/yr)

2-Propanone 36.00 1 of 4 BDL 107.5 29.1

Bis(2-Ethylhexyl) Phthalate 10.78 1 of 4 BDL 75 8.71

Chloroform 6.93 1 of 4 BDL 18.5 5.6

N,N-Dimethylformamide 6.67 1 of 4 BDL 11 5.39

N-Hexacosane 6.06 1 of 4 BDL 10 4.9

Toluene 10.91 1 of 4 BDL 113.5 8.82

Notes:

(1) BDL = Below Detection Limit

(2) Mass loadings were calculated based upon the results of the UNDS Non-Oily Machinery Wastewater Flow

Characterization Report involving four vessels: CVN 74, DDG 67, LHD 5, and LSD 44.2

(3) Log normal means were calculated using measured analyte concentrations. When a sample set contained one or

more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations

equivalent to one-half of the detection levels were used to calculate the mean. For example, if a "non-detect" sample

was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log normal mean

calculation.
Non-oily Machinery Wastewater

11

Table 2. Estimated Annual Mass Loadings of Constituents

Constituent Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Mass Loading

CLASSICALS (mg/L) (mg/L) (mg/L) (lbs/yr)

Ammonia as Nitrogen 0.34 4 of 4 0.1 1 275

Nitrate/Nitrite 0.38 4 of 4 0.19 0.56 295

Total Kjeldahl

Nitrogen

1.05 4 of 4 0.55 2.3 8.49

Total NitrogenA1.43 - 303

Total Phosphorous 1.03 4 of 4 0.14 11 833

ORGANICS (μg/L) (μg/L) (μg/L) (lbs/yr)

Bis(2-Ethylhexyl)

Phthalate

10.78 1 of 4 BDL 75 8.71

MERCURY (ng/L) (ng/L) (ng/L) (lbs/yr)

Mercury* 4.48 2 of 4 BDL 2135 .0036

METALS (μg/L) (μg/L) (μg/L) (lbs/yr)

Copper

 Dissolved 148.76 4 of 4 34.35 1065 120

 Total 599.96 4 of 4 34.2 3045 485

Nickel

 Dissolved 76.10 3 of 4 BDL 237 61.5

 Total 92.63 3 of 4 BDL 404 74.9

Silver

 Total 5.41 1 of 4 BDL 54.85 4.37

Zinc

 Dissolved 140.24 4 of 4 23 847 113

 Total 621.47 4 of 4 90.85 6125 502

BDL = Below Detection Limit

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

* Mercury was not found in excess of WQC; mass loading is shown only because it is a bioaccumulator.

Mass loadings were calculated based upon the results of the UNDS Non-Oily Machinery Wastewater Flow

Characterization Report involving four vessels: CVN 74, DDG 67, LHD 5, and LSD 44.2
Non-oily Machinery Wastewater

12

Table 3. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Constituent Log-normal

Mean

Minimum

Concentration

Maximum

Concentration

Federal Acute

WQC

Most Stringent State

Acute WQC

CLASSICALS

(mg/L)

Ammonia as Nitrogen 0.34 0.1 1 None 0.006 (HI)A

Nitrate/Nitrite 0.38 0.19 0.56 None 0.008 (HI)A

Total Kjeldahl

Nitrogen

1.05 0.55 2.3 None -

Total NitrogenB1.43 None 0.2 (HI)A

Total Phosphorous 1.03 0.14 11 None 0.025 (HI)A

ORGANICS (μg/L)

Bis(2-Ethylhexyl)

Phthalate

10.78 BDL 75 None 5.92 (GA)

Mercury (ng/L)

Mercury* 4.48 BDL 2135 1800 25 (FL, GA)

Metals (μg/L)

Copper

 Dissolved 148.76 34.35 1065 2.4 2.4 (CT, MS)

 Total 599.96 34.2 3045 2.9 2.5 (WA)

Nickel

 Dissolved 76.10 BDL 237 74 74 (CA, CT)

 Total 92.63 BDL 404 74.6 8.3 (FL, GA)

Silver

 Total 5.41 BDL 54.85 1.9 1.2 (WA)

Zinc

 Dissolved 140.24 23 847 90 90 (CA, CT, MS)

 Total 621.47 90.85 6125 95.1 84.6 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

* - Mercury was not found in excess of WQC; concentration is shown only because it is a bioaccumulator.

CA = California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Non-oily Machinery Wastewater

13

Table 4. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Photo Lab Drains

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Photo Lab Drains
Photo Lab Drains

2

2.0 DISCHARGE DESCRIPTION

This section describes the photographic laboratory drains and includes information on:

the equipment that is used and its operation (Section 2.1), general description of the constituents

of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Shipboard photographic laboratory wastes result from the processing of color, black-andwhite, and X-ray film. The chemicals used aboard vessels for these purposes are the same as

those used at shore-based photographic facilities. This discharge is controlled by the Armed

Forces by current guidance which requires containerization of all photo processing wastes for

shore disposal when within 12 nautical miles (n.m.) of shore.1

The photographic wastewater processing system consists of three elements: a film

processor, a washwater recycle system, and a fixer recycle and silver recovery subsystem. The

film processor effluents include the developer and fixer solutions and the thiosulfate washwater

stream. After the film is fixed, it goes through the washwater recycle system, where it is

immersed in thiosulfate washwater and then sprayed with freshwater (rinsewater).2 Black-andwhite and X-ray film effluents are then containerized for shore disposal or directly discharged

overboard via the ship’s collection, holding, and transfer (CHT) system if outside 12 n.m. Fixer

solutions must always be containerized for shore disposal within 12 n.m. Beyond 12 n.m. the

fixer solution may be discharged overboard, provided the fixer solution is processed through a

silver recovery unit, if one is available on-board.3 A silver recovery unit uses an electrolytic

recovery assembly to recover the silver from the recycled fixer solution.2 The effluent from the

recovery unit is then containerized, or discharged overboard if outside 12 n.m.1 Color film

processor effluent (small quantities) may be discharged directly overboard beyond 12 n.m. via

the plumbing drain system.3 In port, or in transit within 12 n.m., the effluent is containerized for

shore disposal. In some cases, rinsewater is discharged to the CHT system in port for discharge

ashore if local regulations permit.

The amount and frequency of waste generation across vessel classes will vary depending

upon the vessels’ photo processing capabilities (color and/or black-and-white), equipment, and

operational objectives. Color film processing waste is generated from batch quantities of

developer, fixer, and intensifier solutions. Black-and-white and X-ray film processing waste is

generated from processor effluent, stop bath, detergents, and hardener solutions. Many vessels

are now being outfitted with self contained automatic processors or digital processors.

Automatic processors do not produce a continuous rinsewater stream. Digital processors do not

use chemicals.4

2.2 Releases to the Environment

Photographic processing effluents are only discharged outside of 12 n.m. from shore.

Black-and-white and X-ray photographic processing effluent is discharged overboard via the

CHT system. Color film processor effluent is permitted to be discharged overboard above the
Photo Lab Drains

3

waterline via the plumbing drain system.1 The discharge can consist of stop bath, detergents,

hardener, developer, fixer, and rinse solutions.

2.3 Vessels Producing the Discharge

Navy vessels such as aircraft carriers (CV/CVN), amphibious assault ships

(LHD/LHA/LPD/LCC), and submarine tenders (AS) have photographic laboratory facilities,

including color, black-and-white and X-ray photographic processors. Two Military Sealift

Command (MSC) hospital ships (T-AH) have photo processing equipment, but neither is used on

a routine basis or within U.S. contiguous or territorial waters. The U. S. Coast Guard (USCG)

currently has two WAGB 400 Class icebreakers with photographic and X-ray processing

capabilities, but does not discharge wastes overboard within 12 n.m. of shore.5 The Army and

the Air Force are not expected to produce this discharge because their vessels do not have

photographic developing capabilities.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Naval Ships’ Technical Manual (NSTM), Chapter 593, provides uniform guidance in the

handling and disposal of photographic processing chemicals. While in port or in transit within

12 n.m., all discharges of X-ray, color and black-and-white photographic processing fixers, and

developers are containerized for shore-side disposal. Film rinsewaters are not containerized in

port due to their large volumes, but are disposed of in to the CHT system. The CHT system is

connected to the pierside collection piping while the vessel is docked. Therefore, overboard

discharges of photographic processing effluents do not occur from any vessel within 12 n.m. of

shore, and most vessels containerize their waste even beyond this point.

Beyond 12 n.m., all photo processing chemicals, if not containerized, are directed to the

CHT system where they are mixed with blackwater and discharged overboard.3 Wastes that can

be directed to the CHT system are black-and-white and X-ray film processing waste from

processor effluent, stop bath, detergents, hardener solutions, and silver recovery unit effluent.

3.2 Rate

Discharge flow rate data were not obtained.

3.3 Constituents
Photo Lab Drains

4

Table 1 lists the chemical constituents identified in the most commonly used developing

solutions and fixers, and in rinse waters on vessels of the Armed Forces. Silver is the only

priority pollutant in this discharge. There are no known bioaccumulators identified in this

discharge.

3.4 Concentrations

The range of photographic processing chemical concentrations was not obtained.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. Mass loadings are

discussed in Section 4.1 and the concentrations of discharge constituents after release to the

environment are discussed in Section 4.2. In Section 4.3, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

Constituent mass loadings were not calculated since the discharge does not occur inside

12 n.m. Furthermore, discharge concentrations and flow rates are unknown.

4.2 Environmental Concentrations

Concentrations released to the environment were not calculated since the discharge does

not occur inside 12 n.m. and the discharge concentrations are unknown.

4.3 Potential for Introducing Non-Indigenous Species

Potable water is used in photographic laboratories; therefore, there is no possibility for

the introduction, transport, or release of non-indigenous species.

5.0 CONCLUSIONS

Existing data are insufficient to determine whether drainage from shipboard photographic

labs has the potential (or has a low potential) of causing an adverse environmental effect.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources were obtained. Table 2

shows the sources of the data used to develop this NOD report.
Photo Lab Drains

5

Specific References

1. Naval Ships’ Technical Manual (NSTM) Chapter 593 Appendix D, pp D-9 and D-10,

Disposal Guidelines For Shipboard Hazardous Waste. September 1, 1991.

2. Laboratory Evaluation of a Photographic Wastewater Processing System, prepared by

David W. Taylor Naval Ship Research and Development Center, Bethesda, MD. August,

1982.

3. UNDS Equipment Expert Meeting Minutes. Photo Laboratory Discharges - April 2,

1997.

4. Personal Communication Between John Julian, NAVSEA 03L13, and Sr. Chief Freeland,

Naval Imaging Command, on Self Contained Automatic Processors and Digital

Processors for use in Photographic Laboratory. September 23, 1997.

5. Personal Communication Between LT. Joyce Aivalotis, U.S. Coast Guard and Dan

Mosher of Malcolm Pirnie, Inc., on USCG Photographic Processing Procedures. April

28, 1997.

6. Personal Communication Between Albert Browne, NAVSEA 03L13, and Mr. Joseph

MacDonald, NAVSEADET (PERA-CV), on Kodak Processor Chemistry Listings for

Kreonite/Kodak RA-4, Black-and-White Imagemaker, and Kodak C-41 Color

Imagemaker Processors. July 25, 1996.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
Photo Lab Drains

6

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Photo Lab Drains

7

Table 1. Chemical Constituents Identified in the Most Commonly Used Photographic

Developing Solutions and Fixers, and in Rinse Waters on Vessels of the Armed Forces6

1,3 - propylenediaminetetraacetic acid Diethanolamine - sulfur dioxide potassium hydroxide

2- aminoethanol Diethanolamine - sulfur dioxide

complex

potassium sulfite

4 - (N-ethyl- N-2-

methanesulfonylaminoethyl) - 2 -

methylphenylenediamine sesquisulfate

monohydrate

diethylene glycol propylene glycol

4 - (N-ethyl-N-2-hydroxyethl)-2-

methylphenylenediamine sulfate

Formaldehyde silver*

4 - (N-ethyl- N-2-

methanesulfonylaminoethyl) - 2 -

methylphenylenediomine sulfate

glacial acetic acid sodium acetate

acetic acid Hydroquinone sodium bisulfite

aluminum sulfate Hydroxylamine sulfate sodium citrate

Ammonia Isothiazolones sodium metabisulfite

ammonium (ethylenodinitrilo) tetraacete)

ferrate

lithium sulfate sodium sulfite

ammonium acetate methyl alcohol sodium sulfosuccinate

ammonium bromide N,N-diethylhydroxylamine stilbene brightner

ammonium citrate nitric acid sulfuric acid

ammonium ferric ethylenediaminetetra

acetic acid

Organosilicone fluid tetra sodium ethylene

diamine tetraacetrate

ammonium ferric

propylenediaminetetraacetic acid

penitetic acid triethanolamine

ammonium sulfite potassium bicarbonate

ammonium thiosulfate potassium carbonate

boric acid potassium chloride

* Priority Pollutant

Table 2. Data Sources

Data Sources

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and Operation X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate (NA)

3.3 Constituents X X

3.4 Concentrations (NA)

4.1 Mass Loadings (NA)

4.2 Environmental Concentrations (NA)

4.3 Potential for Introducing NonIndigenous SpeciesX

Note: NA = not applicable
Portable Damage Control Drain Pump Discharges

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Portable Damage Control Drain Pump Discharges
Portable Damage Control Drain Pump Discharges

2

2.0 DISCHARGE DESCRIPTION

This section describes the portable damage control drain pump discharge and includes

information on: the equipment that is used and its operation (Section 2.1), general description of

the constituents of the discharge (Section 2.2), and the vessels that produce this discharge

(Section 2.3).

2.1 Equipment Description and Operation

Damage control (DC) systems are the fluid, electrical, and ventilation systems that

contribute to combating fires, controlling or removing smoke and/or water, or transmitting power

and communications. Facilities for dewatering compartments in the event of an emergency

consist of fixed drainage systems within the vessel and portable equipment, such as electric

submersible pumps, P-250 or P-100 pumps, and eductors (Figure 1). Portable DC dewatering

equipment is used in emergencies to assist recovery from fire and flooding events by removing

fluids from damaged compartments or from compartments without drainage systems located

close to, or below, the waterline. Emergency situations are not incidental to the normal operation

of the vessel and therefore not considered in this report. The only required operation which

produces a discharge incidental to the normal operation of the vessel is during planned

maintenance system (PMS) activities for the equipment. This report addresses only planned

maintenance activity discharges from this equipment.

Three basic types of dewatering equipment used in damage control situations are

described below.

• Portable electric submersible pumps are used to dewater compartments that do not

have an installed drainage system. The pump is driven by an electric motor enclosed

in a watertight case that allows the pump to operate while submerged. These pumps

are fitted with strainers to prevent debris from clogging the impeller. This pump

does not use a suction hose, and the fluid is discharged through a fire hose.

• Portable engine-driven pumps are designed for firefighting but can also be used for

dewatering operations. Engine-driven pumps take suction through a hard rubber hose

and discharge through a fire hose. The P-250 has a pumping capacity of 250 gallons

per minute (gpm). The P-100 pump is driven by an air-cooled diesel engine and has a

pumping capacity of 100 gallons per minute (gpm). The P-1 (Figure 2) and P-5 (CGP1B and CG-P5) are gasoline-driven portable pumps used by the U.S. Coast Guard

(USCG). The P-5 is similar in design to the P-1, but it has a larger pumping capacity.

The P-1 has a pumping capacity of 120 gpm, and the P-5 has a pumping capacity of

200 gpm.1,2

• Portable eductors Portable eductors are actuated from the discharge of a P-250 or P100 pump or through a fire hose using the vessel’s installed firemain. A suction hose

is not used with portable eductors because the eductor is submerged during operation.

The eductor discharges through a fire hose which is lead directly overboard.
Portable Damage Control Drain Pump Discharges

3

Maintenance schedules for the portable electric submersible pump and portable eductors

do not include a requirement for operation that will produce a discharge.3 The USCG P-1 and P5 pumps are pre-packaged for transfer to a vessel in distress, and periodic maintenance schedules

do not include a requirement to operate the pumps to produce a discharge. The maintenance

schedules for the Navy, the Military Sealift Command (MSC), and Army P-100 and P-250

pumps include a requirement to operate the pumps monthly for 10 minutes and annually for 15

minutes: the annual check is concurrent with a monthly check.4 Current USCG maintenance

schedules require P-250 pumps to be operated for 30 minutes each month, but the maintenance

procedures are expected to be changed to require only a 15 minute run each month.5,6

2.2 Releases to the Environment

During maintenance, P-250 and P-100 pumps are operated to demonstrate proper function

by pumping seawater adjacent to the vessel via a hard rubber suction hose through the system

and discharging it directly overboard through a fire hose.7

The P-250 pump uses a portion of the pump discharge to cool the engine exhaust. This

cooling water is discharged separately from the pump discharge and is not considered part of this

discharge stream. It is addressed in a separate NOD report entitled “Portable Damage Control

2.3 Vessels Producing the Discharge

All Navy, MSC, and USCG surface ships can discharge seawater from portable DC drain

pumps. There are 906 emergency fire pumps on Navy surface vessels. The MSC maintains 137

pumps, and the USCG has 370 pumps on its surface vessels. The Army is currently equipped

with 60 P-250 MOD 1 pumps and six P-100 pumps. The Air Force does not use portable pumps

on any of their water craft. The numbers of individual pumps within the fleets are: 8,9,10,11,12,13,14

P-250 MOD 1 P-100

Navy 70 836

MSC 0 137

USCG 370 0

Army 60 6

Totals 500 979

The Navy is completely converting to P-100 pumps, and it is estimated that all P-250’s in

Navy service will be replaced by P-100’s by the end of 1998.8 The Army has also begun to

replace P-250’s with P-100 pumps, but a timetable for complete conversion has not yet been

developed

As mentioned previously, the USCG P-1 and P-5 pumps are pre-packaged for transfer to

a vessel in distress. These pumps are not required to be operated during periodic maintenance so

these pumps produce no discharge incidental to normal vessel operations.
Portable Damage Control Drain Pump Discharges

4

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

As part of equipment maintenance, the portable damage control equipment is operated

within 12 nautical miles (n.m.).

3.2 Rate

Individual vessel discharge volumes from emergency pumps will vary depending on the

numbers and types of pumps aboard each vessel. Therefore, flow rates will be calculated on a

fleet-wide basis instead of a ship-by-ship basis.

Using standard maintenance operating schedules, pump inventory data, and pump

discharge rates, discharge flow estimates were calculated as shown in Table 1. During monthly

maintenance activities, the Navy, MSC, and Army run pumps for approximately 10 minutes and

for approximately 15 minutes during annual maintenance checks. The USCG currently operates

its pumps for 30 minutes per month. The resulting total annual discharge is approximately

49,062,500 gallons.

Approximate annual flow rates for representative ship types are listed below:

Ship Type Pump Type

Carried and

Number per Ship

Pump Flow

Rate (gpm)

Annual

Operating Time

(Minutes/Year)

Total Yearly

Flow rate

per Ship

Surface Combatant

(DD, DDG, CG, FFG)

4 - P-100’s 100 125 50,000

Large Auxiliary or

Amphibious Ship

(e.g.: AFS, AOE, LPD, LSD)

6 - P-100’s 100 125 75,000

USCG Cutter (WHEC) 3 - P-250’s 250 360 270,000

Army Watercraft (LCU-1600) 1 - P-250’s 250 125 31,250

3.3 Constituents

The portable DC drain pump discharge is seawater that is pumped during maintenance

activities. The seawater contacts rubber suction hoses and the rubber lining of firehoses. It also

contacts the wetted components of the pump (e.g. impeller). The pumps and hoses are not
Portable Damage Control Drain Pump Discharges

5

expected to contribute measurable amounts of pollutants to the discharge because the residence

times of the seawater within the equipment is less than 5 seconds.

3.4 Concentrations

The discharge is expected to be seawater with no measurable contribution of constituents

from the pumping process.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings and environmental concentrations are discussed in Section 4.1 and 4.2. In Section 4.3,

the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The portable DC drain pump discharge is seawater that is pumped during maintenance

activities. The seawater contacts rubber suction hoses and the rubber lining of firehoses. It also

contacts the wetted components of the pump (e.g. impeller). The pumps and hoses are not

expected to contribute measurable amounts of pollutants to the discharge because the residence

times of the seawater within the equipment is less than 5 seconds.

4.2 Environmental Concentrations

The discharge is expected to be seawater with no measurable contribution of constituents

from the pumping process.

4.3 Potential for Introducing Non-Indigenous Species

There is an insignificant potential for introducing non-indigenous species from this

discharge. The seawater pumped through the portable DC drain pumps is discharged in the same

location from which it was taken.

5.0 CONCLUSION

The portable DC drain pump discharge has a low potential for causing an adverse

environmental effect because the discharge consists of seawater pumped and discharged at the

same location from which it was taken. The pumps and hoses are not expected to contribute

significant amounts of pollutants to the discharge because the residence time of the seawater

within the equipment is less than 5 seconds.
Portable Damage Control Drain Pump Discharges

6

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information and assumptions were used to estimate the annual discharge volume. Table 2 shows

the source of the data used to develop this NOD report.

Specific References

1. Gallagher, Larry, M. Rosenblatt & Son, Inc. Portable DC Dewatering Equipment, April

1997, Leslie Panek, Versar, Inc.

2. USCG COMDTINST M10470.10C - Chapter 2, Dewatering Pump Kit. Unknown date.

3. Maintenance Index Page (MIP) 6641/Z06-76, Damage Control Stations. April 1995.

4. Maintenance Index Page (MIP) 6641/008-B2, Portable Gasoline/JP-5 Driven Pump.

November 1992.

5. USCG Uniform Maintenance Procedure Card (UMPC) R-M-014.

6. Personal Communication, LT Joyce Aivalotis USCG to M. Rosenblatt & Son, June 5,

1997.

7. Steinberg, Bob, M. Rosenblatt & Son, Inc. Portable DC Dewatering Equipment, January

1997, Leslie Panek, Versar, Inc.

8. Personal Communication (Fonecon): Steinberg, Bob, M. Rosenblatt & Son. Status of

USN P-250 Replacement Program, 23 January 1998, Mark Hampson, NSWC

9. UNDS Equipment Expert Meeting Minutes - Emergency Fire Pump Wet Exhaust. March

26, 1997.

10. Personal Communication between Chief Warrant Officer Dunbar, USCG and Doug

Hamm, Malcolm Pirnie, Inc., January 26, 1997 and March 27, 1997.

11. Personal Communication (Fonecon): Steinberg, Bob, M Rosenblatt & Son. Status of

MSC P-250 Replacement Program, 5 February 1998, Joe Bohr, MSC Code N72PC

12. Saponara, N. et al. “UNDS Shipcheck of US Army Watercraft, Fort Eustis, VA, 21-22

January 1998: Trip Summary”, undated

13. Personal Communication (Fonecon): Steinberg, Bob, M. Rosenblatt & Son, Inc. Army

Purchases of P-100 Pumps, 14 January 1998, Paul Darley, W.S. Darley & Co.

14. Personal Communication (VoiceMail): Chew, Don, LCOL, USAF, HQ, USAF (ILTV).
Portable Damage Control Drain Pump Discharges

7

Portable damage control pumps on Air Force Watercraft, 21 January 1998, Bob

Steinberg, M. Rosenblatt & Son, Inc.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
Portable Damage Control Drain Pump Discharges

8

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Portable Damage Control Drain Pump Discharges

9

Figure 1. Dewatering Equipment
Portable Damage Control Drain Pump Discharges

10

Figure 2. Portable Dewatering Pump (Model CG-P1B)
Portable Damage Control Drain Pump Discharges

11

Table 1. Annual Discharge from Portable DC Drain Pumps

Service Pump Model Number of Pumps Flow

(GPM)

Annual

Operating Time

(Minutes/Year)

Annual Discharge

(Gallons/Year)

Navy

P-250 MOD 1 70 250 125 2,187,500

P-100 793 100 125 9,912,500

Navy Total: 12,100,000

MSC

P-250 MOD 1 0 250 125 0

P-100 137 100 125 1,712,500

MSC Total: 1,712,500

USCG P-250 MOD 1 370 250 360 33,300,000

Army P-250 MOD 1 60 250 125 1,875,000

P-100 6 100 125 75,000

Army Total: 1,950,000

Cumulative Total: 49,062,500

Table 2. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and Operation Equipment manuals

PMS cards

X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge X X

3.1 Locality X X

3.2 Rate PMS cards X

3.3 Constituents X X X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Non-indigenous Species X
Refrigeration/AC Condensate

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Refrigeration/AC Condensate
Refrigeration/AC Condensate

2

2.0 DISCHARGE DESCRIPTION

This section describes the condensation discharge that is produced from air conditioner

(AC) units, refrigerated spaces, and stand-alone refrigeration units and includes information on:

the equipment that is used and its operation (Section 2.1), general description of the constituents

of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

AC units provide cooling for ship spaces. When warm, moist air passes over the

refrigeration coils of an AC unit, condensation forms that drips from the coils. This condensation

is produced continuously while the AC unit is operating. In addition to AC units, vessels have

refrigerated spaces for food and other perishable materials. These spaces are designed for both

frozen and chilled cargo and commonly range in temperature from below 0 °F to 35 °F.1

Condensation also forms from the normal operation of these refrigerated spaces when moist air is

cooled below the dew point on the cold evaporator coils of the refrigeration system. The

condensate is collected in drains in these refrigerated spaces.

Two types of refrigerated space systems are used: gravity-coil units and forced-air units.

Gravity-coil units are typically used in older ships. They employ tinned-copper refrigerant piping

which runs back and forth along one or more bulkheads in the refrigerated space.1 Aluminum

fins are attached to the piping to provide a large surface area for the exchange of heat. As the air

cools, it becomes more dense and sinks below the comparatively warmer air, creating circulation

without the need for a fan. One disadvantage to this type of cooling unit is that the tubing is

bulky, so the use of gravity-coil units has been discontinued on newer Navy ships. Forced-air

refrigeration units are more compact, self-contained, and use a fan to blow air across the coils.

The forced-air units can be used not only in cold storage spaces, but also in other ship spaces.

On most surface ships, gravity coil refrigerant piping is made of tinned-copper.1,2,3 The

forced-air units have brazed-copper piping. Submarine refrigerated space refrigerant piping and

evaporator coils are made of copper.1

Drip troughs (galvanized steel or tinned-copper) are installed under gravity-type cooling

coils to collect condensate or water during defrosting.1 The piping from these troughs is as short as

practicable and leads to compartment drain piping. The forced-air units have drip pans made of

galvanized steel or tinned-copper which are placed under the units to collect the condensate.

Valved deck drains are also installed in refrigerated spaces that have operating temperatures

above 32°F. Deck drains are installed in refrigerated spaces with operating temperatures below

32°F. At least one deck drain is installed in the passage or compartment outside the refrigerated

food storage spaces.1

The condensate drainage is similar for vessels of all the Armed Forces: condensate

produced above the waterline is directed overboard; condensate produced below the waterline is

retained on board temporarily before it is pumped overboard. On most Navy ships, condensate is

routed directly overboard or combined in a common condensate drain and discharged overboard
Refrigeration/AC Condensate

3

if the space is above the waterline or to a condensate drain tank if the space is below the water

line.2 Some condensate may also be directed to the machinery space wastewater drain system,

the wastewater receiving tank, the sewage collection, holding, and transfer (CHT) tank, or the

bilge. On Army watercraft, condensate from refrigeration and air conditioning systems is not

collected. Any condensate which forms is typically removed by natural evaporation; if a

significant amount of condensate accumulates, it may be removed by mopping or wiping. On

vessels of the other Armed Forces, the condensate is discharged to the bilge from spaces below

the waterline.

On submarines, drains are installed in chilled stores space decks to remove water from

condensation and defrosting. The drains are provided with an isolation valve and lead to a bilge

collecting tank or sanitary tank.

2.2 Releases to the Environment

Refrigeration/AC condensate is generally released to the environment by direct gravity

drainage overboard, or in some cases from a condensate drain tank or other collection points

below the waterline. In addition to continuous condensate drainage, intermittent discharges from

refrigerated spaces include water and mild detergents used for cleaning (generally weekly), and

water from melting ice that is created when the spaces are defrosted (for gravity-coil units,

weekly or when the thickness of the frost on the refrigeration coils exceeds 3/16 inch).4 The

water from cleaning and defrosting is discharged into the space drains or the deck drains.

Organic materials can be an infrequent part of the discharge from residual spilled food

items that wash into the drainage. Although spilled food can be washed to drains occasionally,

spills would normally be cleaned and disposed of as solid waste or into graywater drains.

Navy supply ships that carry refrigerated cargo for at-sea replenishment of Navy combatants

use hot seawater spray to defrost the cargo spaces. This seawater, as well as the freshwater used to

flush out any residual seawater after defrosting, is discharged through the refrigeration condensate

drainage piping. The seawater is provided by the firemain and is heated to 100 °F by a dedicated

heater prior to being sprayed at a maximum rate of 100 gallons per minute on the refrigeration

coils. The vessel classes that employ heated seawater spray for defrosting are the AFS, AOE,

AO, and AOR classes.5

Refrigeration condensate could contain trace amounts of metal from the refrigerant coils

and drainage piping, but these concentrations are expected to be comparatively low (see Section

3.4).

2.3 Vessels Producing the Discharge

Navy and MSC vessels produce refrigeration and AC condensate; this includes 254 Navy

surface ships, 94 Navy submarines, and 70 MSC ships. 2 In addition, an estimated 228 Coast

Guard vessels and 4 Air Force vessels produce this discharge.
Refrigeration/AC Condensate

4

The primary difference between ship classes is the amount of condensate that is

generated, which depends on ambient temperature, relative humidity, and the size and number of

units per ship. USCG vessels also produce refrigeration and AC condensate, and use

specifications similar to the Navy for refrigeration and AC units. Army watercraft have no

collection or discharge of condensate from refrigeration or air conditioning systems.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Flows from refrigeration units and AC units can be discharged at any time, both within

and beyond 12 nautical miles (n.m.) from shore. Operation of the refrigerated spaces and AC

units in port or in transit is not significantly different from operation beyond 12 n.m. from shore.

3.2 Rate

No measurements are available to fully characterize the flow for refrigeration/AC

condensate for all ship classes. The range of flow rates volumes will depend on the temperature

and humidity of the air and the capacity of the cooling units.

Amphibious ships and aircraft carriers of the Navy tend to have the most air conditioning

capacity because of their large contingent of personnel, and therefore, represent worst-case flow

rates for AC condensate discharge. An estimate of AC condensate volume was developed for an

amphibious ship and an aircraft carrier. The estimate was derived for typical ship operating

conditions. The worst-case scenario assumes an unlimited supply of humid air (above 60°F) to

the AC system. In reality, after the air has been dehumidified, the exchange rates with new air

are much lower and will limit available moisture for condensate to about half the worst case

amount. The estimate also assumed that condensate is generated when the outside air is 60°F dry

bulb or higher.6

Based on the above conditions, an amphibious ship will generate no more than 3,840

gallons of condensate per day, and an aircraft carrier no more than 6,795 gallons per day.

Vessels of the other Armed Forces tend be smaller and have fewer personnel, and therefore, will

produce less AC condensate discharge.

3.3 Constituents

Refrigeration condensate could contain metals from the refrigerant coils and condensate

drainage piping, and mild detergents from the occasional cleaning of the refrigerated spaces. AC
Refrigeration/AC Condensate

5

condensate could contain small amounts of metal from the AC coils or the drain piping. These

materials can include aluminum, bronze, copper, iron, lead, nickel, silver, tin, and zinc.

Food particles washed into the condensate drainage system from occasional food spills

would increase the Biochemical Oxygen Demand (BOD) in the discharged water. Seawater used

to defrost cargo spaces on Navy supply ships, and the freshwater used to flush residual seawater

from the cargo spaces are also intermittent constituents of this discharge.

The priority pollutants of this discharge are copper, lead, nickel, silver, and zinc. None of

the constituents of this discharge is a bioaccumulator.

3.4 Concentrations

Refrigeration/AC condensate can contain small amounts of metals from contact with

refrigerant coils and condensate drainage piping. These concentrations are expected to be low for

the following reasons:

1) Condensate is essentially pure water and is not a corrosive medium such as seawater;

2) Drainage lines are only fractionally full of condensate which indicates qualitatively

low flow and low residence time;

3) Condensate drainage flow velocities and turbulence are extremely low. Therefore,

erosion of metals in drainage is not a factor as it could be in pressurized seawater

systems;

4) The residence time of condensate in drainage systems is low. The negligible increase

in the residence time because of the slower flow does not increase the chance of

entrainment of metals;

5) Copper drainage piping forms a protective corrosion-inhibiting film of cuprous oxide

on surfaces in contact with water;7 and

6) The low temperature of this discharge, both on refrigeration coils and in the

condensate drainage piping, would tend to inhibit the corrosion process.

Food spills which could contribute some organic matter to the discharge are intermittent

and limited to small amounts. Therefore, they are expected to contribute very little BOD to the

discharge. Seawater is also a component of refrigeration condensate discharge of vessels with

cargo refrigeration spaces.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. Mass loadings are

discussed in Section 4.1 and the concentrations of discharge constituents after release to the

environment are discussed in Section 4.2. In Section 4.3, the potential for the transfer of nonindigenous species is discussed.
Refrigeration/AC Condensate

6

4.1 Mass Loadings

Mass loadings were not calculated for this discharge.

4.2 Environmental Concentrations

Refrigeration/AC condensate is essentially atmospheric moisture which condenses on

refrigeration coils. For reasons stated in Section 3.4, concentrations of any of the potential

constituents in this discharge are expected to be low. Therefore, the probability that this

discharge results in any measurable effect on environmental concentrations is low.

4.3 Potential for Introducing Non-Indigenous Species

Because this discharge consists of atmospheric moisture, the potential for introducing

non-indigenous species is not significant.

5.0 CONCLUSION

Mass loadings and environmental concentrations cannot be calculated with existing

information; however, process information is sufficient to characterize the concentrations and

loadings of constituents of this discharge.

Refrigeration/AC condensate has a low potential for adverse environmental effect

because:

1) the liquid discharge is moisture condensed from the air;

2) concentrations of metals are expected to be low due to the non-erosive and noncorrosive nature of this discharge, and its low temperature; and

3) the contribution from detergents and from food residues is expected to be small and

intermittent in nature.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 1

shows the sources of data used to develop this NOD report.

Specific References

1. Naval Sea Systems Command (NAVSEA), General Specifications for Ships of the United

States Navy, Section 516 - Refrigeration Plants. 1995 Edition.

2. UNDS Equipment Expert Meeting - Refrigeration/AC Condensate. 15 October 1996.
Refrigeration/AC Condensate

7

3. Military Sealift Command (MSC), General Specifications for T-ships, Section 514 - Air

Conditioning Refrigeration Systems. 1991 Edition.

4. Maintenance Requirement Card (MRC) A3 8YVEN, Refrigeration Plant. October 1993.

5. Kitchen, Gary, NAVSEA 03L2. Cargo Space Refrigeration Coil Defrosting, 9 January

1998, Matthew Worris, M. Rosenblatt & Son, Inc.

6. Goodhue, John, NAVSEA 03L2. Estimate of Air Conditioning Condensate Rates for

UNDS, 23 April 1997, Leslie Panek, Versar, Inc.

7. Davis, Joseph R., et al., Metals Handbook Ninth Edition, Volume 13, Corrosion, ASM

International Handbook Committee, Metals Park, Ohio, 1990.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.
Refrigeration/AC Condensate

8

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Naval Sea Systems Command (NAVSEA), General Specifications for Ships of the United States

Navy, Section 528 - Plumbing, Plumbing Vents, and Space and Weather Deck Drains.

1995 Edition.

Naval Sea Systems Command (NAVSEA), General Specifications for Ships of the United States

Navy, Section 534 - Machinery and Piping Systems Drainage. 1995 Edition.

Baumeister, Theodore; Eugene Avallone; and Theodore Baumeister III. Marks' Standard

Handbook for Mechanical Engineers. McGraw-Hill Book Company, Eighth Edition,

1978.

Harrington, Roy L. Marine Engineering. The Society of Naval Architects and Marine Engineers,

1971.

Sharpe, Richard. Jane’s Fighting Ships. Jane’s Information Group, Ltd., 1996.

Naval Sea Systems Command (NAVSEA), General Specifications for Ships of the United States

Navy, Section 514 - Air Conditioning Plants. 1995 Edition.

UNDS Equipment Expert Meeting - U.S. Army Input to Equipment and Expert Meeting,

Refrigeration/AC Condensate. 5 February 1997.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Refrigeration/AC Condensate

9

Table 1. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents MSDS X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Rudder Bearing Lubrication

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Rudder Bearing Lubrication
Rudder Bearing Lubrication

2

2.0 DISCHARGE DESCRIPTION

This section describes the rudder bearing lubrication discharge and includes information

on the equipment used, its operation (Section 2.1), general description of the constituents of the

discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Rudder bearings support the rudder and allow it to turn freely. While there are small

variations among similar rudder bearings systems, there are generally two major types of rudder

bearings and two lubricating methods for each type, resulting in four different bearing/lubrication

method combinations. They are:

• grease-lubricated roller bearings,

• oil-lubricated roller bearings,

• grease-lubricated stave bearings, and

• water-lubricated stave bearings.

Grease-lubricated Roller Bearings. The rudder stock arrangement for grease-lubricated

roller bearings includes a void space between the lower bearing and the hull seal (Figure 1). This

design prevents seawater from entering the bearing and causing damage. Water that leaks past

the hull seal, as well as grease that leaks past the bearing seals, will enter the void space and

drain to the bilge. Thus, discharges from grease-lubricated roller bearings contribute to the

bilgewater discharge which is covered in a separate NOD report. Since 1970, grease-lubricated

roller bearings have been preferred for use on rudder stocks.

Oil-lubricated Roller Bearings. There is no void space in the rudder stock arrangement

used for oil-lubricated roller bearings and the bottom seal of the lower bearing serves as the hull

seal (Figure 2). To prevent water from entering the bearing and causing damage, the oil is kept at

a slight positive pressure relative to the surrounding seawater pressure by supplying the oil from

an elevated “head” tank located above the waterline. If a leak occurs, this positive pressure will

cause lubricating oil to leak directly into the sea.1

Stave Bearings (Grease and Water Lubricated). This type of bearing is typically

located outside of the hull (Figure 3). Stave bearings, which are similar in appearance to the

wooden staves that make up a barrel, are typically made of a phenolic-resin material. Depending

on the actual type, these stave bearings may be lubricated by grease or water. Grease, when used,

is forced into the bearing to lubricate the area where the rudder stock and staves meet. Waterlubricated stave bearings are designed with passages which allow seawater to flow through the

bearing. For classification purposes, the bushings found on small boats and craft are included in

this subheading due to the similarities in function and design.

Hull seals are used with all types of rudder bearings. A hull seal is installed where the

rudder stock penetrates the hull. This seal prevents seawater from entering the ship and

damaging the lower bearing, while in the case of oil-lubricated roller bearings it also keeps the
Rudder Bearing Lubrication

3

oil in the bearing cavity from leaking to the sea. In many cases this seal is a type of lip seal but

flax packing can be found on older ships. A lip seal consists of a rubber circular ring with a

flexible lip. This lip has a narrow contact area that rubs on the circumference of the shaft,

forming a seal. Flax packing seals in a similar fashion as several rows of the circular packing

material rubs along the rudder stock. Minor leakage can occur in both cases and their rubbing

contact will eventually cause wear on the rudder stock. Hull seals are inspected when the ship is

in dry dock, typically every four or five years.

The potential of oil leakage from lip seals and flax packing is greatest when a vessel is

underway and the rudder is in use rather than when pierside and the rudder is idle. When the

vessel is underway, the action of turning exerts forces on the rudder and rudder stock that can

cause a temporary gap in the seal or packing coverage. The harder the turn or higher the vessel

speed, the greater these forces are and the greater the potential is for oil leakage and the amount

of leakage.

The latest trend in rudder stock hull sealing is to use a face seal. These seals eliminate

the minor leakage sometimes associated with lip seals and flax packing. Face seals move the

sealing point away from the rudder stock to two circular, hard, mating faces. One half of the seal

rotates with the rudder stock while the other half is rigidly attached to the hull of the ship. These

mating faces are honed to very small tolerances and while rubbing together prevent liquids from

seeping through their very fine and smooth contact area. Face seals used on rudder stocks are

designed not to leak as a result of the forces placed on the rudder stock during turning.1

2.2 Releases to the Environment

The two releases possible are oil from oil-lubricated roller bearings and grease from

grease-lubricated stave bearings.

2.3 Vessels Producing the Discharge

All Navy surface ships have rudder bearings, except for those with steerable thrusters or

cycloidal propellers, such as the MHC 51 Class minesweepers.1 Vessels belonging to the

Military Sealift Command (MSC), U.S. Coast Guard (USCG), Army, and Air Force also have

rudder bearings.

Most rudder bearings (roller or stave) are grease-lubricated. Only the AS 36/39 Class and

AOE 1 Class ships, which form 4 percent of the total number of Navy ships, have oil-lubricated

rudder bearings. The T-AFS 1 and T-AE 26 Classes of MSC are also fitted with oil-lubricated

rudder bearings. USCG vessels do not have oil-lubricated rudder bearings. The rudder bearings

or bushings found on small boats and craft are typically made of self-lubricating materials and

are either not lubricated or use water for lubrication.

Surface ship rudders with oil-lubricated roller bearings and grease-lubricated stave

bearings have the potential to produce an oil or grease discharge. Table 1 lists the rudder bearing

type and lubrication method for each Navy ship class. There are currently five Navy ships that
Rudder Bearing Lubrication

4

use oil lubrication for rudder bearings. Five AS 36/39 Class ships (submarine tenders) and four

AOE 1 Class ships (fast combat support ships) were originally fitted with lip seals. Of the

submarine tenders, AS 36 and AS 37 are being decommissioned.2 The three remaining ships

(AS 39-41) are currently scheduled to have their lip seals replaced with face seals. The

replacements are expected to begin in 1999 and conclude in 2002.1 Of the four AOE 1 Class

ships, AOE 2 and AOE 3 have been fitted with face seals. The other two ships in the class are

also scheduled to be fitted with the same type of face seal.3 Therefore, any discharges of oil from

the rudder bearings on Navy vessels is expected to be eliminated in the next 4 to 5 years. Of the

MSC ships, the T-AE 35 had the face seal installed in December 1997.4

USCG ships use water- and grease-lubricated bearings on their rudder stocks, as

summarized in Table 2.5 Small boats and craft use bearings/bushings that are either selflubricated or water-lubricated. The lubricity of the materials used in self-lubricated

bearings/bushings is such that additional lubricants are not required; water-lubricated

bearings/bushings are also made of special materials, but require water to be present on their

contact surfaces for proper lubrication. Table 3 lists the rudder bearings/bushings found in

USCG small boats and craft.6 The upper bearing/bushing of these small boats and craft is

typically self- or grease-lubricated because it may not contact the water, while the lower

bearing/bushing is lubricated by being submerged in the water. The USCG is increasing the use

of self-lubricated bearing material in its ships and is reducing the use of grease as a lubricating

material in all areas exposed to the sea and weather.5

Table 4 lists MSC vessels, including the type of bearing, method of lubrication, and

allowable leakage rates. Eight TAE 26 Class and eight TAFS 1 Class vessels have oil lubricated

bearings.

Army and Air Force vessels have rudder bearings similar to those found on Coast Guard

vessels of comparable size.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information which characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

This discharge can occur in port and while operating within 12 nautical miles (n.m.).

3.2 Rate

This discharge comprises the leaking of oil or the washout of grease from rudder

bearings. For the oil discharge, rules-of-thumb for characterizing hull seal failure limit the hull
Rudder Bearing Lubrication

5

seal leakage rates to one gallon per day at sea and one pint per day in port.2 These rates are

abnormally high and are typically associated with a malfunctioning or failing seal. Little or no

leakage would be expected from a properly functioning and maintained seal.

3.3 Constituents

In general, greases and lubricating oils are made from lubricating stocks generated during

petroleum fractionation. These fractions contain organic compounds that are generally larger

molecules, containing more than 17 carbon atoms. Lubricating oils are composed of aliphatic,

olefinic, naphthenic (cycloparaffinic), and aromatic hydrocarbons, as well as additives,

depending on their specific use. Lubricating oil additives may include antioxidants, bearing

protectors, wear resistors, dispersants, detergents, viscosity index improvers, pourpoint

depressors, and antifoaming and rust-resisting agents.7 Not all the additives may be present at

one time. It is anticipated that the additives are similar to those found in commercial oils. There

are no bioaccumulators expected to be present in this discharge.

3.4 Concentrations

The greases and lubricating oils used conform to MIL-G-24139 specifications and

2190TEP (MIL-L-17331) respectively.1 Based on MSDS information, MIL-G-24139 grease

contains 86% hydrotreated heavy paraffinic distillates, 6% clay, and 4% fatty acid amides.

Lubricating oil 2190 TEP contains greater than 99% heavy hydrotreated paraffinic distillates and

less than 1% additives.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality standards. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loading

4.1.1 Oil

At Sea. A high estimate of the oil released by a ship at sea is one gallon of oil per day, as

discussed in Section 3.2. It is also estimated that it takes 4 hours for a ship to cover the 12 n.m.

transit zone. Therefore, during each transit (either into or out of port), one-sixth of a gallon of oil

could be released. An AOE 1 Class ship averages 22 transits per year and an AS 36/39 Class

ship averages 12 transits per year. Under this scenario, an AOE 1 Class ship could release

(1/6)(22) = 3.7 gallons of oil and an AS 36/39 Class ship would release (1/6)(12) = 2.0 gallons of

oil to the surrounding seawater each year. As stated in Section 2.3, two AOE 1 Class ships and 3

AS 36/39 Class ships have oil-lubricated bearings. The maximum estimated amount of oil
Rudder Bearing Lubrication

6

released from Navy ships fleetwide per year within 12 n.m. would be (3.7)(2) + (2.0)(3) = 13.4

gallons. Using a specific gravity of 0.89 for oil (MSDS for 2190TEP), this translates into

approximately 100 pounds per year (lbs/year).

Using the same logic for the MSC ships, eight T-AE 26 Class (8 transits) and eight TAFS 1 Class (14 transits), the total mass loading would be:

(1/6 gallons)(8 transits)(8 ships) + (1/8 gallons)(14 transits)(8 ships) =

29.3 gallons or 218 lbs/year

Therefore, the total mass loading at sea during transit would be 100 + 218 = 318 lbs/year.

However, the actual release rates will be much less because all ships of a class will not leak oil at

such high rates, for such a long period of time, at the same time.

In Port. A high estimate of the oil released by a ship in port is one pint per day, as

discussed in Section 3.2. Assuming that each of the two AOE 1 Class and three AS 36/39 Class

ships spend 183 days per year in port, the total amount of oil released would be (1 pint)(5

ships)(183 days/yr) = 915 pints or 114 gallons per year. This translates into approximately 846

lbs/year.

For the eight MSC ships, the total amount of oil released in port would be:

(1 pint)(8 ships)(183 days/year) = 1,460 pints/year, 183 gallons/year, or 1,360 lbs/year.

Therefore, the maximum estimated mass loading in port would be 846 + 1,360 = 2,206

lbs/year. However, the actual release rates are expected to be much less because all ships of a

class will not leak oil at such high rates, for such a long period of time, at the same time.

4.1.2 Grease

Grease washout occurs only from grease-lubricated stave bearings and only when the ship

is moving and the rudder is in use. When the ship is first constructed or when the bearings are

overhauled, approximately 2 pounds of grease are used for the entire bearing.1 During the

required, biweekly lubrication of these bearings, the grease is topped-off to replenish the amount

lost while cruising at sea and, therefore, less than 2 pounds are used. Specifications for MIL-G24139 grease require that no more than 5 percent of the grease may wash out when tested in

accordance with the ASTM D-1264 method. It was estimated that for every two weeks underway

(in accordance with the biweekly maintenance requirement), 5 percent of the grease is washed

out and is subsequently replenished. Therefore, a maximum of 0.1 pounds of grease (5% of 2

lbs.) are estimated to be washed out every two weeks underway.

Since the release of grease only occurs through erosion while the ship is moving through

the water, discharges of grease are not expected in port. The 0.1-pound biweekly washout

estimate can be used to calculate the grease washed out per transit. Based on vessel monitoring

data, each vessel, on average, makes 24 transits a year within the 12 n.m. zone.8 Each round trip
Rudder Bearing Lubrication

7

transit (including inbound and outbound transits) lasts approximately 8 hours (0.024 weeks).

Therefore, on each transit, 0.0024 pounds of grease could be discharged (i.e. 0.1 pounds per

week multiplied by 0.024 weeks). Fleetwide, for the 56 vessels that have stave bearings, the

mass loading would be 3.23 pounds (0.0024 pounds per transit x 24 transits per vessel x 56

vessels) within the 12 n.m. zone.

4.2 Environmental Concentrations

4.2.1 Lubricating Oil

At Sea. An estimate was made of the amount of water swept by an AOE 1 Class ship

while in transit. Any rudder bearing oil leaking while underway will be churned into this volume

by the propellers. An AOE 1 Class ship is 107 feet wide. For a draft (depth of ship bottom) of

39 feet and a length of 12 n.m. (72,960 feet), the total volume of water swept is

(107)(39)(72,960) = 304 million cubic feet or 8 billion liters. Therefore, on each transit through

the 12 n.m. zone, for each AOE 1 Class ship, one-sixth of a gallon of oil (i.e., 630 mL) is

released in 8 billion liters of seawater. Using a specific gravity of 0.89 for oil (MSDS for

2190TEP), this translates into a maximum estimated concentration of 7 x 10-5 milligrams per

liter (mg/L).

A similar estimate can be made for an AS 36/39 Class ship that is 85 feet wide. For a

draft of 25.5 feet and a length of 12 n.m. (72,960 feet), the total volume of water swept is

(85)(25.5)(72,960) = 158 million cubic feet or 4.5 billion liters. Therefore, on each transit

through the 12 n.m. zone, for each AS 36/39 Class ship, one-sixth of a gallon of oil (i.e., 630 mL)

is released in 4.5 billion liters of seawater. This translates into a maximum estimated

concentration of 1.2 x 10-4 mg/L.

MSC ships with oil-lubricated rudder bearings (T-AE 26 and T-AFS 1 Classes) have an

average width of 80 feet and an average draft of 26 feet. Therefore, as calculated above for the

Navy ships, the oil concentration resulting from these ships would be approximately 1.3 x 10-4

mg/L.

In Port. While in port the ship is stationary. Any oil that leaks from the rudder bearings

will be mixed continuously with the water surrounding the rudder stock at the stern of the ship.

The leakage of oil will be continuous over the day, so if the maximum allowable release of one

pint daily (.125 gallons) were divided by 1440 minutes per day, the discharge rate would be 8.68

x 10-5 gallons per minute. It is assumed that local currents will displace 5 cubic feet of water

(37.4 gallons) from the area around the rudder stock at least once per minute. Calculating the

concentration of oil within the volume displaced during one minute yields a local concentration

of about 2.1 mg/L.

4.2.2 Grease

Because grease-lubricated stave bearings are installed in several vessel classes, a vessel

width of 80 feet and a draft of 25 feet were assumed in the calculations. Following calculations
Rudder Bearing Lubrication

8

similar to the ones in Section 4.2.1, the total volume of water swept would be 255 million cubic

feet or 7 billion liters. As calculated in Section 4.1, a maximum of 0.0024 pounds (or 1.1 grams)

of grease is released during each trip. This translates into a concentration of 1.6 x 10-10 mg/L.

Based on the environmental concentrations estimated in Sections 4.2.1 and 4.2.2 above, a

high estimate of the oil and grease concentration in the surrounding water would be 1.3 x 10-4

mg/L at sea, and 2.1 mg/L in port. These concentrations do not exceed federal discharge

standards or the most stringent state water quality criteria, as shown in Table 5.

4.3 Potential for Introducing Non-Indigenous Species

There is no potential for the transport of non-indigenous species since seawater is not

taken aboard or discharged.

5.0 CONCLUSIONS

The rudder bearing lubrication discharge has a low potential for causing an adverse

environmental effect because the concentrations of oil and grease in the environment from rudder

bearing lubrication while the ship is within the 12 n.m. zone are below relevant federal discharge

standards and state water quality criteria.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources were obtained. Process

information and assumptions were used to estimate the rate of discharge. Based on this estimate

and on the reported concentrations of oil and grease components, the concentrations of oil and

grease in the environment resulting from this discharge were then estimated. Table 6 lists the

data sources used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes. Rudder Bearing Lubrication Leakage.

September 26, 1996.

2. UNDS Round 2 Equipment Expert Meeting Minutes. Rudder Bearing Lubrication

Leakage. March 6, 1997.

3. Personal communication between Penny Weersing (MSC) and David Eaton (MR&S) concerning

Action Item RT1. April 16, 1997.

4. Personal communication between Rich Machinsky (MSC) and Dick Soule (MR&S).

April 9, 1998.
Rudder Bearing Lubrication

9

5. Personal communication between LT Joyce Aivalotis (USCG) and David Eaton (MR&S).

May 2, 1997.

6. Report of April 1997 Trip to USCG, Baltimore to Research Rudder Bearings on USCG

Small Boats and Craft. January 13, 1998.

7. Patty’s Industrial Hygiene & Toxicology, 3rd Ed., Volume 2B. 1981. John Wiley &

Sons, New York, pp 3369, 3397.

8. Pentagon Ship Movement Data for Years 1991-1995. March 4, 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.
Rudder Bearing Lubrication

10

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Rudder Bearing Lubrication

11

Figure 1. Rudder Grease-Lubricated Roller Bearings Generic Sketch
Rudder Bearing Lubrication

12

Figure 2. Rudder Oil-Lubricated Roller Bearings Generic Sketch
Rudder Bearing Lubrication

13

Figure 3. Rudder Stave Bearings (Example)
Rudder Bearing Lubrication

14

Table 1. Navy Ships - Lower Rudder Bearing Type and Lubrication Method

Ship Class

Lower Rudder Bearing & 

Type of Lubrication # in Class

AGF 3 Stave Brg., Grease 1

AGF 11 Stave Brg., Grease 1

AO 177 Roller Brg., Grease 13

AOE 1 Roller Brg., Oil/Grease 2/2

AOE 6 Stave Brg., Grease 3

ARS 50 Stave Brg., Grease 4

AS 36/39 Roller Brg., Oil 3

ATS 1 Stave Brg., Grease 3

CG 47 Roller Brg., Grease 27

CGN 36 Stave Brg., Water 2

CGN 40 Stave Brg., Water 1

CV 62 Stave Brg., Water 1

CV 63 Stave Brg., Water 2

CV 67 Stave Brg., Water 1

CVN 65 Stave Brg., Water 1

CVN 68 Stave Brg., Water 7

DD 963 Roller Brg., Grease 31

DDG 51 Roller Brg., Grease 18

DD 993 Roller Brg., Grease 4

FFG 7 Roller Brg., Grease 43

LCC 19 Stave Brg., Grease 2

LHA 1 Roller Brg., Grease 5

LHD 1 Roller Brg., Grease 4

LPD 4 Stave Brg., Grease 9

LPH 2 Stave Brg., Grease 2

LSD 36 Stave Brg., Grease 5

LSD 41 Stave Brg., Grease 11

MCM 1 Stave Brg., Grease 14

MCS 12 Stave Brg., Grease 1

223
Rudder Bearing Lubrication

15

Table 2. U.S. Coast Guard Cutters, Types of Bearing, and Lubrication

Cutter Class No. in Class Type of Bearing Lubrication

399 WAGB 2 Laminated Phenolic Staves Grease

378 WHEC 12 Micarta Bushing Flax Packing/Grease

270 WMEC 13 Bushings Grease/Water

210 WMEC 16 Micarta Bushing Grease

140 WTGB 9 Staves Water

Note: There is no information available on the following classes:

225 WLB New production

175 WLM New production

180 WLB Decommissioned by 2001

157 WLM Decommissioned by 2000

133 WLM Decommissioned by 2000

160 WLIC No information
Rudder Bearing Lubrication

16

Table 3. U.S. Coast Guard Small Boats and Craft

(Types of Bearings and Lubrication)

Vessel/Craft Type Upper Rudder 

Bearing

Method of 

Lubrication

Lower Rudder 

Bearing

Method of 

Lubrication

26' MSB motor surfboat Thordon SXL 

bushing self Thordon SXL bushing water

32' PWB ports & waterways boat Delrin or nylon 

bushing self Delrin or nylon bushing water

44' MLB(S) motor lifeboat (steel) Micarta 

bushing self Micarta bushing water

47' MLB motor lifeboat Thordon SXL self Thordon SXL 

bushing water

52' MLB(S) motor lifeboat (steel) ball bearing grease Micarta bushing water

55' ANB aid to navigation boat metal bushing grease metal bushing grease

65' WLR river buoy tender spherical roller 

bearing grease

Goodrich 

cutless bearing water

65' WYTL tug boat (steel) roller bearing grease Micarta bushing water

75' WLIC inland construction tender spherical roller 

bearing grease bronze bushing grease

75' WLR river buoy tender spherical roller 

bearing grease

Thordon XL 

bushing water

82' WPB patrol boat spherical roller 

bearing grease Micarta bushing water

110' WPB patrol boat spherical roller 

bearing grease bushing water
Rudder Bearing Lubrication

17

Table 4. Military Sealift Command Ships

(Type of Rudder Bearings and Lubrication)

SHIP CLASS/NAME APL BEARING TYPE/LUBRICATION ALLOWABLE SEAL LEAKAGE

WATER OR OIL

REMARKS

UPPER & LOWER

RUDDER STOCK

PINTLE

BEARING

T-AE 26/ USNS KILAUEA 319010122 ROLLER BEARING/

OIL

STAVE/

WATER

1 PINT/DAY IN PORT/ANCHOR.

1 GALLON/DAY UNDERWAY

RUDDER POST HAS NEW

JOHN CRANE SPLIT SEAL

INSTALLED DURING YARD

PERIOD

T-AFS 1/ USNS MARS 319010106 ROLLER

BEARING/OIL

T-AG 194/

 USNS VANGUARD

NO DATA AVAILABLE

T-AGM 22/

USNS RANGE SENTINEL

NO DATA AVAILABLE

T-AGOS 21/ USNS

EFFECTIVE

AEROSHELL

GREASE 6SG6127

70026

1 PINT/DAY IN PORT/ANCHOR.

1 QUART/DAY FOR ALL

OPERATING CONDITIONS

T-AGS 45/ USNS

WATERS

M319010192 ROLLER/GREASE STAVE/

WATER

1 PINT/DAY IN PORT /ANCHOR.

1 GAL./DAY FOR ALL

OPERATING CONDITIONS.

T-AGS 60/ USNS

PATHFINDER

N.A N.A N.A N.A. THIS CLASS HAS “ZEE”

DRIVES . THERE ARE NO

RUDDERS.

T-AH 19/ USNS MERCY NO DATA AVAILABLE

T-AO 187/

 USNS HENRY J.

KAISER

ROLLER/GREASE 1 PINT/DAY IN PORT/ANCHOR. 1

QUART/DAY FOR ALL

OPERATING CONDITIONS

T-ARC 7/

 USNS ZEUS

NO DATA AVAILABLE

T-ATF 166/

USNS POWHATAN

NO DATA AVAILABLE

The blank spaces in the table indicate that information is not available.
Rudder Bearing Lubrication

18

Table 5. Comparison of Environmental Concentration with Relevant Water Quality

Criteria (mg/L)

Constituent Concentration Federal Discharge

Standard

Most Stringent State Water

Quality Criteria

oil and grease 1.3 x 10-4 (at sea)

 2.1 (in port)

visible sheena/15b

5.0 (FL)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

a Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen

on receiving waters.

b International Convention for the Prevention of Pollution from Ships (MARPOL 73/78) as implemented by the

Act to Prevent Pollution from Ships (APPS)

Table 6. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents X X

3.4 Concentrations X X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous Species

X X
Seawater Cooling Overboard Discharge

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Seawater Cooling Overboard Discharge
Seawater Cooling Overboard Discharge

2

2.0 DISCHARGE DESCRIPTION

This section describes discharges from seawater cooling systems and includes

information on: the equipment that is used and its operation (Section 2.1), general description of

the constituents of the discharge (Section 2.2), and the vessels that produce this discharge

(Section 2.3).

2.1 Equipment Description and Operation

Seawater cooling systems on surface ships and submarines provide cooling water for heat

exchangers, removing heat from the propulsion plant and mechanical auxiliary systems. Heat

exchangers are provided for steam, diesel, and gas turbine propulsion plants and electric

generating plants; air-conditioning (A/C) plants; air compressors; and electronic equipment.

Seawater is provided to steam propulsion plants for the purpose of condensing exhausted steam

from propulsion or electric generator turbines before the condensate is cycled back to boilers or

steam generators.

Seawater cooling systems draw seawater either directly from hull connections (sea

chests), or indirectly from the firemain that is supplied directly from a hull connection. The

seawater is pumped through heat exchangers where it absorbs heat and is then discharged

overboard at a higher temperature. At sea, the demands for seawater cooling are higher than

pierside or at anchor because systems requiring seawater cooling tend to be in use and at a higher

power output level while underway. Even while pierside, however, the demands for cooling of

auxiliary systems may be significant. Conventional steam vessels were estimated to have a 24-

hour start-up and securing cycle and nuclear vessels a 48-hour start-up and securing cycle.1

Typically, the demand for cooling water is continuous. The residence time of seawater in

seawater cooling systems is relatively short, perhaps a minute or two for most portions of the

cooling system. Some branch piping, however, may have relatively long residence times due to

inactivity of equipment.2

Seawater cooling systems are designed to minimize flow-induced erosion of the piping

system. The piping systems, where possible, have geometry (e.g., increase turn or elbow radii) or

sizing to minimize turbulent flow. The materials of construction (e.g., copper, nickel, and

titanium) are selected because of their resistance to seawater corrosion. Sea chests, heat

exchangers, and other components could also contain sacrificial material such as waster pieces or

zinc anodes to protect the system from corrosion.

Many boats and craft such as utility landing craft and rigid inflatable boats use keel

coolers or stern flushing tubes.1 Keel coolers use ship’s motion to pass water over exposed heat

transfer coils in a recessed area of the boat keel. Stern flushing tubes are simple cooling systems

in which engine cooling water is drawn from a hull connection and is discharged from the

vessel’s stern, normally above the water line.
Seawater Cooling Overboard Discharge

3

Sea chests and hull connections are equipped with sea strainer plates to prevent debris

from entering the seawater cooling system (especially when in port or in coastal waters) and

causing failures due to clogging.3 The openings in these strainer plates vary in diameter from 1/4

inch to 1-1/2 inches and require periodic blowdowns to prevent clogging. This is accomplished

by blowing low-pressure air or steam out through the plates.3

Some vessels add biofouling prevention chemicals to the seawater.1,4 The contribution of

anti-fouling additives to seawater cooling overboard discharge is addressed in the Seawater

Piping Biofouling Prevention NOD report and will not be considered in this report.

In addition to seawater cooling while pierside, Navy vessels with non-conventional steam

propulsion also fill their main steam condenser heat exchangers with fresh water if the vessel is

going to be in port for an extended period. When vessels are in port for an extended period of

time, they often deactivate their propulsion plants. During these periods, the main condenser is

filled with fresh water because fresh water inhibits biofouling.1 Freshwater layups for nonconventional main steam condenser heat exchangers are discussed in the Freshwater Layup NOD

report.

2.2 Releases to the Environment

The releases to the environment consist of the seawater discharged overboard from the

seawater cooling system with entrained or dissolved materials from the components of the

seawater cooling system and bottom sediments that are brought onboard through the sea chest.

The components of the seawater cooling system include: the sea chest, pumps, heat exchangers,

pipes, fittings, and valves. The sea chests are constructed of steel and are painted with high

durable epoxy paints, and they also contain steel or zinc sacrificial material.1 The pumps are

constructed of titanium, stainless steel, nickel alloys, bronze, and non-metallic composites.1 Heat

exchangers are copper-nickel alloys or titanium.1 The pipes and fittings in seawater systems are

primarily copper-nickel alloys, but fittings may also be bronze with silver-brazed joints.1 Valves

are constructed of bronze, nickel alloys, or aluminum alloys.1 Some traces of hydraulic oil or

other lubricants may enter the seawater from remotely operated valves or pumps. The metals that

may enter the seawater include copper, nickel, lead, aluminum, tin, silver, iron, titanium,

chromium, and zinc.

In addition, the discharge constitutes a thermal load. The maximum discharge

temperature is 140 degrees Fahrenheit (°F) to prevent formation of soft scale (calcium carbonate)

inside the pipes and heat exchangers.1 The difference in temperature from influent to effluent is

usually between 10 °F to 15 °F, but the range can be as much as 5 °F to 25 °F.5

Sea strainer plate blowdown consists of air or steam, and any solids blown off the strainer

plate. Air bubbles rise to the surface and dissipate, while the solids fall to the bottom. Solids can

include anything that has been held against the plate by the cooling water suction (e.g., debris and

mud) plus biota that has grown on the plate over time (e.g., sea grass and slime).

2.3 Vessels Producing the Discharge
Seawater Cooling Overboard Discharge

4

Ships, boats, and craft in the Navy, Military Sealift Command (MSC), U.S. Coast Guard

(USCG), Army, and Air Force with the exception of some non-self propelled service craft such

as barges, use seawater for cooling. Of the over 6,000 ships, boats, and craft in the Armed

Forces, the vast majority of these vessels (over 5,000) consists of boats and craft. The majority

of the seawater cooling overboard discharge, however, is generated by larger ships and vessels

that have large, continuous seawater cooling demands. There are 673 such surface ships and

submarines. The boats and craft in service use either intermittent cooling water or have keel

coolers where there is no flow through the vessel. Table 1 lists the vessels that contribute to this

discharge and the estimates for the number of transits, number of days in port, and number of

days operating within 12 nautical miles (n.m.) by each ship class each year.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

This discharge occurs both within and beyond 12 n.m. of shore.

3.2 Rate

Seawater cooling flow rates can vary from several gallons per minute (gpm) for smaller,

diesel-powered ships to flows of greater than 170,000 gpm for aircraft carriers during full-power

steaming. While transiting, vessels tend to operate at levels sufficient to maintain steering

control and do not require the maximum amount of seawater cooling. While anchored or

pierside, seawater cooling flow rates are at their lowest because only certain auxiliary equipment

is required. Table 2 lists examples of typical pierside and transit steaming flow rates for vessel

classes.6

Tables 3a, 3b, and 3c provide estimates of discharge flow rates for various ship classes

within 12 n.m. of shore based on available data. The number of transits were used to estimate

the number of light-off and securing cycles for steam-powered vessels. The calculations use a

typical transit time of 4 hours between 0 to 12 n.m.7 For USCG vessels, operation within 12 n.m.

of shore includes seawater cooling flow rates at pierside rates for 16 hours each day with the

remaining 8 hours at typical underway flow rates. An example for the estimated annual flow of

the WAGB 399 Class for operation within 12 n.m. of shore is calculated by the equation:
Seawater Cooling Overboard Discharge

5

Based on these estimates, the total annual flow of seawater cooling overboard discharge

from Navy, MSC, Army, and USCG vessels is estimated as 390 billion gallons. Flow rates for

Air Force vessels are not estimated.

3.3 Constituents

Seawater cooling overboard discharge is primarily seawater that contains trace materials

from seawater cooling system pipes, fittings, valves, seachests, pumps, and heat exchangers. The

expected constituents of seawater cooling discharge include copper, iron, aluminum, zinc, nickel,

tin, titanium, arsenic, manganese, chromium, lead, and possibly oil and grease from valves and

pumps. Of the constituents expected to be present in this discharge, arsenic, chromium, copper,

lead, nickel, and zinc are priority pollutants. None of the expected constituents is a

bioaccumulator.

The constituents from strainer plate blowdown include the material ejected from the

strainer plate, such as biota, mud, or debris, trapped from the sea or harbor waters.

3.4 Concentrations

Influent and effluent samples were collected from the seawater cooling systems of five

ships.8 A summary of the analytical results are presented in Table 4. This table shows the

constituents, the log-normal mean, the frequency of detection for each constituent, the minimum

and maximum concentrations, and the mass loadings of each constituent. For the purposes of

calculating the log-normal mean, a value of one-half the detection limit was used for nondetected results.

The analytical data for a Coast Guard vessel were not used to calculate the log-normal

mean concentrations in Table 4 because the data indicated a large average net decrease in effluent

concentrations for total copper, nickel, tin, and zinc. For example, data for this vessel varied

widely for total copper with an average influent concentration of 1,450 μg/L and an average

effluent concentration of 419 μg/L, a net decrease of 1,031 μg/L. These concentrations are one to

two orders of magnitude higher than data from the other ships. The Coast Guard vessel data

were considered an anomaly and were excluded from log-normal mean concentration

calculations to avoid biasing the data with large, negative net concentrations.

Variability is expected within this discharge as a result of several factors including

material erosion and corrosion, residence times, passive films, and influent water variability.

Pipe erosion is caused by high fluid velocity, or by abrasive particles entrained in the seawater

Estimated Annual Flows (gal), Operating Within 12 n.m.

= (Qty)(Operating Time)(60) [(16/24)(Pierside Flow) + (8/24)(Operating Flow)]

WAGB 399 Annual Flow (gal), Operating Within 12 n.m.

= (2)(2400 hrs)(60 min/hr) [(16/24)(800 gal/min) + (8/24)(4000)]

= 537,600,000 gal
Seawater Cooling Overboard Discharge

6

flowing at any velocity. In most cases of pipe erosion, the problematic high fluid velocity is a

local phenomenon, such as would be caused by eddy turbulence at joints, bends, reducers,

attached mollusks, or tortuous flow paths in valves. Passive films inhibit metal loss due to

erosion. Corrosion is influenced by the residence time of seawater in the system, temperature,

biofouling, constituents in the influent, and the presence or absence of certain films on the pipe

surface. All of these influences on metallic concentrations are variable within a given ship over

time, and between ships.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria.

Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

Based on the discharge volume estimates developed in Tables 3a, 3b and 3c and the lognormal mean discharge concentrations and mass loadings are presented in Table 4. Table 5 is

present in order to highlight constituents with log-normal mean concentrations that exceed water

quality criteria (WQC). A sample calculation of the estimated annual mass loading for copper is

shown here:

Mass Loading for Copper (Total)

Mass Loading = (Net Positive Log-normal Mean Concentration)(Flow Rate)

(34.49 μg/L)(3.785 L/gal)(390,000,000,000 gal/yr)(2.202 lbs/kg)(10-9 kg/μg) ≅ 112,100 lbs/yr

4.2 Environmental Concentrations

The log-normal mean discharge concentrations are compared to the Federal and most

stringent state WQC in Table 6. Copper exceeds the Federal and most stringent state WQC.

This can be attributed to two factors: 1) the copper concentrations of many harbors exceed the

standard, and 2) other copper sources (e.g. copper hull coatings) of the vessel are located near the

influent sea chest. Between 1 and 90 μg/L of copper naturally occurs in seawater.9 Nickel and

silver concentrations also exceed the Federal and most stringent state WQC. Nitrogen (as

ammonia, nitrate/nitrite, and total kjeldahl nitrogen) exceeds the most stringent state WQC.

4.3 Thermal Effects

The potential for seawater cooling overboard discharge to cause thermal environmental

effects was evaluated by modeling the thermal plume generated under conditions tending to

produce the greatest temperature rise and then compared to state plume thermal discharge
Seawater Cooling Overboard Discharge

7

requirements. Thermal effects of seawater cooling water overboard discharge were modeled

using the Cornell Mixing Zone Expert System (CORMIX) to estimate the plume size and

temperature gradients in the receiving water body. Thermal modeling was performed for three

ships in three harbors (Mayport, FL; Norfolk, VA; and Bremerton, WA) to assess the potential

thermal impact. The discharge was also assumed to occur during winter when the ambient water

temperatures are lowest. Based on these models, Navy aircraft carriers are predicted to generate

thermal plumes that, under conditions of low harbor flushing, low wind velocities, and maximum

cooling water flow rates, would exceed the regulatory limits of Washington.5 Thermal plumes

from models of smaller ships (destroyers) do not exceed regulatory limits.5 Of the five states

having a substantial presence of Armed Forces’ vessels, only Virginia and Washington have

established thermal mixing zone dimensions.

4.4 Potential for Introducing Non-Indigenous Species

The seawater cooling water system has a minimal potential for transporting nonindigenous species, because the residence times for most portions of the system are short. Some

portions of the seawater system lie stagnant where marine organisms may reside. However, these

areas tend to develop anaerobic conditions quickly, except at the junctions with the active

portions of the system, where oxygenated water continuously flows by and through the ship. The

seawater is not a system where large volumes of water, under aerobic conditions, are transported

over distances.

A small potential exists for transport of non-indigenous species because the blowdown

procedure for the strainer plates may dislodge biota that has grown on the plate over time.

5.0 CONCLUSION

Seawater cooling overboard discharge has a potential to cause an adverse environmental

effect because:

1) Nitrogen, copper, nickel, and silver concentrations in the discharge exceed Federal

and the most stringent state water quality criteria, and the mass loadings of nitrogen,

copper, nickel, and silver are significant; and

2) Some vessels could exceed some states’ thermal mixing zone requirements while in

port.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. System

engineering information was used to estimate the rate of discharge. Table 7 shows the sources of

data used to develop this NOD report.
Seawater Cooling Overboard Discharge

8

Specific References

1. UNDS Equipment Expert Meeting Minutes. Seawater Cooling Water Overboard . 27

August 1996.

2. Worris, Matthew, M. Rosenblatt & Son, Inc. Seawater Cooling Residence Times,

Pierside and Underway, 16 October 1996, Clarkson Meredith, Versar, Inc.

3. Tsao, Fred, NAVSEA 03L32. Sea Strainer Blowdown, 21 December 1996, Clarkson

Meredith, Versar, Inc.

4. Weersing, Penny, Military Sealift Command Point Paper: Supplemental Information

About Wastestreams from Seawater Cooling Systems.

5. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed

Services. Versar, Inc. July 3, 1997.

6. Worris, Matthew, M. Rosenblatt & Son, Inc. Seawater Cooling Flow Rates, Pierside and

Underway, 30 September 1996, Clarkson Meredith, Versar, Inc.

7. Pentagon Ship Movement Data for Years 1991 - 1995, 4 March 1997.

8. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

9. Van der Leeden, et al. The Water Encyclopedia, Second Edition. Lewis Publishers,

1990.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.
Seawater Cooling Overboard Discharge

9

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. 23 March 1995.

UNDS Ship Database, August 1, 1997.
Seawater Cooling Overboard Discharge

10

Table 1. Typical Ship Movement Data

Vessel Class Quantity Number of

Transits/Vessel/Year

Hours per

Transit

Days in

Port/Vessel/Year

Days Operating

within 12 n.m.

Surface Ships, Submarines

Forrestal Class Aircraft Carriers CV 59 1 6 4 143 0

Kitty Hawk Class Aircraft Carriers CV 63 3 7 4 137 0

Enterprise Class Aircraft Carriers CVN 65 1 6 4 76 0

Nimitz Class Aircraft Carriers CVN 68 7 7 4 147 0

Ticonderoga Class Guided Missile Cruisers CG 47 27 12 4 166 0

California Class Guided Missile Cruisers CGN 36 2 11 4 143 0

Virginia Class Guided Missile Cruisers CGN 38 1 11 4 161 0

Spruance Class Destroyers DD 963 31 12 4 178 0

Arleigh Burke Destroyers DDG 51 18 11 4 101 0

Kidd Class Destroyers DDG 993 4 12 4 175 0

Oliver Hazard Perry Guided Missile Frigates FFG 7 43 13 4 167 0

Submarines, SSN, SSBN, All Classes 89 6 4 183 0

Blue Ridge Class Amphibious Command Ships LCC 19 2 8 4 179 0

Wasp Class Amphibious Assault Ships LHD 1 4 13 4 185 0

Tarawa Class Amphibious Assault Ships LHA 1 5 9 4 173 0

Iwo Jima Class Amphibious Assault Ships LPH 2 2 11 4 186 0

Austin Class Amphibious Transport Docks LPD 4 3 11 4 178 0

Amphibious Transport Docks LPD 7 3 12 4 188 0

Amphibious Transport Docks LPD 14 2 11 4 192 0

Anchorage Class Dock Landing Ships LSD 36 5 13 4 215 0

Whidbey Island Class Dock Landing Ships LSD 41 8 13 4 170 0

Harpers Ferry Class Dock Landing Ships LSD 49 3 13 4 215 0

Avenger Class Mine Countermeasures Vessels MCM 1 14 28 4 232 0

Osprey Class Coastal Minehunters MHC 51 12 28 4 232 0

Cyclone Class Coastal Defense Ships PC 1 13 18 4 105 0

Auxiliaries

Emory S Land Class Submarine Tenders AS 39 3 6 4 293 0

Simon Lake Class Submarine Tender AS 33 1 6 4 229 0

Command Ships AGF 2 12 4 183 0

Jumboised Cimarron Class Oilers AO 177 5 10 4 188 0

Sacramento Class Fast Combat Support Ships AOE 1 4 11 4 183 0
Seawater Cooling Overboard Discharge

11

Supply Class Fast Combat Support Ships AOE 6 3 6 4 114 0

Safeguard Class Salvage Ships ARS 50 4 22 4 208 0

Gyre Class Oceanographic Research Ships AGOR 21 1 11 4 113 0

T.G.Thompson Oceanographic Research Ships AGOR 23 2 11 4 113 0

Military Sealift Command

Kilauea Class Ammunition Ships AE 26 8 4 4 26 0

Mars Class Combat Stores Ships AFS 1 8 7 4 148 0

Missile Range Instrumentation Ships AGM 22 1 4 4 133 0

Mercy Class Hospital Ships AH 19 2 2 4 184 0

Zeus Class Cable Repairing Ships ARC 7 1 2 4 8 0

Mission Class Navigation Research Ships AG 194 2 10 4 151 0

Stalwart Class Ocean Surveillance Ships AGOS 1 5 4 4 70 0

Victorious Class Ocean Surveillance Ships AGOS 19 4 5 4 107 0

Silas Bent & Wilkes Classes Surveying Ships AGS 26 2 6 4 44 0

Waters Class Surveying Ship AGS 45 1 1 4 7 0

John McDonnell Class Surveying Ships AGS 51 2 6 4 96 0

Pathfinder Class Surveying Ships AGS 60 4 6 4 96 0

Algol Class Vehicle Cargo Ships AKR 287 8 3 4 109 0

Maersk Class Fast Sealift Ships AKR 295 3 9 4 59 0

Henry J. Kaiser Class Oilers AO 187 13 6 4 78 0

Potawan Class Fleet Ocean Tugs ATF 166 7 16 4 127 0

US Coast Guard

High Endurance Cutters WHEC 378 12 13 4 151 0

Medium Endurance Cutters WMEC 213 1 9 4 98 0

Medium Endurance Cutter, WMEC 230 1 11 4 167 0

Medium Endurance Cutters WMEC 210A 5 13 4 235 0

Medium Endurance Cutters WMEC 210B 11 9 4 149 0

Medium Endurance Cutters WMEC 270A 4 6 4 137 0

Medium Endurance Cutters WMEC 270B 9 7 4 164 0

Mackinaw Class Icebreaker WAGB 290 1 4 4 215 146

Polar Class Icebreakers WAGB 399 2 4 4 148 100

Island Class Patrol Craft WPB 110 ( A,B & C ) 49

Point Class Patrol Craft WPB 82 ( C & D ) 36

Juniper Class Buoy Tenders WLB 225 2 18 4 190 100

Balsam Class Buoy Tenders WLB 180A 8 18 4 190 100

Balsam Class Buoy Tenders WLB 180B 2 5 4 120 200

Balsam Class Buoy Tenders WLB 180C 13 16 4 123 200
Seawater Cooling Overboard Discharge

12

Bay Class Icebreaking Tugs WTGB 140 9 1 4 215 146

Inland Buoy Tender WLI 100A 1 0 0 160 201

Inland Buoy Tender WLI 100C 1 0 0 160 201

Inland Buoy Tenders WLI 65303 2 0 0 160 201

Inland Buoy Tenders WLI 65400 2 0 0 160 201

Cosmos Class Inland Construction Tenders WLIC 100 3 0 0 160 201

Anvil Class Inland Construction Tenders WLIC 75A 2 0 0 160 201

Inland Construction Tenders WLIC 75B 3 0 0 160 201

Clamp Class Inland Construction Tenders WLIC 75D 2 0 0 160 201

River Buoy Tender WLR 115 1 0 0 160 201

River Buoy Tenders WLR 75 13 0 0 160 201

River Buoy Tenders WLR 65 6 0 0 160 201

Pamlico Class Inland Construction Tenders WLIC 160 4 0 0 160 201

White Sumac Class Coastal Buoy Tenders WLM 157 9 16 4 123 100

Keeper Class Coastal Buoy Tenders WLM 551 2 16 4 123 200

65 ft. Harbor Tugs WYTL ( A, B, C & D ) 11

Army

Logistics Support Vessel LSV 6 20 4 150 30

Landing Craft Utility LCU-2000 35 3 4 275 60

Large Tug LT-128 6 5 4 245 60

Total 673
Seawater Cooling Overboard Discharge

13

Table 2. Seawater Cooling Flow Rates, Examples (Naval Vessels)

Vessel Class Pierside (gpm) In Transit (gpm)

Aircraft carriers (CVN 68) 4,100 >170,000

Cruisers (CG 47) 1,650 7,000

Destroyers (DDG 51) 1,500 6,840

Frigates (FFG 7) 1,750 3,000

Amphibious assault ships (LHD 1) 3,000 up to 40,500

Submarines 2,000 10,000 - 12,000
Seawater Cooling Overboard Discharge

14

Table 3a. Estimated Annual Flows, Seawater Cooling Water, Navy and MSC

Estimated Flow Rates (gpm) Estimated Times within 12 n.m. (hrs) Estimated Annual Flows (gal)

Qty Pierside Start-up/

Securing

In Transit Pierside Start-up/

Securing

In Transit Pierside Start-up/

Securing

In Transit

Surface Ships, Submarines

Forrestal Class Aircraft Carriers CV 59 1 4,100 170,000 170,000 3,432 288 48 844,272,000 2,937,600,000 489,600,000

Kitty Hawk Class Aircraft Carriers CV 63 3 4,100 170,000 170,000 3,288 336 56 2,426,544,000 10,281,600,000 1,713,600,000

Enterprise Class Aircraft Carriers CVN 65 1 4,100 170,000 170,000 1,824 576 48 448,704,000 5,875,200,000 489,600,000

Nimitz Class Aircraft Carriers CVN 68 7 4,100 170,000 170,000 3,528 672 56 6,075,216,000 47,980,800,000 3,998,400,000

Ticonderoga Class Guided Missile Cruisers CG 47 27 1,650 0 7,000 3,984 0 96 10,649,232,000 0 1,088,640,000

California Class Guided Missile Cruisers CGN 36 2 1,650 7,000 7,000 3,432 1,056 88 679,536,000 887,040,000 73,920,000

Virginia Class Guided Missile Cruisers CGN 38 1 1,650 7,000 7,000 3,864 1,056 88 382,536,000 443,520,000 36,960,000

Spruance Class Destroyers DD 963 31 1,500 0 6,840 4,272 0 96 11,918,880,000 0 1,221,350,400

Arleigh Burke Destroyers DDG 51 18 1,680 0 6,840 2,424 0 88 4,398,105,600 0 650,073,600

Kidd Class Destroyers DDG 993 4 1,500 0 6,840 4,200 0 96 1,512,000,000 0 157,593,600

Oliver Hazard Perry Guided Missile Frigates FFG 7 43 1,750 0 3,000 4,008 0 104 18,096,120,000 0 804,960,000

Submarines, SSN, SSBN, All Classes 89 2,000 11,000 11,000 4,392 576 48 46,906,560,000 33,834,240,000 2,819,520,000

Blue Ridge Class Amphibious Command Ships LCC 19 2 3,000 * 40,500 40,500 * 4,296 384 64 1,546,560,000 1,866,240,000 311,040,000

Wasp Class Amphibious Assault Ships LHD 1 4 3,000 40,500 40,500 4,440 624 104 3,196,800,000 6,065,280,000 1,010,880,000

Tarawa Class Amphibious Assault Ships LHA 1 5 3,000 * 40,500 40,500 * 4,152 432 72 3,736,800,000 5,248,800,000 874,800,000

Iwo Jima Class Amphibious Assault Ships LPH 2 2 3,000 * 40,500 40,500 * 4,464 528 88 1,607,040,000 2,566,080,000 427,680,000

Austin Class Amphibious Transport Docks LPD 4 3 3,000 * 40,500 40,500 * 4,272 528 88 2,306,880,000 3,849,120,000 641,520,000

Amphibious Transport Docks LPD 7 3 3,000 * 40,500 40,500 * 4,512 576 96 2,436,480,000 4,199,040,000 699,840,000

Amphibious Transport Docks LPD 14 2 3,000 * 40,500 40,500 * 4,608 528 88 1,658,880,000 2,566,080,000 427,680,000

Anchorage Class Dock Landing Ships LSD 36 5 3,000 * 40,500 40,500 * 5,160 624 104 4,644,000,000 7,581,600,000 1,263,600,000

Whidbey Island Class Dock Landing Ships LSD 41 8 3,000 * 0 40,500 * 4,080 0 104 5,875,200,000 0 2,021,760,000

Harpers Ferry Class Dock Landing Ships LSD 49 3 3,000 * 0 40,500 * 5,160 0 104 2,786,400,000 0 758,160,000

Avenger Class Mine Countermeasures Vessels MCM 1 14 1,650 * 0 7,000 * 5,568 0 224 7,717,248,000 0 1,317,120,000

Osprey Class Coastal Minehunters MHC 51 12 1,500 * 0 6,840 * 5,568 0 224 6,013,440,000 0 1,103,155,200

Cyclone Class Coastal Defense Ships PC 1 13 200 * 0 1,500 * 2,520 0 144 393,120,000 0 168,480,000

Auxiliaries

Emory S Land Class Submarine Tenders AS 39 3 2,000 * 40,500 40,500 * 7,032 288 48 2,531,520,000 2,099,520,000 349,920,000

Simon Lake Class Submarine Tender AS 33 1 2,000 * 40,500 40,500 * 5,496 288 48 659,520,000 699,840,000 116,640,000

Command Ships AGF 2 2,000 * 40,500 40,500 * 4,392 576 96 1,054,080,000 2,799,360,000 466,560,000

Jumboised Cimarron Class Oilers AO 177 5 2,000 * 40,500 40,500 * 4,512 480 80 2,707,200,000 5,832,000,000 972,000,000

Sacramento Class Fast Combat Support Ships AOE 1 4 1,650 * 7,500 7,500 * 4,392 528 88 1,739,232,000 950,400,000 158,400,000

Supply Class Fast Combat Support Ships AOE 6 3 1,650 * 0 7,500 * 2,736 0 48 812,592,000 0 64,800,000

Safeguard Class Salvage Ships ARS 50 4 1,500 * 0 6,840 * 4,992 0 176 1,797,120,000 0 288,921,600

Gyre Class Oceanographic Research Ships AGOR 21 1 1,500 * 0 6,840 * 2,712 0 88 244,080,000 0 36,115,200

T.G.Thompson Oceanographic Research Ships AGOR

23

2 1,500 * 0 6,840 * 2,712 0 88 488,160,000 0 72,230,400
Seawater Cooling Overboard Discharge

15

Military Sealift Command

Kilauea Class Ammunition Ships AE 26 8 2,000 * 40,500 40,500 * 624 192 32 599,040,000 3,732,480,000 622,080,000

Mars Class Combat Stores Ships AFS 1 8 2,000 * 40,500 40,500 * 3,552 336 56 3,409,920,000 6,531,840,000 1,088,640,000

Missile Range Instrumentation Ships AGM 22 1 2,000 * 40,500 40,500 * 3,192 192 32 383,040,000 466,560,000 77,760,000

Mercy Class Hospital Ships AH 19 2 2,000 * 40,500 40,500 * 4,416 96 16 1,059,840,000 466,560,000 77,760,000

Zeus Class Cable Repairing Ships ARC 7 1 2,000 * 0 40,500 * 192 0 16 23,040,000 0 38,880,000

Mission Class Navigation Research Ships AG 194 2 1,500 * 6,840 6,840 * 3,624 480 80 652,320,000 393,984,000 65,664,000

Stalwart Class Ocean Surveillance Ships AGOS 1 5 1,500 * 0 6,840 * 1,680 0 32 756,000,000 0 65,664,000

Victorious Class Ocean Surveillance Ships AGOS 19 4 1,500 * 0 6,840 * 2,568 0 40 924,480,000 0 65,664,000

Silas Bent & Wilkes Classes Surveying Ships AGS 26 2 1,500 * 0 6,840 * 1,056 0 48 190,080,000 0 39,398,400

Waters Class Surveying Ship AGS 45 1 1,500 * 0 6,840 * 168 0 8 15,120,000 0 3,283,200

John McDonnell Class Surveying Ships AGS 51 2 1,500 * 0 6,840 * 2,304 0 48 414,720,000 0 39,398,400

Pathfinder Class Surveying Ships AGS 60 4 1,500 * 6,840 6,840 * 2,304 288 48 829,440,000 472,780,800 78,796,800

Algol Class Vehicle Cargo Ships AKR 287 8 2,000 * 0 40,500 * 2,616 0 24 2,511,360,000 0 466,560,000

Maersk Class Fast Sealift Ships AKR 295 3 2,000 * 0 40,500 * 1,416 0 72 509,760,000 0 524,880,000

Henry J. Kaiser Class Oilers AO 187 13 2,000 * 0 40,500 * 1,872 0 48 2,920,320,000 0 1,516,320,000

Potawan Class Fleet Ocean Tugs ATF 166 7 1,650 * 0 7,500 * 3,048 0 128 2,112,264,000 0 403,200,000

-------- ----------------------- ----------------------- ---------------------

399 177,600,801,600 160,627,564,800 32,269,468,800

* - These flow rates are estimated based on the mission and the size ship in relation to ships whose flow rates are known. Seawater Cooling Total: 370,497,835,200
Seawater Cooling Overboard Discharge

16

Table 3b. Estimated Annual Flows, Seawater Cooling Water, USCG

Estimated Flow Rates (gpm) Estimated Times within 12 n.m. (hrs) Estimated Annual Flows (gal)

Qty Pierside

Operating 

within 12 n.m. In Transit Pierside Operating In Transit Pierside

Operating 

within 12 n.m. In Transit

US Coast Guard

High Endurance Cutters WHEC 378 12 1,200 * 6,000 6,000 * 3,624 0 104 3,131,136,000 0 449,280,000

Medium Endurance Cutters WMEC 213 1 800 * 4,000 4,000 * 2,352 0 72 112,896,000 0 17,280,000

Medium Endurance Cutter, WMEC 230 1 800 * 4,000 4,000 * 4,008 0 88 192,384,000 0 21,120,000

Medium Endurance Cutters WMEC 210A 5 800 * 4,000 4,000 * 5,640 0 104 1,353,600,000 0 124,800,000

Medium Endurance Cutters WMEC 210B 11 800 * 4,000 4,000 * 3,576 0 72 1,888,128,000 0 190,080,000

Medium Endurance Cutters WMEC 270A 4 800 * 4,000 4,000 * 3,288 0 48 631,296,000 0 46,080,000

Medium Endurance Cutters WMEC 270B 9 800 * 4,000 4,000 * 3,936 0 56 1,700,352,000 0 120,960,000

Mackinaw Class Icebreaker WAGB 290 1 1,000 * 5,000 5,000 * 5,160 3,504 32 309,600,000 490,560,000 9,600,000

Polar Class Icebreakers WAGB 399 2 800 * 4,000 4,000 * 3,552 2,400 32 340,992,000 537,600,000 15,360,000

Island Class Patrol Craft WPB 110 ( A,B & C ) 49

Point Class Patrol Craft WPB 82 ( C & D ) 36

Juniper Class Buoy Tenders WLB 225 2 800 * 4,000 4,000 * 4,560 2,400 144 437,760,000 537,600,000 69,120,000

Balsam Class Buoy Tenders WLB 180A 8 100 * 500 500 * 4,560 2,400 144 218,880,000 268,800,000 34,560,000

Balsam Class Buoy Tenders WLB 180B 2 100 * 500 500 * 2,880 4,800 40 34,560,000 134,400,000 2,400,000

Balsam Class Buoy Tenders WLB 180C 13 100 * 500 500 * 2,952 4,800 128 230,256,000 873,600,000 49,920,000

Bay Class Icebreaking Tugs WTGB 140 9 100 * 500 500 * 5,160 3,504 8 278,640,000 441,504,000 2,160,000

Inland Buoy Tender WLI 100A 1 50 * 50 50 * 3,840 4,824 0 11,520,000 14,472,000 0

Inland Buoy Tender WLI 100C 1 50 * 50 50 * 3,840 4,824 0 11,520,000 14,472,000 0

Inland Buoy Tenders WLI 65303 2 50 * 50 50 * 3,840 4,824 0 23,040,000 28,944,000 0

Inland Buoy Tenders WLI 65400 2 50 * 50 50 * 3,840 4,824 0 23,040,000 28,944,000 0

Cosmos Class Inland Construction Tenders WLIC 100 3 50 * 50 50 * 3,840 4,824 0 34,560,000 43,416,000 0

Anvil Class Inland Construction Tenders WLIC 75A 2 50 * 250 250 * 3,840 4,824 0 23,040,000 67,536,000 0

Inland Construction Tenders WLIC 75 3 50 * 50 50 * 3,840 4,824 0 34,560,000 43,416,000 0

Clamp Class Inland Construction Tenders WLIC 75D 2 50 * 50 50 * 3,840 4,824 0 23,040,000 28,944,000 0

River Buoy Tender WLR 115 1 50 * 50 50 * 3,840 4,824 0 11,520,000 14,472,000 0

River Buoy Tenders WLR 75 13 50 * 50 50 * 3,840 4,824 0 149,760,000 188,136,000 0

River Buoy Tenders WLR 65 6 50 * 50 50 * 3,840 4,824 0 69,120,000 86,832,000 0

Pamlico Class Inland Construction Tenders WLIC 160 4 100 * 50 50 * 3,840 4,824 0 92,160,000 96,480,000 0

White Sumac Class Coastal Buoy Tenders WLM 157 9 100 * 500 500 * 2,952 2,400 128 159,408,000 302,400,000 34,560,000

Keeper Class Coastal Buoy Tenders WLM 551 2 100 * 500 500 * 2,952 4,800 128 35,424,000 134,400,000 7,680,000

65 ft. Harbor Tugs WYTL ( A, B, C & D ) 11 50 * 250 250 * 3,840 4,824 0 126,720,000 371,448,000 0

--------- ---------------------------------------------------------------------

227 11,562,192,000 4,376,928,000 1,194,960,000

* - These flow rates are estimated based on the mission and the size ship in relation to ships whose flow rates are known. Seawater Cooling Total: 17,134,080,000
Seawater Cooling Overboard Discharge

17

Table 3c. Estimated Annual Flows, Seawater Cooling Water, Army

Estimated Flow Rates (gpm) Estimated Times within 12 n.m.

(hrs)

Estimated Annual Flows (gal)

Qty Pierside Operating

within 12 n.m.

In Transit Pierside Operating In Transit Pierside Operating

within 12 n.m.

In Transit

Army

Logistics Support Vessel LSV 6 110 110 110 2,400 320 160 95,040,000 12,672,000 6,336,000

Landing Craft Utility LCU-2000 35 140 140 140 4,400 936 24 1,293,600,000 275,184,000 7,056,000

Large Tug LT-128 6 100 * 100 100 * 3,920 920 40 141,120,000 33,120,000 1,440,000

----- ----------------- ----------------- -------------------

47 1,529,760,000 320,976,000 14,832,000

* - These flow rates are estimated based on the mission and the size ship in relation to ships whose flow

rates are known.

Seawater Cooling Total: 1,865,568,000
Seawater Cooling Overboard Discharge

18

Table 4. Summary of Detected Analytes

Constituent Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Log Normal

Mean

Frequency

of Detection

Minimum

Concentration

Maximum

Concentration

Effluent - Influent

Log Normal Mean

Mass Loading

Seawater Cooling Dedicated Influent Seawater Cooling Dedicated Effluent

Metals (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (lbs/yr)

Aluminum

 Dissolved 59.7 2 of 5 BDL 207.0 59.84 3 of 5 BDL 175 0.12 390

 Total 147.4 4 of 5 BDL 296.0 151.1 4 of 5 BDL 399.0 3.69 11,993

Arsenic

 Dissolved 1.97 2 of 5 BDL 12.60 2.26 1 of 5 BDL 18.50 0.29 943

 Total 1.48 1 of 5 BDL 11.30 4.24 3 of 5 BDL 56.60 2.76 8,970

Barium

 Dissolved 15.37 5 of 5 5.80 23.90 18.02 5 of 5 10.10 21.85 2.65 8,613

 Total 21.69 5 of 5 15.80 26.60 21.59 5 of 5 15.25 26.50 -0.10 (a)

Boron

 Dissolved 2090 5 of 5 1740 2340 2082 5 of 5 1705 2435 -8.17 (a)

 Total 2059 5 of 5 1710 2340 2027 5 of 5 1590 2360 -32.08 (a)

Calcium

 Dissolved 196248 5 of 5 164000 223000 197497 5 of 5 163000 229000 1248.60 4,058,145

 Total 195870 5 of 5 164000 220000 192465 5 of 5 155000 218500 -3405.42 (a)

Chromium

 Dissolved 5.47 1 of 5 BDL 10.70 ~ 0 of 5 BDL BDL ~ (b)

 Total ~ 0 of 5 BDL BDL 7.71 2 of 5 BDL 35.50 7.71 25,059

Copper

 Dissolved 9.86 3 of 5 BDL 18.80 40.55 5 of 5 11.90 1040.00 30.69 99,747

 Total 14.88 4 of 5 BDL 27.30 49.37 5 of 5 7.55 1135.00 34.49 112,098

Iron

 Dissolved 11.82 1 of 5 BDL 173.0 12.69 2 of 5 BDL 214 0.87 2,828

 Total 227.5 5 of 5 90.6 399.0 241.2 5 of 5 87.65 546.5 13.73 44,625

Lead

 Dissolved ~ 0 of 5 BDL BDL 4.12 1 of 5 BDL 3.40 4.12 13,391

 Total 4.19 1 of 5 BDL 2.40 ~ 0 of 5 BDL BDL ~ (b)

Magnesium

 Dissolved 617279 5 of 5 485000 741000 620084 5 of 5 470500 758500 2804.72 9,115,777

 Total 613048 5 of 5 483000 743000 613252 5 of 5 435500 739000 204.53 664,754

Manganese

 Dissolved 10.58 5 of 5 5.90 24.80 12.44 5 of 5 5.80 26.40 1.86 6,045

 Total 18.03 5 of 5 12.20 31.40 19.99 5 of 5 13.35 28.55 1.96 6,370

Molybdenum

 Dissolved 4.31 3 of 5 BDL 7.20 5.89 5 of 5 3.25 11.10 1.58 5,135

 Total 3.73 3 of 5 BDL 5.10 3.44 3 of 5 BDL 5.50 -0.29 (a)
Seawater Cooling Overboard Discharge

19

Nickel

 Dissolved ~ 0 of 5 BDL BDL 15.4 2 of 5 BDL 96.4 15.39 50,020

 Total ~ 0 of 5 BDL BDL 19.6 3 of 5 BDL 95.0 19.55 63,541

Silver

 Total ~ 0 of 5 BDL BDL 2.77 1 of 5 BDL 5.90 2.77 9,003

Sodium

 Dissolved 5065465 5 of 5 3650000 6300000 5248566 5 of 5 4250000 6505000 183101.78 595,109,334

 Total 5195468 5 of 5 3810000 6390000 5062513 5 of 5 3730000 6300000 -132954.92 (a)

Thallium

 Dissolved 6.25 1 of 5 BDL 15.30 6.2 1 of 5 BDL 25.0 -0.02 (a)

 Total 9.37 2 of 5 BDL 35.60 5.5 1 of 5 BDL 10.8 -3.89 (a)

Tin

 Dissolved ~ 0 of 5 BDL BDL 4.02 2 of 5 BDL 5.50 4.02 13,066

 Total 3.44 1 of 5 BDL 4.30 5.19 3 of 5 BDL 35.50 1.75 5,688

Titanium

 Total 4.60 3 of 5 BDL 9.00 5.42 3 of 5 BDL 15.80 0.82 2,665

Vanadium

 Dissolved 5.48 1 of 5 BDL 12.10 5.7 2 of 5 BDL 11.9 0.20 650

Zinc

 Dissolved 18.29 5 of 5 15.80 20.80 30.00 5 of 5 14.15 50.25 11.71 38,059

 Total 21.27 5 of 5 13.40 54.80 35.75 5 of 5 11.75 78.40 14.48 47,062

Classicals (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (lbs/yr)

Alkalinity 68.5 5 of 5 49.0 84.0 62.8 5 of 5 38.0 94.0 -5.67 (a)

Ammonia as

Nitrogen

0.10 3 of 5 BDL 0.22 0.12 4 of 5 BDL 0.24 0.02 65,010

Chemical Oxygen

Demand

140.2 5 of 5 70.00 289.0 141.5 4 of 5 BDL 265.0 1.28 4,160,617

Chloride 9270 5 of 5 7600 11000 9641 5 of 5 7750 12900 370.61 1,204,661,245

HEM ~ 0 of 5 BDL BDL ~ 0 of 5 BDL BDL ~ (b)

Nitrate/Nitrite 0.06 4 of 5 BDL 0.45 0.08 4 of 5 BDL 1.71 0.02 65,010

Sulfate 1222 5 of 5 972 1600 1236 5 of 5 930 1440 14.53 47,229,508

Total Dissolved

Solids

17618 5 of 5 14800 20700 16966 5 of 5 14300 20500 -651.92 (a)

Total Kjeldahl

Nitrogen

0.58 5 of 5 0.20 1.70 0.68 5 of 5 0.34 1.30 0.10 325,048

Total Organic

Carbon

1.7 2 of 5 BDL 3.6 2.0 3 of 5 BDL 2.9 0.32 1,040,154
Seawater Cooling Overboard Discharge

20

Total Phosphorous 0.08 4 of 5 BDL 0.31 0.07 4 of 5 BDL 0.20 -0.01 (a)

Total Recoverable

Oil & Grease

2.1 5 of 5 0.8 12.0 1.29 5 of 5 0.90 2.30 -0.85 (a)

Total Sulfide 4.0 5 of 5 2.0 7.0 5.4 5 of 5 2.0 35.0 1.35 4,388,151

Total Suspended

Solids

23.7 5 of 5 20.0 32.0 20.3 5 of 5 10.0 72.0 -3.40 (a)

Volatile Residue 1117 4 of 5 BDL 20700 465 4 of 5 BDL 20600 -652.05 (a)

Organics (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (μg/L) (lbs/yr)

4-Chloro-3-

Methylphenol

~ 0 of 5 BDL BDL 6.93 1 of 5 BDL 46.00 6.93 22,524

BDL = Below Detection Limit

~ = Value could not be calculated because samples are BDL

(a) = Mass loading was not determined for parameters for which the influent concentration exceeded the effluent.

(b) = Mass loading was not determined for parameters for which the effluent has a frequency of zero detections.

Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or more samples with the analyte below detection levels (i.e.,

“non-detect” samples), estimated analyte concentrations equivalent to one-half of the detection levels were also used to calculate the log-normal mean. For example, if a

“non-detect” sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log-normal mean calculation.
Seawater Cooling Overboard Discharge

21

Table 5. Estimated Annual Mass Loadings of Constituents

Constituent* Log-normal Mean

Influent (μg/L)

Log-normal Mean

Effluent (μg/L)

Log-normal Mean

Concentration (μg/L)

Estimated Annual

Mass Loading (lbs/yr)

Ammonia as Nitrogen 100 120 20 65,010

Nitrate/Nitrite 60 80 20 65,010

Total Kjeldahl

Nitrogen

580 680 100 325,048

Total NitrogenA390,058

Copper

 Dissolved 9.86 40.6 30.7 99,700

 Total 14.88 49.37 34.49 112,100

Nickel

 Dissolved ~ 15.4 15.4 50,100

 Total ~ 19.6 19.6 63,700

Silver

 Total ~ 2.77 2.77 9,000

* Mass loadings are presented for constituents that exceed ambient WQC and for bioaccumulators only. See Table 4

for a complete listing of mass loadings.

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Seawater Cooling Overboard Discharge

22

Table 6. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Constituents Log-normal

Mean

Effluent

Minimum

Concentration

Effluent

Maximum

Concentration

Effluent

Federal

Chronic WQC

Most Stringent State

Chronic WQC

Classicals (μg/L)

Ammonia as

Nitrogen

20 BDL 240 None 6 (HI)A

Nitrate/Nitrite 80 BDL 1710 None 8 (HI)A

Total Kjeldahl

Nitrogen

680 340 1300 None -

Total NitrogenB760 None 200 (HI)A

Metals (μg/L)

Copper

 Dissolved 40.55 11.90 1040.00 2.4 2.4 (CT, MS)

 Total 49.37 7.55 1135.00 2.9 2.9 (FL, GA)

Nickel

 Dissolved 15.4 BDL 96.4 8.2 8.2 (CA, CT)

 Total 19.6 BDL 95.0 8.3 7.9 (WA)

Silver

 Total 2.77 BDL 5.90 0.92 1.2 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA = California

CT = Connecticut

FL = Florida

GA= Georgia

HI = Hawaii

MS = Mississippi

WA = Washington
Seawater Cooling Overboard Discharge

23

Table 7. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents X X

3.4 Concentrations X

4.1 Mass Loadings X X

4.2 Environmental Concentrations X

4.3 Thermal Effects X

4.4 Potential for Introducing NonIndigenous Species

X
Seawater Piping Biofouling Prevention

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)--either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Seawater Piping Biofouling Prevention
Seawater Piping Biofouling Prevention

2

2.0 DISCHARGE DESCRIPTION

This section describes the seawater piping biofouling control discharge and includes

information on: the equipment that is used and its operation (Section 2.1), general description of

the constituents of the discharge (Section 2.2), and the vessels that produce this discharge

(Section 2.3). This report does not cover discharge of seawater cooling water from systems

which use copper piping as the only biofouling preventative--this discharge is covered in the

separate “Seawater Cooling Overboard Discharge” Nature of Discharge report.

2.1 Equipment Description and Operation

The detrimental effects of marine biofouling on vessel performance have long been

recognized by the Navy. The effects from biofouling are fouled surfaces of shipboard piping,

heat exchangers and other related equipment used to distribute seawater aboard vessels resulting

in flow restrictions and loss of heat transfer efficiency. Seawater cooling systems on vessels are

used to provide cooling water for propulsion plant and auxiliary system heat exchangers. Heat

exchangers remove heat directly from the main propulsion machinery, the electrical generating

plants, air conditioning plants, and directly or indirectly from all other equipment requiring

cooling. Seawater cooling systems draw seawater either directly, via a hull connection (sea

chest), or indirectly, via a seawater header or the firemain that is supplied directly from a hull

connection. The seawater is pumped through heat exchangers where the seawater absorbs heat

and is then discharged overboard.

Preventing biofouling in seawater cooling system heat exchanger tubes is essential for

maintaining peak heat exchanger operation and optimum propulsion plant performance. Marine

biofouling prevention is accomplished on certain vessels with on-board chlorinators that inject

low concentrations of sodium hypochlorite, a chlorine solution, at or near seawater cooling

system intakes. See Figure 1 for a schematic diagram of a typical shipboard chlorinator

treatment system. Chlorinators convert some chloride in seawater into a sodium hypochlorite

solution in an electrolytic cell. The hypochlorite solution from the cell is then piped to the

seawater intake or to junction piping at or near the seawater intake, where it is metered into the

seachest. This provides treatment of the seawater prior to passing through the cooling system

piping and components. The chlorine solution inhibits the growth of biofouling organisms or

prevents them from attaching to the interior surfaces of seawater cooling system piping and

components. A sampling connection at the outlet of the heat exchangers allows chlorine

concentration levels to be monitored, and the injection rate to be modified as necessary.

In addition to chlorination, Military Sealift Command (MSC) vessels use two other

methods to control biofouling; chemical dosing using an ethyl alcohol based chemical seawater

dispersant, and anodic biofouling control systems.1

Chemical dosing as a means of biofouling control involves the periodic injection of a

proportioned amount of an ethyl alcohol based chemical dispersant into the seawater cooling

system at or near the point of seawater intake, usually a seachest, and is currently used on one

MSC oiler. See Figure 2 for a schematic diagram of a typical shipboard chemical dosing
Seawater Piping Biofouling Prevention

3

treatment system. The means of injection may include a gravity head tank and flowmeter, an

eductor dosing system, or a pump and tank system directed to a seachest. The chemical is

flushed through the system and then discharged with the seawater.

Anodic biofouling control systems are designed for continuous operation. See Figure 3

for a schematic diagram of a typical shipboard anodic biofouling control system. Several

systems are currently in use. Each anodic system works on the same principle: an impressed

current applied to copper anodes accelerates the dissolution of copper ions. The anodes are

usually mounted in the sea chest of the vessel. Copper ions inhibit the propagation of marine life

and prevent biofouling.

2.2 Releases to the Environment

The purpose of chlorinating seawater is to protect the cooling system against biofouling

caused by the attachment of living organisms. A chlorination system generates “free chlorine” in

the form of a solution of sodium hypochlorite. This free chlorine reacts with various materials in

seawater, including living tissue, as described in Section 3.3. Seawater discharged from cooling

systems that are protected from biofouling with chlorine systems can contain residual free

chlorine as well various reaction products resulting from the reaction of the free chlorine with

organic material, ammonia, and bromide ion (see Section 3.3). In seawater, free chlorine and

resulting reaction products are collectively called “chlorine produced oxidants” or CPO.

It is expected that the cooling water discharged from the MSC vessel that chemically

doses its seawater cooling systems will contain the ethyl alcohol based dispersant. For those

MSC vessels with anodic treatment systems, constituents from the copper anodes used are

expected in the discharge.

2.3 Vessels Producing the Discharge

Refer to Table 1 for Navy and MSC vessel discharges. All other Armed Force vessels do

not use seawater piping biofouling control methods or equipment.2,3,4

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Seawater biofouling treatment systems continuously discharge both within and beyond 12

nautical miles (n.m.) of shore as long as seawater cooling systems are in operation.
Seawater Piping Biofouling Prevention

4

3.2 Rate

Table 1 presents estimated flow rates by ship class for pierside and underway

conditions.3,4,5

Seawater cooling water flows vary with propulsion plant operating conditions and the

system cooling requirements. There is a greater demand for cooling water when a vessel is

underway because the propulsion plant is operating. However, the time spent underway while

transiting within 12 n.m. is small compared to the time a vessel spends pierside and beyond 12

n.m. While pierside, the demand for seawater cooling is primarily from auxiliary equipment

such as electrical generators, and air conditioning and refrigeration plants.

Anodic biofouling control systems are manually controlled systems normally pre-set for a

current output of 0.2 amps,6 which results in the generation of approximately 0.237 g copper/hr

based on the following Faraday’s Law calculation:

{(0.2 amps) (63.54 g copper/mole) (1 coulomb/amp-sec) (3,600 sec/hr)} /

{(2 equivalents/mole) (96,484 coulomb/equivalent)}

= 0.237 g copper/hr

3.3 Constituents

Seawater dosed with sodium hypochlorite contains free chlorine in the form of

hypochlorous acid (HOCl) and hypochlorite ion (OCl-). Free chlorine undergoes four important

types of reactions in natural waters: (1) oxidation of reduced materials and subsequent

conversion to chloride ion; (2) reaction with ammonia and organic amines to form chloramines,

collectively called combined chlorine; (3) reaction with bromide to form hypobromous acid

(HOBr) and hypobromite (OBr--), called “free bromine;” and (4) reaction with organics to form

chloro-organics. Free bromine reacts in a manner similar to free chlorine, oxidizing reduced

material or forming bromamines (combined bromine) or bromo-organics. Most common

analytical methods for quantifying chlorine in water measure the sum of all free and combined

chlorine and bromine in solution, but do not measure the chloro- and bromo-organics. The

results of such measurements in seawater are reported as CPO. The Navy injects enough free

chlorine to meet the chlorine demand, and ensure that there is sufficient excess CPO throughout

the system to protect against biofouling.

Seawater treated with the chemical seawater dispersant contains primarily ethyl alcohol

and ammonium chloride. Other constituents of this dispersant are unknown.1

For those MSC vessels with installed anodic biofouling control systems, components of

copper ions are expected in the discharge.

Copper is the only priority pollutant in this discharge. There are no known

bioaccumulators in this discharge.
Seawater Piping Biofouling Prevention

5

3.4 Concentrations

On submarines, sodium hypochlorite solution containing hypochlorous acid and

hypochlorite ion is injected continuously into seawater piping systems to maintain a CPO

concentration of 100 μg/L at a sampling point within the system (i.e. before the point of

discharge from the submarine). The actual CPO concentration at the point of discharge from the

submarine is not measured. However, based on monitoring during initial system setup and

system design data, the CPO concentration in seawater cooling overboard discharge is lower than

the 100 μg/L concentration at the sample point. The concentrations of CPO discharged from

MSC vessels are assumed to be similar to the concentrations discharged from submarines (i.e.,

100 μg/L) because there are no available chlorine discharge data for MSC vessels.

Every three days, over the course of one hour, twelve liters of the chemical dosing

seawater dispersant is metered into a 9,200 gallons per minute (gpm) cooling water system

aboard one MSC oiler.1 Assuming all of the chemical added is also discharged, based on this

ratio, a concentration of approximately 6 mg/L in the discharge would result. The ethyl alcohol

based dispersant is expected to degrade rapidly and to be less than 6 mg/L after mixing with the

receiving waters.

Copper ion emission concentrations resulting from the use of anodic biofouling control

systems is dependent on the current (amperage) output and the seawater flow rate. The current

output is manually set (0.2 amps typically) and is not adjusted when seawater pumps are put on

or taken off line which changes the seawater flow rate. For a flow rate of 1,000 gal/min and

current output of 0.2 amps, the resultant concentration will be 1.04 μg/L based on the unit

conversion calculation below:

Concentration = (mass copper) / (volume water)

mass copper = 0.237 g/hr

volume water = 1,000 gal/min (3.785 L/gal) (60 min/hr) = 2.27 x 105 L/hr

concentration = (0.237 g/hr) / (2.27 x 105 L/hr) = 1.04 x 10-6 g/L = 1.04 μg/L

A flow rate of 1,000 gal/min, was used for this sample calculation only. 1,000 gal/min is a round

number and close to the flow rate of many fire pumps. Similar calculations can be performed for

other flow rates, with the resultant concentrations presented in Table 1.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality standards. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.
Seawater Piping Biofouling Prevention

6

4.1 Mass Loadings

Mass loadings were calculated in Table 2 based on ship movement data and the flow rates of

seawater estimated from Table 1.7 Calculations in Table 2 assumed that a chlorine concentration

of 100 μg/L is continuously present in the seawater discharge. Most common analytical methods

for quantifying chlorine in water measure the sum of all free and combined chlorine and bromine

in solution. The results of such measurements in seawater are reported as CPO. The Navy

injects enough “free chlorine” to meet the chlorine demand, and ensure that there is sufficient

excess CPO throughout the system to protect against biofouling. The total estimated mass

loadings for chlorine as CPO in Table 2 were calculated to be 2,538 pounds per year. The

following is a sample calculation for the SSN 688 at pierside:

Cl2 Mass Loading =(0.1 mg/L)(1.41x10

8

 gal/yr)(3.7854 L/gal)(2.2 lb/kg)(1 kg/1x106 mg)

=117 lb/yr

Cl2 concentration =0.1 mg/L (Mean concentration)

Flow rate =141,000,000 gal/yr

Conversion gals to liters =3.7854 L/gal

Conversion kg to lb =2.2 lb/kg

Conversion mg to kg =1 kg/1x106 mg

Cl2 Mass Loading =117 lb/yr

The dispersant dosing treatment system injects 12 liters of dispersant 26 times per year.1

At a weight of 8.23 pounds per gallon (lb/gal), a total of 678 pounds (82 gallons) of the

dispersant are added to over 1.033 billion gallons of seawater cooling water while in port. It was

assumed that with only 48 hours of transit time annually (with an average of 4 hours per transit),

dispersant dosing evolutions would not take place during transit.

Dispersant Mass Loading = (26 inj/yr)(12 L)(8.23 lb/gal)(.2642 gal/liters)

= 678 lb/yr

Injections per year = (78 days in port)/(Inject every 3 days) = 26 inj/yr

Amount Injected = 12 liters per injection

Conversion gals to lb = 8.23 lb/gal

Conversion liters to gal = .2642 gal/liters

Dispersant Mass Loading = 678 lb/yr

For the 19 MSC vessels with anodic biofouling control systems, using the copper

discharge rate of 0.237 g copper/hr and the estimated annual seawater discharge flow rates from

these vessels (Table 1 and 2), yields a total copper mass loading of 25.0 pounds per year.

4.2 Environmental Concentrations

Table 3 compares the constituent concentrations from Section 3.4 with the Federal and

most stringent state water quality criteria for CPO and copper. The estimated concentrations of
Seawater Piping Biofouling Prevention

7

CPO exceed the most stringent state water quality criteria.

Based on monitoring and system design data, CPO levels are estimated to be less than

100 μg/L for seawater discharges on submarines. There are no Federal water quality criteria for

chlorine. The most stringent state water quality criteria is 7.5 μg/L. The concentration value of

100 μg/L is measured as CPO which is primarily chlorine but can also include a small amount of

bromine.

A computer model was used that plotted chlorine plumes (using existing and planned

chlorine discharge levels) from various vessels in Mayport, Florida. Mayport is the smallest of

the five major naval ports. Plume dimensions at critical concentrations (7.5, 10, and 13 μg/L)

were compared with mixing zone limitations enforced by the states of Virginia and Washington.

Virginia and Washington are used because they are the only states with clearly defined mixing

zones. Only the chlorine plume from the MSC vessels did not meet the mixing requirements of

the selected states. This plume spread out during the later stages of mixing and exceeded certain

mixing zone width requirements.8 The computer model did not assume expected decay of CPO,

which would result in smaller mixing zones.

4.3 Potential for Introducing Non-indigenous Species

Biofouling prevention systems do not present an opportunity for transport of nonindigenous species. The anti-biofouling systems are designed to prevent organisms from

attaching to any part of seawater systems so they are discharged directly overboard in the same

geographical area in which they are pulled into the system.

5.0 CONCLUSION

Seawater piping biofouling control discharge has the potential to cause an adverse

environmental effect. For chlorinator biofouling prevention systems, chlorine is discharged in

significant amounts at concentrations expected to exceed ambient state water quality criteria.

The use of anodic biofouling control systems results in the discharge of copper overboard. The

copper concentration being significantly lower than water quality criteria, and the annual mass

loading being very low, the discharges from anodic biofouling control have a low potential for

causing adverse environmental effects.

6.0 DATA SOURCES AND REFERENCES

Table 4 lists the data source of the information presented in each section of this NOD

report.

Specific References

1. Weersing, P., MSC Central Technical Activity, Code N72PC1. Point Paper,
Seawater Piping Biofouling Prevention

8

“Supplemental Information About Chlorinators and Other Anti-Fouling Systems for

Seawater Systems On MSC Ships,” December 20, 1996.

2. Aivalotis, J., USCG, Personal communication with David Eaton, M. Rosenblatt & Son.

April 25, 1997.

3. Kurz, Richard J., SEA 92T251. Equipment Expert Meeting Structured Questions,

“Seawater System Chlorination with Dechlorination,” September 5, 1996.

4. UNDS Equipment Expert Meeting (October 2, 1996) Minutes.

Chlorinator/Dechlorinator. October 11, 1996.

5. UNDS Round Two Equipment Expert Meeting Minutes, Seawater Piping Biofouling

Control Discharge, April 4, 1997.

6. Cathelco Limited Information Packet, December 24, 1997.

7. Pentagon Ship Movement Data for Years 1991 - 1995, Dated March 4, 1997.

8. Malcolm Pirnie Inc., “Environmental Effects Analysis: Chlorination of Seawater Cooling

Systems for Biofouling Prevention,” September 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
Seawater Piping Biofouling Prevention

9

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Seawater Piping Biofouling Prevention

10

Figure 1. Chlorination Systems Schematic
Seawater Piping Biofouling Prevention

11

Figure 2. Typical Installation of Chemical Dosing System
Seawater Piping Biofouling Prevention

12

Figure 3. Typical Installation of Anodic Biofouling Control System
Seawater Piping Biofouling Prevention

13

Table 1 - Estimated Annual Seawater Cooling Water Discharge Volumes for Vessels With Seawater Piping

Biofouling Control Systems

Ship Class Biofouling

Control

System

No. of

Ships

No. of

Transits

per Year(1)

No. of

Days In

Port(1)

No. of Hours

In Transit

(<12 n.m.)(2)

Estimated

Flow by Ship

Class Pierside

(gal/min)

Estimated Flow

by Ship Class

Underway

(gal/min)

Concentrations

(μg/L)

pierside (3) U/W

Total Estimated

Discharge

Pierside

(gal/year)

Total Estimated

Discharge In

Transit (<12 n.m.)

(gal/year)

SSN 688

(Mod 25)

Chlorinator 4 14 183 56 133 192,000 100 (6) 141,000,000 1,790,000

T-AH Chlorinator 2 8 184 32 2,000 40,500 100 (6) 1,070,000,000 156,000,000

T-AFS Chlorinator 3 14 148 56 2,000 40,500 100 (6) 1,280,000,000 408,000,000

T-AO Chemical

Dosing(4)

1 12 78 48 9,200 40,500 6,000 (7) 1,030,000,000 117,000,000

T-AGS Anodic(5) 5 12 96 48 1,500 6,840 0.69 0.15(8) 1,040,000,000 98,500,000

T-AGOS 1

Class

Anodic(5 6 8 70 32 1,500 6,840 0.69 0.15(8) 907,000,000 78,800,000

T-AGOS 19

Class

Anodic(5 4 10 107 40 1,500 6,840 0.69 0.15(8) 924,000,000 65,700,000

T-AGM Anodic(5 1 8 133 32 2,000 40,500 0.52 0.026(8) 383,000,000 77,800,000

T-ATF Anodic(5 3 34 166 136 1,650 7,500 0.63 0.14(8) 1,180,000,000 184,000,000

(1) In accordance with information presented in Reference 7.

(2) Assuming an average transit time of 4 hours per vessel.

(3) Differing pierside and underway (U/W) concentrations apply to vessels with anodic biofouling control systems

(4) It is assumed that the same volume of chemical dispersant injected is also discharged (representing worst case).

(5) Anodic biofouling control system concentrations were calculated based on a copper generation rate of 0.237 g/hr (Section 3.4)

(6) Concentration of Chlorine as CPO

(7) Concentration assuming the dispersant is 100% ethanol (representing worst case)

(8) Concentration of copper
Seawater Piping Biofouling Prevention

14

Table 2 - Estimated Annual Mass Loading Calculations for Seawater Cooling Water Discharges from Vessels With

Seawater Piping Biofouling Control Systems Currently Installed Onboard

Ship Class Biofouling

Control

System

Total

Estimated

Discharge

Pierside

(gal/year)

Total

Estimated

Discharge

In Transit

(<12 n.m.)

(gal/year)

Estimated

Flow by Ship

Class

Pierside

(gal/min)

Estimated

Flow by

Ship Class

Underway

(gal/min)

Concentrations

μg/L

pierside (1) U/W

Estimated

Mass Loading

Pierside

(lb/yr)

Estimated

Mass

Loading

In Transit

(lb/yr)

Total Mass

Loading by

Type of System

Pierside

(lb/yr)

Total Mass

Loading by

Type of

System

In Transit

(lb/yr)

SSN 688

(Mod 25)

Chlorinator 141,000,000 1,790,000 133 133 100 (4) 117 1.5

T-AH Chlorinator 1,070,000,000 156,000,000 2,000 40,500 100 (4) 883 130 2,066 472

T-AFS Chlorinator 1,280,000,000 408,000,000 2,000 40,500 100 (4) 1,066 340

T-AO Chemical

Dosing(2)

1,030,000,000 117,000,000 9,200 40,500 6,000 (5) 678 Note (7) 678 Note (7)

T-AGS Anodic(3) 1,040,000,000 98,500,000 1,500 6,840 0.69 0.15(6) 6.02 0.125

T-AGOS 1

Class

Anodic(3) 907,000,000 78,800,000 1,500 6,840 0.69 0.15(6) 5.25 0.100

T-AGOS 19

Class

Anodic(3) 924,000,000 65,700,000 1,500 6,840 0.69 0.15(6) 5.35 0.083 24.48 0.54

T-AGM Anodic(3) 383,000,000 77,800,000 2,000 40,500 0.52 0.026(6) 1.66 0.017

T-ATF Anodic(3) 1,180,000,000 184,000,000 1,650 7,500 0.63 0.14(6) 6.21 0.213

(1) Differing pierside and underway (U/W) concentrations apply to vessels with anodic biofouling control systems

(2) It is assumed that the same volume of chemical dispersant injected is also discharged (representing worst case)

(3) Anodic biofouling control system concentrations were calculated based on a copper generation rate of 0.237 g/hr (Section 3.4)

(4) Concentration of Chlorine as CPO

(5) Concentration assuming the dispersant is 100% ethanol (representing worst case)

(6) Concentration of copper

(7) It is assumed that with only 48 hours of transit time annually (with an average of 4 hours per transit), chemical dosing evolutions would not take place during

this time.
Seawater Piping Biofouling Prevention

15

Table 3. Environmental Concentrations and Water Quality Criteria (μg/L)

Constituent Concentration

(μg/L)

Federal Chronic

WQC (μg/L)

Most Stringent State

Chronic WQC (μg/L)

CPO 100 - 7.5 (CT, HI, MS, NJ, VA,

WA)

Copper 0.52 - 0.69 2.4 2.4 (CT, MS)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

CT = Connecticut

HI = Hawaii

MS = Mississippi

NJ = New Jersey

VA = Virginia

WA = Washington

Table 4. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents X X X

3.4 Concentrations X X

4.1 Mass Loadings X

4.2 Environmental Concentrations X X

4.3 Potential for Introducing NonIndigenous SpeciesX X
Small Boat Engine Wet Exhaust

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipments or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Small Boat Engine Wet Exhaust
Small Boat Engine Wet Exhaust

2

2.0 DISCHARGE DESCRIPTION

This section describes the small boat engine wet exhaust discharge and includes

information on: the equipment that is used and its operation (Section 2.1), general description of

the constituents of the discharge (Section 2.2), and the vessels that produce this discharge

(Section 2.3).

2.1 Equipment Description and Operation

Small boat engines commonly use seawater to both cool and quiet their exhaust. Seawater

passes through the heat exchanger, gear oil cooler, and aftercooler (if equipped), and is then

injected into the exhaust. When injected, some of the gaseous and solid components of the

exhaust transfer into the cooling water. The cooling water then discharges into the receiving

water. Any cooling water that is not injected into the exhaust is directed overboard.1 For

purposes of this analysis, it was assumed that all cooling water cycled through the engine is

injected into the air exhaust.

Small boats are powered by either inboard or outboard engines. Inboard engines usually

develop greater power than outboards. In addition, inboard engines are generally diesel fueled

while outboard engines typically use gasoline. Inboard and outboard engines can be either twoor four-stroke. The majority of small boat outboard engines are two-stroke gasoline engines.

The moving parts of gasoline-powered, two-stroke outboard engines are lubricated with oil that

is pre-mixed with gasoline. Thus, the oil is continuously burned with the gasoline. In fourstroke engines, lubricating oil is circulated and not intentionally introduced into the combustion

chamber.2

A diagram of a typical two-stroke diesel engine air system is included as Figure 1. A

diagram of a typical inboard wet-exhaust system is included as Figure 2. Although engine design

may vary based on boat class, general process flow will be similar for all water-cooled, small

boat engines.

2.2 Releases to the Environment

This discharge consists of water injected as a cooling stream into the exhaust system of

small boat engines. Exhaust constituents generated during the operation of the engines can be

transferred to the engines’ water cooling streams and discharged as wet exhaust. Inboard engines

usually discharge wet exhaust above the water line. Outboard engines generally discharge their

wet exhaust underwater through the propeller hub.

2.3 Vessels Producing the Discharge

There are approximately 3,300 Navy, 1,560 U.S. Coast Guard (USCG), 209 Army, and

1,454 Marine Corps small boats currently using seawater for cooling engine exhaust. Of the total

number of small boats in the military fleet, 3,822 have inboard engines and 2,701 have outboard
Small Boat Engine Wet Exhaust

3

engines.3 Air Force and Military Sealift Command (MSC) small boats have not been included in

this analysis; however, their inclusion does not significantly affect this reports conclusion.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Based on their limited range, all small boats are expected to operate within 12 nautical

miles (n.m.).1

3.2 Rate

Approximately one-third of the small boat fleet is equipped with outboard engines.

Based on engine specifications, outboard engines can discharge up to 20 gallons per minute

(gpm).4 This rate was used as the fleet-wide average for outboard-driven small boats.

Inboard diesel engines generally have a higher discharge rate than outboard engines, and

can discharge up to 100 gpm.5 This estimate assumes that all cooling water flows through the

engine and is discharged into the exhaust. Many small Armed Forces boats have twin engines,

yielding a total flow rate up to 200 gpm per vessel. However, to take into account vessels with

single engine installations, and for vessels with engines discharging less than 100 gpm per

engine, a flow rate of 150 gpm per vessel was used as the average fleet-wide flow rate for boats

with inboard engines.

Table 1 summarizes the estimated annual small boat engine wet exhaust flow rate by

service. Flow rates were calculated for each service based on a monthly average operating time

of 25 hours, and each vessel discharging 150 gpm of wet exhaust for inboards and 20 gpm for

outboards.4,5,6 The total fleet-wide discharge is approximately 11 billion gallons per year.

3.3 Constituents

The main constituents from all engines are oxides of nitrogen (NOx), organic compounds

(including hydrocarbons (HCs)), carbon monoxide (CO), and particulates. The HC constituents

are primarily the result of incomplete combustion. Since diesel fuels have a different

composition than regular gasoline, the distribution of constituents in the exhaust differ between

the two engine types. In general, diesel engines produce higher particulate emissions and lower

organic emissions than gasoline-powered engines.7

3.3.1 Outboard Engines
Small Boat Engine Wet Exhaust

4

As mentioned in Section 2.1, almost all outboard engines are two-stroke gasoline

powered engines. Some limited studies have been done on the impact of engine exhaust on

water quality. A 1995 study measured the rate of introduction of volatile organic compounds

(VOCs) into water during the operation of gasoline powered two-stroke and four-stroke outboard

engines. In this study, a 10-horsepower (hp) outboard engine of each type was operated in an

enclosed tank, and the increase in VOCs such as benzene was measured. The results were given

in terms of milligram (mg) of compound per 10 minutes (min) of operation (e.g. 2800 mg

benzene/10 min). Therefore, the number was a bulk measurement of the rate of accumulation of

the compound in the water.8

The study reported that the VOC compounds found in water for both two-stroke and fourstroke engines were almost exclusively aromatic hydrocarbons. In most cases, other types of

HCs were not found. The amount of VOCs found in the water on a power basis (grams per

horsepower-hour (g/hp-hr) was equivalent to approximately 10% of the total HCs emitted in the

exhaust. The VOC compounds measured in the 1995 study and the rate of accumulation are

shown in Table 2.8 Of the compounds listed in Table 2, benzene, toluene, ethylbenzene, and

naphthalene are priority pollutants. No bioaccumulators are suspected to be present in this

discharge.

3.3.2 Inboard Engines

To support the air quality management planning process, EPA has published emission

factors for various industrial sources, including stationary diesel engines up to 600 hp. These

emissions factors relate quantities of released materials to fuel input, as nanogram per joule

(ng/J) fuel input, or power output, as in g/hp-hr. Although intended for stationary diesel engines,

these emission factors may be used to approximate diesel engine emissions for small boats and

craft for the following reasons:

• For diesel engine families with 1994 emissions certification, more than 90 percent

have HC emissions of 0.5 g/hp-hr or less.9 According to the manufacturer’s

specification sheet, the HC emissions rate for a typical diesel engine in use by the

Armed Forces is 0.45 g/hp-hr.5

 This demonstrates that the emissions from the

typical diesel engine used by the Armed Forces is similar to industry standard

diesel engines.

• The EPA emission factor for total organic carbon (TOC) emitted by diesel engines

is approximately 1.1 g/hp-hr.7 Because HCs are a subset of TOC, these emissions

rates appear to be appropriate for an order of magnitude estimate.

Table 3 lists the emission factors for constituents present in the air exhaust of diesel

engines.7

 Through contact with the cooling water, many of these constituents have the potential

to be introduced into the water. Of the compounds shown in Table 3, benzene, toluene, acrolein,

naphthalene, acenaphthylene, acenaphthene, fluorene, phenanthrene, anthracene, fluoranthene,

pyrene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene,
Small Boat Engine Wet Exhaust

5

benzo(a)pyrene, indeno(1,2,3-cd)pyrene, dibenzo(a,h)anthracene, and benzo(g,h,i)perylene are

priority pollutants. None of the constituents listed in Table 3 are bioaccumulators.

3.4 Concentrations

3.4.1 Outboard Engines

The 1995 study measured the VOC accumulation in water from the exhaust of 10-hp (7.3

kilowatt (kW)) two-stroke engines. Because the typical two-stroke outboard engine used by the

Armed Forces is a 100 hp (74.6 kW) engine, the results from the 10-hp engine are not directly

transferable. However, one pertinent observation was reported in the 1995 study which permits

the results of the smaller engine to be “scaled” up for a larger engine. This observation was that

the concentration of VOC in the water was related primarily to the level of HC emissions in the

exhaust. The higher the level of HC emissions in the engine air exhaust, the higher the level of

VOC found in the water.8 This indicates that if the level of total HC emissions for a larger

engine can be estimated, the VOC concentrations for the compounds given in the 1995 study can

reasonably be estimated by comparing the total HC emission rates.

In 1996, EPA published a rule regulating the emissions of gasoline-powered marine

engines. The rule gives an equation for HC output which describes the current emission rates of

two-stroke engines for the power output range from 2 hp to 300 hp. This equation is given as:

In this expression, P is the power in kW, and HC is the hydrocarbon emissions rate in

g/kW-hr.10 The relationship between power and emissions is different for 4-stroke and 2-stroke

engines. However, in the absence of a similar equation for 4-stroke engines, it was assumed that

4-stroke engine emissions follow the same trend in emissions output on a normalized basis

(power basis) as two-stroke engines.

Using the typical two-stroke outboard engine size of 100 hp and the EPA equation, the

normalized output for HC is 162.5 g/kW-hr. Therefore, the total emissions rate is approximately

12,122 g/hr. Using the 7.3 kW engine power and the 267 g/kW-hr HC emissions rate reported in

the 1995 study for the two-stroke engine, the total HC emissions rate is 1,949 g/hr. The ratio of

HC emissions for these two engine sizes can be calculated as shown below:

Estimate the hydrocarbon emissions ratio for a 100 hp (74.6 kW) engine

Total emissions rate (7.3 kW engine): = (HC)(P) = (267 g/kW-hr) (7.3 kW) = 1,949 g/hr

Projected emissions rate (74.6 kW engine): = (HC)(P) = (162.5 g/kW-hr)(74.6 kW) = 12,122 g/hr

Emissions ratio = 12,122/1,949 = 6.2

If it is assumed that there is a direct relationship between the HC emissions rate and the

VOC introduction rate, the rates of VOC introduction measured in the 1995 study can be

multiplied by the HC emissions ratio. Using this approach, Table 4 provides the estimated VOC

HC = [151+(557/P0.9)], or 300 g/kW-hr, whichever is lower.
Small Boat Engine Wet Exhaust

6

introduction rates for two-stroke outboard engine wet exhaust. An example calculation for

benzene is provided below:

Benzene introduction rate for a 7.3 kW engine is 2800 mg/10 min (from 1995 study)

Hydrocarbon emissions ratio for a 74.6 kW engine equals 6.2 (from above calculation)

Benzene introduction rate equals (6.2)(2800 mg/10 min) = 17,360 mg/10 min

A similar procedure can be followed to estimate the VOC introduction rate for fourstroke engines. For these engines, a typical engine size is 90 hp. Again, using the EPA equation,

the normalized output for HC in a 90 hp (67.1 kW) engine is 163.6 g/kW-hr. Therefore, the total

emissions rate is approximately 10,961 g/hr. Using the 7.3 kW engine power and the 267 g/kWhr HC emissions rate reported in the 1995 study for the two-stroke engine, the total HC

emissions rate for the two-stroke engine in the 1995 study is 1,949 g/hr. For a 90 hp engine, the

hydrocarbon emissions ratio therefore is 10,961/1,949 or 5.62. Using this ratio, Table 4 shows

the estimated VOC introduction rate for four-stroke outboard engines. A sample calculation for

the introduction rate of benzene is given below:

Benzene introduction rate for a 7.3 kW engine is 110 mg/10 min (from 1995 study)

Hydrocarbon emissions ratio for a 67.1 kW engine equals 5.62 (from above calculation)

Benzene introduction rate equals (5.62)(110 mg/10 min) = 618.2 mg/10 min

To estimate the concentration of the constituents in the wet exhaust, the flow rate must be

used. From Section 3.2, the approximate wet exhaust flow rate for outboard engines is 20 gpm.

The constituent concentration can be estimated by assuming all the VOCs introduced into the

exhaust enters the water. Table 4 shows the estimated concentrations for the constituents in both

two-stroke and four-stroke outboard engines. A sample calculation is presented below:

Wet Exhaust Flow rate: 20 gpm

Benzene introduction rate: 17,360 mg/10 min

Concentration = (17,360 mg/10 min)(1 min/20 gal)(1 gal/3.7854 L) = 22.9 mg/L

3.4.2 Inboard Engines

The constituent concentrations for the discharge of inboard engines were determined

through a multi-step calculation. Using emission factors for mid-size stationary diesel engines

given in Table 3 and diesel engine output specifications, the concentrations in air exhaust were

estimated. The transfer of air exhaust constituents into the water was estimated using Henry’s

Law, which relates the partial pressure of a gas in the atmosphere to the concentration of the gas

in water. Table 5 provides the estimated constituent concentrations in the inboard engine wet

exhaust. A sample calculation for the concentration of benzene is presented in the calculation

sheet at the end of the report.

4.0 NATURE OF DISCHARGE ANALYSIS
Small Boat Engine Wet Exhaust

7

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality standards. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The estimated mass loadings shown in Table 6 and Table 7 were based on the total

number of small boats in the Navy, USCG, Army, and Marine Corps; on a monthly average

operating time of 25 hours; and each boat discharging 150 gpm of wet exhaust for inboards and

20 gpm for outboards.4,5,6 The concentration data for two-stroke engines were used because the

majority of Armed Forces outboard engines are two-stroke. This approach is conservative

because constituent concentrations in two-stroke engine wet exhaust are higher than

concentrations in four-stroke engine exhaust.

Mass loading sample calculations:

Table 6, Outboard Engine for benzene is:

(22.93 mg/L)(0.97 billion gallons/yr)(3.785 liters/gallon)(1 kg/106 mg) = 84,186 kg/yr

Table 7, Inboard Engine for benzo(a)pyrene is:

(7.69 x 10-5 mg/L)(10.31 billion gallons/yr)(3.785 liters/gallon)(1 kg/106 mg) = 3.0 kg/yr

4.2 Environmental Concentrations

The concentrations and mass loading estimates described above are likely an overestimate

because of non-equilibrium effects. The method used to estimate the concentrations of the diesel

exhaust components in wet exhaust using Henry’s Law assumed sufficient residence time inside

the engine for the aerosols in the exhaust to reach equilibrium with the cooling water. However,

due to the short residence time of both air and water in the exhaust system, equilibrium

conditions are unlikely. Residence time in the exhaust system is expected to be less than one

second. Because equilibrium conditions are unlikely, less constituents will dissolve in the

cooling water.

Based on cited research, chemical constituents in the wet exhaust from small boat engines

can be present at concentrations that exceed water quality criteria (WQC). Table 8 summarizes

estimated discharge concentrations and WQC for constituents of this discharge. Benzene,

toluene, ethylbenzene, and naphthalene in two stroke outboard engines exceed the most stringent

state WQC. Benzene and ethylbenzene in four-stroke outboard engine wet exhaust, and total

PAHs in inboard engine wet exhaust each exceed the most stringent state WQC.

4.3 Non-Indigenous Species
Small Boat Engine Wet Exhaust

8

The residence time of cooling water in small boat engines is very short; therefore, the wet

exhaust is discharged within yards of where the cooling water was taken aboard. Because

seawater is not transported during small boat operations, it is unlikely that the operation of small

boat engines could transport or introduce non-indigenous species.

5.0 CONCLUSIONS

Constituents found in small boat engine wet exhaust discharge are estimated to be

discharged in significant amounts that exceed water quality criteria. Therefore, this discharge has

the potential to cause adverse environmental effects.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information, equipment specifications, average annual use, and fleet-wide inventories were

considered in estimating the rate of discharge. Estimated constituent concentrations were

calculated using solubility principles and published emissions data. Additional constituent

concentrations were obtained from previously completed research. Table 9 shows the sources of

data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Small Boat Engine Wet Exhaust. 3

September 1996, M. Rosenblatt and Son, Inc. (MR&S)

2. Davis, Kip, NSWC. Small Boat Equipment Description and Operation, 10 March 1998,

Doug Hamm, Malcolm Pirnie, Inc.

3. UNDS Round 2 Equipment Expert Meeting Minutes - Small Boat Wet Exhaust. 8 April

1997.

4. Outboard Marine Corporation. Water Pump Flow Data - V4/V6/V8. February 5, 1997.

5. Marine Specification Sheet, Model 7082-7000 Diesel Engine, Detroit Diesel Corporation,

1993.

6. Kip Davis (NSWC). Boat Numbers and Flow Rates, 18 March 1997, Doug Hamm

(MPI).

7. United States Environmental Protection Agency, Office of Air Quality Planning and

Standards. Compilation of Air Pollution Emission Factors. AP-42, Fifth Addition,

January 1995.
Small Boat Engine Wet Exhaust

9

8. Juttner, et. al, “Emissions of Two- and Four-stroke Outboard Engines- I. Quantification

of Gases and VOC.” Water Resources, Vol. 29 (November 1995): 1976-1982.

9. Environmental Protection Agency. Final Regulatory Impact Analysis: Control of

Emissions of Air Pollution from Highway Heavy Duty Engines, 16 September 1997.

10. Environmental Protection Agency, “Final Rule for New Gasoline Spark-Ignition Marine

Engines”, Federal Register, Vol. 61, No. 194 (4 October 1996): 52091.

11. UNDS Database. 593.9117, Volume 2, Part 1. Small Boat Wet Exhaust. “Air Systems

of a 2-stroke cycle engine (GM71).” 19 November 1996.

12. Oregon Iron Works. "Boat Information Book for 65' Explosive Ordnance

Disposal Support Craft (EODSC) MK2, FY91-S9007-CL-BIB-010". 15 December

1993. Pg 3-12.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
Small Boat Engine Wet Exhaust

10

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

LT Joyce Aivalotis, USCG. Average Operating Times for USCG Small Boats. 11 April 1997.

William Boudreaux (NSWC) & Kip Davis (NSWC). Ship Numbers and Flow Rates, 12 May

1997, Doug Hamm (MPI).

Staskiel, Mike, PMS324G16. List of Small Boats by Engine Type. 3 October 1996.

MARCORSYSCOM. Totals for Marine Small Boat/Watercraft. 14 February 1997.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. 23 March 1995.
Small Boat Engine Wet Exhaust

11

Figure 1. Air Systems of a Two-Stroke Cycle Engine (GM71)11
Small Boat Engine Wet Exhaust

12

Figure 2. Typical Water Jacketed Elevated Loop12
Small Boat Engine Wet Exhaust

13

Table 1. Estimated Annual Small Boat Wet Exhaust Discharge Flow Rates3,4,5,6

Service (fleet) Number of Small

Boats

Estimated Annual Discharge*

(billions of gallons)

Navy (inboard) 2,500 6.75

Navy (outboard) 800 0.29

USCG (inboard) 620 1.67

USCG (outboard) 940 0.34

Army (inboard) 152 0.41

Army (outboard) 57 0.02

Marine Corps (outboard) 904 0.32

Marine Corps (inboard) 550 1.48

Totals (inboard)

Totals (outboard)

Totals (combined)

3,822

2,701

6,523

10.31

 0.97

11.28

* Based on 150 gpm for vessels with inboard engines, 20 gpm for vessels with outboard engines, and an average

operating time of 25 hours/month.

Table 2. Wet Exhaust Constituents Emitted from Two and Four-Stroke 10 Horsepower

Gasoline Outboard Engines8

Constituent Amount in Wet Exhaust from

Two-Stroke Outboard Engines

(mg/10 min)*

Amount in Wet Exhaust from

Four-Stroke Outboard Engines

(mg/10 min)

Benzene 2800 110

Toluene 8500 260

Ethylbenzene 2000 22

p/m-Xylene 6900 71

o-Xylene 3600 37

3 4-Ethyltoluene 3400 26

Mesitylene 1200 10

2-Ethyltoluene 870 8.7

Pseudocumene 4500 40

Hemellitene 1200 13

Indane 840 4.7

Indene 270 6.5

Naphthalene 1400 13

2-Methylnaphthalene 930 5.5

1-Methylnaphthalene 350 2.7

Formaldehyde 970 100

*Note: Majority of small boat outboard engines in the Armed Forces are two-stroke engines
Small Boat Engine Wet Exhaust

14

Table 3. Organic Compound Emission Factors for Diesel Engines7

Constituent Emission Factor

(lb/MMBtu)* (ng/J)

Benzene 0.000933 0.40119

Toluene 0.000409 0.17587

Xylenes 0.000285 0.12255

Formaldehyde 0.00118 0.5074

Acetaldehyde 0.000767 0.32981

Acrolein 0.0000925 0.039775

Nox 4.41 1896.3

CO 0.95 408.5

CO2 164 70520

Naphthalene 0.0000848 0.036464

Acenaphthylene 0.00000506 0.0021758

Acenaphthene 0.00000142 0.0006106

Fluorene 0.0000292 0.012556

Phenanthrene 0.0000294 0.012642

Anthracene 0.00000187 0.0008041

Fluoranthene 0.00000761 0.0032723

Pyrene 0.00000478 0.0020554

Benzo(a)anthracene 0.00000168 0.0007224

Chrysene 0.000000353 0.00015179

Benzo(b)fluoranthene 9.91E-08 0.000042613

Benzo(k)fluoranthene 0.000000155 0.00006665

Benzo(a)pyrene 0.000000188 0.00008084

Indeno(1,2,3-cd) pyrene 0.000000375 0.00016125

Dibenz(a,h) anthracene 0.000000583 0.00025069

Benzo(g,h,i) perylene 0.000000489 0.00021027

* lb/MMBtu = pounds per million British thermal units
Small Boat Engine Wet Exhaust

15

Table 4. Estimated Concentrations of Wet Exhaust Constituents from Two- and FourStroke Gasoline Outboard Engines

Constituent Introduction Rate

Two-Stroke Engines

(mg /10 min)*

Introduction Rate

Four-Stroke Engines

(mg /10 min)*

Estimated Concentrations in

Engine Wet Exhaust (mg/L)

Two-Stroke Four-Stroke

Benzene 17360 618.2 22.93 0.82

Toluene 52700 1461.2 69.62 1.93

Ethylbenzene 12400 123.64 16.38 0.16

p/m-Xylene 42780 399.02 56.51 0.53

o-Xylene 22320 207.94 29.48 0.27

3 4-Ethyltoluene 21080 146.12 27.85 0.19

Mesitylene 7440 56.2 9.83 0.07

2-Ethyltoluene 5394 48.89 7.13 0.06

Pseudocumene 27900 224.8 36.86 0.3

Hemellitene 7440 73.06 9.83 0.1

Indane 5208 26.41 6.88 0.035

Indene 1674 36.53 2.21 0.048

Naphthalene 8680 73.06 11.47 0.1

2-Methylnaphthalene 5766 30.91 7.62 0.04

1-Methylnaphthalene 2170 15.17 2.87 0.02

Formaldehyde 6014 562 7.94 0.74

*Note: The majority of small boat outboard engines in the Armed Forces are two-stroke engines.
Small Boat Engine Wet Exhaust

16

Table 5. Estimated Concentrations of Wet Exhaust Constituents from

Diesel Inboard Engines

Constituent Concentration in Air Exhaust Concentration in Discharge

(moles/ft3) (mg/L)

Benzene 3.21E-08 1.87E-04

Toluene 1.19E-08 6.78E-05

Xylenes 7.22E-09 4.91E-05

Formaldehyde 1.06E-07 7.58E-01

Acetaldehyde 4.68E-08 4.83E-02

Acrolein 4.44E-09 6.15E-04

Nox 3.95E-04 1.82E-02

CO 9.11E-05 1.97E-03

CO2 1.00E-02 1.11E+01

Naphthalene 1.78E-09 2.19E-04

Acenaphthylene 8.93E-11 2.16E-06

Acenaphthene 2.47E-11 6.58E-06

Fluorene 4.72E-10 3.81E-04

Phenanthrene 4.43E-10 8.17E-04

Anthracene 2.82E-11 3.46E-05

Fluoranthene 1.01E-10 3.84E-06

Pyrene 6.35E-11 4.43E-04

Benzo(a)anthracene 1.98E-11 9.18E-04

Chrysene 4.15E-12 2.13E-04

Benzo(b)fluoranthene 1.05E-12 5.28E-06

Benzo(k)fluoranthene 1.65E-12 2.49E-06

Benzo(a)pyrene 2.00E-12 7.69E-05

Indeno(1,2,3-cd) pyrene 3.65E-12 3.45E-03

Dibenzo(a,h) anthracene 5.63E-12 5.05E-03

Benzo(g,h,i) perylene 4.75E-12 5.80E-03
Small Boat Engine Wet Exhaust

17

Table 6. Estimated Annual Fleet-Wide Mass Loading of Wet Exhaust Constituents

from Outboard Engines

Constituent Concentrations Estimated Mass Loading

(mg/L) (kg/yr) (lbs/yr)

Benzene 22.93 84,196 185,600

Toluene 69.62 255,595 562,500

Ethylbenzene 16.38 60,140 132,600

p/m-Xylene 56.51 207,483 456,400

o-Xylene 29.48 108,252 238,700

Naphthalene 11.47 42,098 92,800

2-Methylnaphthalene 7.62 27,965 61,700

* These values were based on an annual flow rate of 0.97 billion gallons/year (see Section 4.1). Mass

loadings are based on estimated emissions from a 100 HP, two-stroke engine.

Table 7. Estimated Annual Fleet-Wide Mass Loading of Wet Exhaust Constituents from

Diesel Inboard Engines

Constituent Concentration in

Discharge

Annual Mass

Loading

Annual Mass

Loading

(mg/L) (Kilograms) (Pounds)

Polyaromatic

Hydrocarbons (PAHs)

Naphthalene 2.19E-04 8.56E+00 18.9

Acenaphthylene 2.16E-06 8.44E-02 0.186

Acenaphthene 6.58E-06 2.57E-01 0.566

Fluorene 3.81E-04 1.49E+01 32.8

Phenanthrene 8.17E-04 3.19E+01 70.3

Anthracene 3.46E-05 1.35E+00 2.98

Fluoranthene 3.84E-06 1.50E-01 0.330

Pyrene 4.43E-04 1.73E+01 38.1

Benzo(a)anthracene 9.18E-04 3.58E+01 79.0

Chrysene 2.13E-04 8.32E+00 18.3

Benzo(b)fluoranthene 5.28E-06 2.06E-01 0.454

Benzo(k)fluoranthene 2.49E-06 9.72E-02 0.214

Benzo(a)pyrene 7.69E-05 3.00E+00 6.61

Indeno(1,2,3-cd) pyrene 3.45E-03 1.35E+02 297

Dibenzo(a,h) anthracene 5.05E-03 1.97E+02 434

Benzo(g,h,i) perylene 5.80E-03 2.26E+02 499

* These values were based on an annual flow rate of 10.31 billion gallons/year (see Section 4.1)
Small Boat Engine Wet Exhaust

18

Table 8. Comparison of Estimated Concentrations of Wet Exhaust Constituents and

Water Quality Criteria (μg/L)

Constituent Estimated Discharge

Concentration

Federal Acute

WQC

Most Stringent State Acute

WQC

Outboard Engines

Two-Stroke

Benzene 22,930 None 71.28 (FL)

Toluene 69,620 None 2,100 (HI)

Ethylbenzene 16,380 None 140 (HI)

Naphthalene 11,470 None 780 (HI)

Four-Stroke

Benzene 820 None 71.28 (FL)

Ethylbenzene 160 None 140 (HI)

Inboard Engines

Acenaphthylene 2.16E-03 None 0.031 (FL)1

Phenanthrene 8.17E-01 None 0.031 (FL)1

Chrysene 2.13E-01 None 0.031 (FL)1

Benzo(a)pyrene 7.69E-02 None 0.031 (FL)1

Benzo(a)anthracene 9.18E-01 - 0.031 (FL)1

Benzo(b)fluoranthene 5.28E-03 - 0.031 (FL)1

Benzo(k)fluoranthene 2.49E-03 - 0.031 (FL)1

Indeno(1,2,3-cd) pyrene 3.45 - 0.031 (FL)1

Dibenzo(a,h) anthracene 5.05 - 0.031 (FL)1

Benzo(g,h,i) perylene 5.80 - 0.031 (FL)1

TOTAL PAHs (Inboard

Engines)

16.3 1 0.031 (FL)1

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

FL = Florida

HI = Hawaii

1: Florida criteria for total PAHs is for the total of the following individual PAH compounds: acenaphthylene,

benzo-(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene,

chrysene, dibenzo(a,h)anthracene, indeno(1,2,3-cd)pyrene, and phenanthrene. Estimated discharge

concentrations for total PAHs represent a sum of these chemicals.
Small Boat Engine Wet Exhaust

19

Table 9. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X X

2.2 Releases to the Environment X X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X X

3.2 Rate X X X

3.3 Constituents X X X

3.4 Concentrations X X

4.1 Mass Loadings X

4.2 Environmental Concentrations X X

4.3 Potential for Introducing NonIndigenous SpeciesX
Small Boat Engine Wet Exhaust

20

Calculation Sheet

Benzene

Background:

Henry’s Law was used to estimate the concentration of components in wet exhaust from small boat inboard

diesel engines. This calculation sheet shows the calculation for the concentration of benzene in the wet

exhaust. Calculations for the other exhaust components were similar.

A heat balance was used to determine the approximate wet exhaust equilibrium temperature. The

temperature was determined using an air exhaust flow rate of 2,190 cfm at 870 °F, and a water injection rate

of 100 gpm at 60 °F. 60 °F is believed to be an appropriate average because most large military ports are

located in areas with similar average water temperatures. For this calculation, we assume the exhaust gas to

have thermal properties similar to air.

ΔH: Change in enthalpy, m: mass of air or water, Cp: Specific heat capacity of air or water

ΔHexhaust gas = ΔHwater

ΔHexhaust gas = mCp (200 °F - T)

 = (2,190 ft3/min) (0.0601 lbm/ft3 ) (0.24 Btu/lbm°F) (870 °F - T)

 = 31.59 Btu/°F min. (870 °F - T) (1)

ΔHwater = mCp (T - 60 °F) = (100 gal/min) (8.345 lbm /gal) (1 Btu/ lbm °F) (T - 60 °F)

= 834.5 Btu/°F min (T - 60 °F) (2)

Setting (1) = (2) we obtain the following:

31.59 Btu/°F (870 °F - T) = 834.5 Btu/°F( T - 60 °F)

31.59 (T) + 834.5 (T) = 870 °F (31.59) + 834.5 (60 °F)

 T = 89.5 °F = (9/5) °C + 32 = 32 °C

This temperature was then used to determine the appropriate values for Henry’s Law

constants, which vary with temperature.

At dilute concentrations, the concentration of benzene dissolved in water can be found from Henry’s Law:

Xexhaust = (Ha) (Xwater) / (Pt)

Where: 

Xexhaust: Mole Fraction of Benzene in Exhaust

Ha: Henry’s Law Constant (Adjusted Reference 7)

Xwater: Mole Fraction of Benzene in Water

Pt: Total Exhaust Pressure (atm)

Rearranging, Henry’s Law can be rewritten as:

Xwater = (Xexhaust) (Pt) / Ha

The mole fraction of benzene in exhaust can then be converted into a concentration of benzene in the wet

exhaust in mg/L using the molecular weight of benzene.

Given Conditions and Assumptions:
Small Boat Engine Wet Exhaust

21

55.56 moles H2O in 1 liter, [ (1000 g/liter) (mole H2O / 18 g ) = 55.56 moles H2O / liter ]

Exhaust temperature of 870 °F

2,190 cfm air exhaust flow rate for 228 kW diesel engine

0.401 ng/J generation rate of benzene

Backpressure (Pt) on engine is approximately 1.147 atm

Molecular weight of benzene is 78.11 grams per mole (78,110 mg/mole)

Based on a water temperature of 32 °C (305.15 K), Henry’s Law constants (in atm) for the constituents are

the following:

Constituent Ha (atm)

Benzene 6.52E+02

Toluene 7.94E+02

Xylenes 7.64E+02

Formaldehyde 2.05E-01

Acetaldehyde 2.09E+00

Acrolein 1.98E+01

Nox 6.81E+04

CO 1.37E+05

CO2 3.85E+03

Naphthalene 5.09E+01

Acenaphthylene 3.08E+02

Acenaphthene 2.84E+01

Fluorene 1.01E+01

Phenanthrene 4.74E+00

Anthracene 7.11E+00

Fluoranthene 2.61E+02

Pyrene 1.42E+00

Benzo(a)anthracene 2.41E-01

Chrysene 2.18E-01

Benzo(b)fluoranthene 2.47E+00

Benzo(k)fluoranthene 8.19E+00

Benzo(a)pyrene 3.22E-01

Indeno(1,2,3-cd) pyrene 1.43E-02

Dibenzo(a,h) anthracene 1.52E-02

Benzo(g,h,i) perylene 1.11E-02

The conversion of Henry’s Law constants into common units is presented at the end of the calculation sheet.

Solution:

1) Total number of moles per cubic foot in the air exhaust, including constituents and circulated air, nt

The number of moles per cubic foot can be determined using the ideal gas law; PV = ntRT

Where:

P: Pressure within the exhaust piping, 1.147 atm

V: Volume of space occupied by gas (assume 1 ft3)

R: Gas constant, 0.08206 L-atm/ K-mol

T: Temperature, 305.15 K

Rearranging the ideal gas law equation and solving for nt/V:

nt /V = P/RT

nt /V = (1.147atm) / (( 0.08206 L-atm/ K-mol) ( 1 ft3 /28.32 L) (305.15 K))

 = 1.30 moles/ ft3
Small Boat Engine Wet Exhaust

22

2) Concentration of benzene in air exhaust, Ab

Ab= (0.401 ng/J) (228 kW) (3.6 x 106 J/kW-hr) (10-9g/ng) (1000 mg/g) (min./2190 ft3) (hr/60 min)

 = 2.50 x 10-3 mg/ft3

 = (2.50 x 10-3 mg/ft3

) (mole benzene/78,110 mg) = 3.2 x 10-8 moles benzene/ft3 exhaust

3) Mole fraction of gas in exhaust, Pa

Pa = Ab / total molar concentration

Pa = (3.2 x 10-8 moles benzene/ ft3 exhaust) / (1.30 total moles/ ft3 exhaust)

Pa = 2.46 x 10-8 moles benzene/ mole exhaust

4) Mole fraction of gas in water, Xwater

Xwater = (Xexhaust) (Pt) / Ha

Xwater = (2.46 x 10-8) (1.147 atm) / (652 atm)

Xwater = 4.33 x 10-11 moles benzene/ mole water

5) Concentration of gas in water:

Per 1 liter of water;

Moles benzene = (4.33 x 10-11 moles benzene/mole H2O)(55.56 moles H2O/ 1 liter) = 5.19 x 10-9 moles/L

 = (2.4 x 10-9 moles/L) (78,110 mg benzene/mole) = 1.87 x 10-4 mg/L benzene
Small Boat Engine Wet Exhaust

23

Determination of Henry’s Constants

Henry’s constants for the constituents were available, but units and temperature for the constants varied between the

references used. Henry’s constants with the following units were available:

1) H1, atm

2) H2, atm-m3/mol

For purposes of clarity, the same calculation was used for each constituent. It was therefore necessary to

convert all of Henry’s constants to atm units, (1).

1) Conversion H2 (atm-m3/mol) to H1 (atm):

H1 = (H2 atm-m3/mol) (55.6 mol water / L) ( L / 10-3 m3 water) = (H2) (55,600)

Henry’s constants with the following temperatures in degrees Celsius were available:

(1) 20 oC

(2) 24 oC

(3) 25 oC

(4) 40 oC

(5) 32 oC

Henry’s constants increase on average about threefold for every 10 oC rise in temperature for most volatile

hydrocarbons.a Therefore, with an increase in temperature the constants increase by a factor of ΔH = 3(ΔT/10). All of

the constants were converted to 32 oC constants using the following conversions.

For Henry’s constant at 32 oC and converting from Henry’s constants at 20 oC , 24 oC, 25 oC, and 40 oC respectively:

H32 = (H20) (3.74),

H32 = (H24) (2.41),

H32 = (H25) (2.16), and

H32 = (H40) / (2.41)

Example - Henry’s Constant Calculation

For Acrolein, Henry’s constant was available in atm-m3/mol for 20oc (Ha = 9.54 x 10-5)

Ha (atm) = (9.54 x 10-5 atm-m3/mol) (55,600 mol/m3) (3.74)

Ha = 19.8 atm

Using these methods, the constants were converted to atm units as shown in the table on the following page.
Small Boat Engine Wet Exhaust

24

Table of Henry’s Constants

Degrees 32 degrees 20 degrees 25 degrees 25 degrees 40 degrees 32 degrees

Source Cooper USEPA Mackay Mackay CH2M Hill Henry's Constants

Units atm (atm*m3

/mol) (atm*m3/mol) Kpa m3/mol (atm*m3/mol) atm

Benzene 5.50E-01 6.52E+02

Toluene 6.70E-01 7.94E+02

Xylenes 6.45E-01 7.64E+02

Formaldehyde 9.87E-07 2.05E-01

Acetaldehyde 9.05E-05 2.09E+00

Acrolein 9.54E-05 1.98E+01

Nox 3.18E+04 3.18E+04

CO 6.35E+04 6.35E+04

CO2 1.95E+03 1.95E+03

Naphthalene 1.15E-03 4.24E-04 4.30E-02 5.09E+01

Acenaphthylene 1.48E-03 3.08E+02

Acenaphthene 9.20E-05 2.37E-04 2.40E-02 2.84E+01

Fluorene 6.42E-05 8.39E-05 8.50E-03 1.01E+01

Phenanthrene 1.59E-05 3.95E-05 4.00E-03 4.74E+00

Anthracene 1.02E-03 5.92E-05 6.00E-03 7.11E+00

Fluoranthene 6.46E-06 2.17E-03 2.20E-01 2.61E+02

Pyrene 5.04E-06 1.18E-05 1.20E-03 1.42E+00

Benz(a)anthracene 1.16E-06 2.41E-01

Chrysene 1.05E-06 2.18E-01

Benzo(b)fluoranthene 1.19E-05 2.47E+00

Benzo(k)fluoranthene 3.94E-05 8.19E+00

Benzo(a)pyrene 1.55E-06 3.22E-01

Indeno(1,2,3-cd) pyrene 6.86E-08 1.43E-02

Dibenz(a,h) anthracene 7.33E-08 1.52E-02

Benzo(g,h,i) perylene 5.34E-08 1.11E-02

Bold: Original Referenced Number

Sources:

a. Kavanaugh, M. C. and R. Rhodes Trussell, “Design of Aeration Towers to Strip Volatile

Contaminants from Drinking Water” Journal of the American Water Works Association, December, 1980.

b. Cooper, D. and F. Alley, Air Pollution Control, A Design Approach. Waveland Press, Inc., 1986.

c. United States Environmental Protection Agency, Office of Air Quality Planning and Standards.

Ground-Water and Leachate Treatment Systems Manual. R-94, January 1995.

d. Mackay, D. and W. Y. Shiu, “A Critical Review of Henry’s Law Constants for Chemicals of

Journal of Phys. Chem. Ref. Data. Vol. 10, No. 4, pp. 1175-1199. 1981.

e. CH2M Hill Inc., Bay Area Sewage Toxic Emissions Model. Version 3, 1992.
Small Boat Engine Wet Exhaust MPCD Analysis

1

SMALL BOAT ENGINE WET EXHAUST

MARINE POLLUTION CONTROL DEVICE (MPCD) ANALYSIS

Several alternatives were investigated to determine if any reasonable and practicable

MPCDs exist or could be developed for controlling discharges from small boat engine wet

exhaust. An MPCD is defined as any equipment or management practice, for installation or use

onboard a vessel, designed to receive, retain, treat, control, or eliminate a discharge incidental to

the normal operation of a vessel. Phase I of UNDS requires several factors to be considered

when determining which discharges should be controlled by MPCDs. These include the

practicability, operational impact, and cost of an MPCD. During Phase I of UNDS, an MPCD

option was deemed reasonable and practicable even if the analysis showed it was reasonable and

practicable only for a limited number of vessels or vessel classes, or only on new construction

vessels. Therefore, every possible MPCD alternative was not evaluated. A more detailed

evaluation of MPCD alternatives will be conducted during Phase II of UNDS when determining

the performance requirements for MPCDs. This Phase II analysis will not be limited to the

MPCDs described below and may consider additional MPCD options.

MPCD Options

Small boats of the armed forces are equipped with either two- or four-stroke compression

ignition diesel or two-stroke spark ignition gasoline engines. During the operation of small boat

engines, seawater is used to cool and quiet engine exhaust. As seawater is introduced into the

engine exhaust, combustion by-products are captured by the seawater stream, and are discharged

into the receiving water.

Three potential MPCD options were investigated. The purpose of these MPCDs would

be to reduce or eliminate the release of hydrocarbons, oil and grease, volatile organic compounds,

and semi-volatile organic compounds into the marine environment. The MPCD options were

selected based on initial screenings of alternate materials and equipment, pollution prevention

options, and management practices. They are listed below with brief descriptions of each:

Option 1: Employ dry exhaust systems on new boats and craft with inboard engines

-This option would require that new small boats and craft to be equipped with inboard

engines to be outfitted with dry exhaust systems wherever practicable.

Option 2: Convert small boats and craft with inboard engines to a dry exhaust

system - This option would involve converting small boats and craft that are currently

discharging wet exhaust at or below the waterline to dry exhaust systems.
Small Boat Engine Wet Exhaust MPCD Analysis

2

Option 3: Procure new outboard engines with reduced emissions to meet new

emissions requirements being imposed in 1999 - This option would involve replacing

existing outboard engines with new “low emission” outboard engines either all at once or

through attrition. These new outboards would meet EPA emission requirements which

will be taking effect in 1999.

MPCD Analysis Results

Table 1 shows the results of the MPCD analysis. It contains information on the elements

of practicability, effect on operational and warfighting capabilities, cost, environmental

effectiveness, and a final determination for each option. Based on these findings, Option 1 --

building small boats and craft with inboard engines and dry exhaust systems, and Option 3 --

procure new outboard engines with reduced emissions to meet new emissions requirements, offer

the best combination of these elements and are both considered to represent a reasonable and

practicable MPCD.
Small Boat Engine Wet Exhaust MPCD Analysis

3

Table 1. MPCD Option Analysis and Determination

MPCD Option Practicability Effect on Operational &

Warfighting Capabilities

Cost Environmental

Effectiveness

Determination

Option 1. Employ dry

exhaust systems on new

boats and craft with

inboard engines

This option would require a

practicability study for new

small boat and craft that

have inboard engines.

Higher acoustic and thermal

signatures of dry exhaust

systems are anticipated and

could affect selected

mission/operational profiles

for some large special

warfare boats. A boat and

craft class study would be

necessary to assess

operational impact.

Changing the existing

design would impose

additional design costs

including engineering

analysis, drawing

development, and design

history documentation.

Costs associated with actual

installation of the dry

exhaust systems are limited

to material costs because

labor costs for installing

each type of system are

approximately the same.1

Dry exhaust systems would

eliminate the exhaust /

seawater discharge on boats

and crafts on which they are

installed. Dry exhaust

systems would disperse

pollutants over a larger area

reducing the potential for

causing a sheen.

This option appears to be

practicable for most new

boats and craft with inboard

engines. This option would

eliminate the wet exhaust

discharge from new small

boats and craft, on which it

is practicable to install a dry

exhaust system.

Option 2. Convert small

boats and craft with

inboard engines to a dry

exhaust system

Installing dry exhaust

systems on existing small

boats would require many

modifications because of the

large number of small boat

configurations. Feasibility

studies would be necessary

for each boat class as it may

not be physically possible to

install a dry exhaust system

on many boat classes.

Higher acoustic and thermal

signatures of dry exhaust

systems is anticipated and

could affect selected

mission/operational profiles

for some large special

warfare boats. A boat and

craft class study would be

necessary to assess

operational impact.

Converting existing inboard

engines would result in

costs for: feasibility studies,

engineering design,

installation drawing

development, alteration

record preparation, Boat

Information Book update,

material, and installation.

It is estimated that $36M

would be required to study,

design, and install this

change on small boats/craft

in the Navy.1

The dry exhaust system

would eliminate the

exhaust/seawater discharge

on vessels where the

installation is practicable.

Dry exhaust systems would

disperse pollutants over a

larger area reducing the

potential for causing a

sheen.

This option does not appear

to be practicable due to

space and weight

limitations on small vessels,

and due to high cost on all

boats and craft.
Small Boat Engine Wet Exhaust MPCD Analysis

4

MPCD Option Practicability Effect on Operational &

Warfighting Capabilities

Cost Environmental

Effectiveness

Determination

Option 3. Procure new

outboard engines with

reduced emissions to

meet new emissions

requirements being

imposed in 1999

Space and volume

requirements are expected

to be similar to those of

existing engines. In some

select cases, an increase in

weight may occur and

therefore slightly effect the

boat’s trim angle. Some

new engines are expected to

weigh about 15% more than

existing engines. Limited

horsepower ranges currently

available, may require two

outboards where one was

sufficient before.

This MPCD is not expected

to cause any significant

change in war fighting

capabilities or ship

mobility. Assuming that

the boat is supplied with

similar horsepower and

other characteristics as

previous engines, the

operational impact will be

negligible.

The costs associated with

this option include:

feasibility study, design,

development, alteration

record preparation, Boat

Information Book update,

maintenance record /

preventative maintenance

documentation update,

material, and installation

costs. Replacing all

existing small boat and craft

outboard engines in the

Navy would cost an

estimated $9.0M.

Implementing this option

through attrition would

impose a considerably lower

annual cost of $34,000.1

New technology outboard

engines will significantly

reduce engine emissions.2

New EPA regulations are

likely to encourage the

widespread use of fourstroke, fuel injection, and

advanced two-stroke

engines. Engine

manufacturers claim a 94%

reduction in hydrocarbons

with four-stroke engines.

This MPCD appears to be

practicable with the

exception of converting all

existing craft to reduced

emission engines, as the

cost of conversion often

exceeds the value of the

craft. The reduced emission

engine, which burns fuel

more completely and

directly, will reduce the

amount of pollution

significantly.
Small Boat Engine Wet Exhaust MPCD Analysis

5

REFERENCES

1

 NSWC Comments on NOD Report Review, March 18, 1997.

2

 USEPA, Amendment to Emissions Requirements Applicable to New Gasoline Spark-Ignition

Marine Engines, EPA Title 40 CFR Part 91, Effective April 2, 1997.
Sonar Dome Discharge

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Sonar Dome Discharge
Sonar Dome Discharge

2

2.0 DISCHARGE DESCRIPTION

This section describes the sonar dome discharge and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Sonar domes are located on the hulls of submarines and surface ships. Their purpose is to

house electronic equipment used for detection, navigation, and ranging. Figures 1 through 4

show typical hull-mounted submarine and surface ship sonar domes.

Sonar domes on Navy surface ships are made of rubber. On submarines, they are made of

steel or glass-reinforced plastic (GRP) with a 1/2-inch rubber boot covering the exterior.

Military Sealift Command (MSC) T-AGS Class ships have sonar domes made of GRP. Zinc

anodes are fastened to the exterior of steel sonar domes, and are contained within all the sonar

domes, for cathodic protection. Figure 5 shows a Navy surface ship rubber dome, prior to

installation.

Sonar domes can be filled with fresh and/or seawater to maintain their shape and design

pressure. Most surface ship sonar domes are initially filled with freshwater, and any water that is

lost underway is replenished with seawater from the firemain system. Sonar domes on FFG 7

Class frigates and some MSC ships are filled with seawater. Submarine sonar domes are

connected to the sea through a small tube to equalize pressure, but water inside the dome has

limited exchange with seawater.1

Table 1 summarizes sonar dome types, applications, and characteristics. The larger

AN/SQS-53 and AN/SQS-26 sonar domes on cruisers and destroyers are located at the bow, and

the smaller AN/SQS-56 domes on frigates are mounted on the keel. Submarine sonar domes are

located at the bow. MSC T-AGS Class ships have several small sonar domes at various locations

on the hull. The T-AGS Class sonar domes listed as free flood in Table 1, have ports which are

open to the sea.

Table 2 shows materials that compose sonar domes, and components and materials inside

sonar domes. Components and materials interior to sonar domes can include piping, sacrificial

anodes, paint and the interior material surface of the sonar dome itself. Materials on the exterior

surface of the sonar dome consist of the exterior material surface of the dome itself, any paints or

coatings applied to the dome, and in some cases, sacrificial anodes.

There have been changes in the composition of the rubber material in Navy surface ship

sonar domes. Prior to 1985, all sonar domes contained tributyltin (TBT) antifoulant on the

interior and exterior, to prevent or minimize marine growth. The TBT was impregnated into the

outermost 1/4-inch layers (both exterior and interior) of the rubber. Figure 6 shows the plys or

layers of a surface ship rubber sonar dome. Since 1985 rubber sonar domes have been

manufactured with TBT only on the exterior surface. This type of sonar dome has been
Sonar Dome Discharge

3

backfitted on older ships when they require sonar dome replacement, and has been installed on

all new ships since 1990. Submarine sonar domes do not contain TBT. Instead, the exterior

rubber boots are coated with a copper-based antifouling paint.2 Table 3 lists the surface ships

that have no TBT in the interior of their sonar domes.

Sonar domes are emptied for sonar dome maintenance or replacement, and are always

emptied when a vessel is in drydock. Some maintenance can be performed pierside. Sonar

domes are emptied by first pressurizing them with air, to force as much water as possible through

the installed eductor piping. Once this step is complete, eductors are used to remove all

remaining water in the dome. The total volume of water discharged exceeds the sonar dome

volume because the seawater used to operate the eductors is discharged along with water from

the sonar dome.

The water emptied from the sonar dome interior is: 1) discharged overboard, if the vessel

is waterborne, or 2) collected for proper management ashore, if the vessel is in drydock.

2.2 Releases to the Environment

There are two sonar dome discharges, discharges of the water from the interior of sonar

domes and external discharges. Discharges of water from the interior of the sonar dome result

from maintenance evolutions that require the sonar dome to be emptied. External discharges

result from continuous leaching of TBT or other anti-fouling compounds from the sonar dome

exterior.

2.3 Vessels Producing the Discharge

Only Navy and MSC vessels are equipped with sonar domes; the other Armed Forces

ships are not. Sonar domes are equipped on the following types and classes of Navy and MSC

ships:

• cruisers (CG and CGN Classes);

• destroyers (DD and DDG Classes);

• frigates (FFG Class);

• submarines (all SSN and SSBN Classes); and

• MSC T-AGS Class ships.

Tables 1 and 4 list the classes and populations of sonar dome-equipped vessels. Eightythree of the Navy surface ships have the larger AN/SQS-26 or SQS-53 sonar domes, and 43 have

the smaller SQS-56 domes. Seventy-two active submarines have the smaller BQQ-5, BQR-7 or

BSY-1 sonar domes, and the 17 others have much larger BQQ-6 sonar domes.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the
Sonar Dome Discharge

4

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Discharges from the interior of sonar domes only occur while vessels are pierside.

Discharges from the external surface of sonar domes occur both within and beyond 12 nautical

miles (n.m.) of shore, as materials leach continuously from the exterior of the dome. Discharges

from the external surface of sonar domes were studied by the Naval Command, Control and

Ocean Surveillance Center to characterize the environmental effects in San Diego harbor.3

3.2 Discharge Rate

Discharge from the interior of sonar domes is intermittent, depending on when the dome

is emptied for maintenance. The average volume of water discharged for maintenance or repair

activities is estimated based on input from naval shipyards. Sonar dome discharge volume varies

with the dome type (size) and the method used to empty the dome. Norfolk and Pearl Harbor

Naval Shipyards report that between 23,000 and 38,000 gallons is typically emptied from

AN/SQS-53 sonar domes.4,5 Table 4 contains the estimated annual discharge for sonar doneequipped vessels, based on the vessel class populations, sonar dome water capacity, and number

of sonar domes expected to be emptied per year. On average, sonar domes on surface ships are

emptied two times per year. Submarine sonar domes are normally emptied once per year.2 Table

4 indicates a total annual discharge estimate of about 9.3 million gallons of interior sonar dome

effluent, with just under 4.0 million of that being from sonar domes with internal TBT coatings.

Discharge from the external surface of a sonar dome is not a liquid discharge; rather, it is

the leaching of anti-fouling agents into the surrounding water, and cannot be characterized by a

volumetric flow rate. A Navy study was conducted in San Diego Bay in 1996 to determine TBT

release rates from rubber sonar domes. Release rates from the external surfaces were determined

by attaching a closed capture system to the sonar domes exteriors of three ships. The sampled

sonar domes ranged in age, at 3, 10 and 20 years since installation. Table 5 shows that the

average release rate for TBT from the external surfaces of the sonar domes was 0.36 μg/cm2

/day

(micrograms per square centimeter per day), which results in an average release of 0.27 grams of

TBT per day per ship.3

3.3 Constituents

Table 2 shows the components and materials in sonar domes that can contribute

constituents to the sonar dome discharge. The specific constituents depend on vessel class, the

age of the dome, and the source of water that fills the dome. Discharges from the interior of

sonar domes can include copper, nickel, tin and zinc which corrodes, erodes, or leaches from

piping, sacrificial anodes, paint, or other material inside the dome. If the interior of the dome is

impregnated with TBT, discharges will also include that constituent. The potable water and/or

seawater that fills the sonar dome is also a source of constituents in discharges from the interior.
Sonar Dome Discharge

5

In addition to these constituents, the interior effluent can contain compounds that are produced

by degradation of the materials or reaction of material with the water. For instance, TBT, which

might be found on both the interior and exterior of surface ship rubber sonar domes, degrades to

dibutyltin (DBT) and monobutyltin (MBT).

External discharge constituents will include the TBT impregnated into the exterior of

rubber sonar domes, or copper from copper based antifoulant coating on GRP and steel domes.

Discharge from copper based and other antifoulant coatings are addressed separately, by the Hull

Coating Leachate NOD Report.

Sampling of the water within the interior of sonar domes was conducted to identify and

measure constituents, and was done according to procedures specified by the Navy. Samples

from the interior of sonar domes were manually collected from the sonar dome piping systems of

Navy surface ships and submarines, prior to discharge. The three sampling activities, Norfolk

and Pearl Harbor Naval Shipyards and the Naval Command, Control and Ocean Surveillance

Center did not all sample for the same constituents, as shown in Table 6. The tests that were

performed on the samples included gas chromatography, hydride derivization and atomic

absorption for TBT, and Toxicity Characteristic Leaching Procedure (TCLP) for metals. Tests

done on sonar domes have indicated that the constituents of discharges from the interior of sonar

domes are copper, nickel, tin, zinc, TBT (also known as tetra-normal-tributyltin), DBT and MBT.

External sonar dome discharge constituents are TBT, DBT, MBT, copper, and zinc.3,4,5,6

Of the discharge constituents listed above, copper, nickel, and zinc are priority pollutants.

None of the discharge constituents are bioaccumulators.

3.4 Concentrations

A summary of results of sampling discharges from the interior of sonar domes is

contained in Table 6. Altogether, previous Navy studies have analyzed the water from the

interior of sonar domes on 31 surface ships and submarines, with some vessels sampled multiple

times. In addition to the metals and compounds listed in Section 3.3, four samples from the USS

South Carolina were analyzed for Chemical Oxygen Demand (COD) and four samples from the

USS Conolly were analyzed for both Total Suspended Solids (TSS) and Total Organic Carbon

(TOC). The results of the sampling are summarized below:3,4,5

The average concentrations of the metal constituents are listed in Table 6.

Among the classical pollutants, COD levels ranged from 20 to 180 milligrams per liter

(mg/L), with an average of 123 mg/L. Total organic carbon levels ranged between 4 and 6 mg/L.

Total suspended solids were all below 4 mg/L.

TBT concentrations ranged from 1 to 470 micrograms per liter (μg /L), with an average of

74 μg/L. Only one sample has been taken for concentrations of MBT and DBT. The results

were 5 and 33 μg/L, respectively.
Sonar Dome Discharge

6

The firemain system is normally used to replenish sonar dome water lost on surface ships

while underway and to educt the final water remaining when a sonar dome is emptied. However,

the seawater from the firemain has a negligible effect on the constituent concentrations in this

report. The salinity of the samples was low, indicating that little make-up seawater was added to

the sonar domes during operations. The sonar dome sampling procedure requires samples to be

taken from the dome, not from the emptied water, so firemain water that powers the eductors will

not dilute or contribute constituents to the samples.

The above analytical results only address discharges from the interior of the sonar domes,

and do not account for the discharge from the external surfaces. The external surface TBT

release rates and estimated mass loadings are included in Sections 3.2 and 4.1, respectively.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality standards. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The amount of water discharged fleet-wide from the interior of sonar domes was

estimated using:

1) the amount of water generated from each type of sonar dome when that sonar dome is

emptied;

2) the frequency of maintenance requiring sonar domes to be emptied;

3) the number of vessels with each type of sonar dome; and

4) the average concentrations of each of the constituents.

The estimated fleet-wide mass loadings for copper, nickel, tin, and zinc were calculated

by the following formula:

For example, copper:

This calculation of mass loadings from sonar domes overestimates the actual mass

loadings because:

Mass Loading (lbs/yr) =

(avg. concentrations in μg/L) (discharge in gal/yr) (3.7854 L/gal) (2.2 lb/kg) (10-9 kg/μg)

Mass Loading =

(303 μg/L) (9,278,800 gal/yr) (3.7854 L/gal) (2.2 lb/kg)(10-9 kg/μg) = 23.4 lbs/yr
Sonar Dome Discharge

7

1) All discharges are assumed to occur pierside, but some of the discharges actually

occur in drydock, where they are managed under shipyard discharge permits.

2) All discharges are assumed to occur within U.S. territorial waters, but some of the

discharges actually occur outside U.S. territorial waters.

3) Results of discharge sample measurements which were below detection levels were

assumed to be at the detection level.

The average constituent concentrations from Table 6, and a total estimated annual

discharge volume of 9.3 million gallons per year for all vessels, taken from Table 4, were used to

calculate the mass loadings. Based upon this information and the above formula, the annual

mass loadings for metals were calculated to be 23 pounds for copper, 11 pounds for nickel, 15

pounds for tin, and 122 pounds for zinc.

The estimated fleet-wide mass loading for TBT, DBT and MBT generated from sonar

dome interiors was calculated by the same formula (above), using a 3.96 million gallon discharge

volume per year for those vessels in Table 4 that could have TBT inside the sonar dome. Using

the average TBT concentration of 74 μg/L, the annual mass loading estimate for TBT is 2.4

pounds per year due to discharges of water from the interior of the sonar dome. Although not

representative of all vessels, the one sample in which DBT and MBT were measured is used to

calculate fleet-wide mass loading for those constituents, using the same 3.96 million gallon

discharge volume , since DBT and MBT are degradation products of TBT. Based on the single

sample concentrations of 33 and 5 μg/L for DBT and MBT, respectively, the estimated mass

loadings are 1.1 and 0.2 pounds per year, respectively.

The calculation for TBT mass loading from the exteriors of surface ship rubber sonar

domes was performed using the following formula:

Sonar Dome External Discharge TBT Mass Loading (lbs/yr) =

(avg. release rate in g/day) (0.00205 lbs/g) (no. of ships with rubber domes) [avg. days/yr in port

+ ((no. transits/yr) (4 hrs/transit)÷ 24 hrs/day)]

(0.27 g/day) (0.00205 lbs/g) (126 ships) (158 days/yr in port + ((12 transits/yr)(4 hrs/transit)÷ 24

hrs/day)) = 12.6 lbs/yr

This formula uses the release rate from Table 5, which is based on sampling the discharge

from the external surface of rubber sonar domes on three Navy surface ships, two of which had

older sonar domes, and the newer DDG 51 Class USS John Paul Jones.3 The formula also uses

158 days/yr as the estimated annual in-port time for each ship. The result is a TBT annual mass

loading of 12.6 pounds due to discharges from the external surface of the sonar dome.

Therefore, the estimated maximum TBT mass loading within 12 n.m. for surface ships

equipped with rubber sonar domes is 15.0 lbs/yr. This is the sum of 2.4 lbs/yr from discharges

from the interior of the sonar domes and 12.6 lbs/yr from discharges from the external surface.

The estimated mass loadings generated from sonar dome interior and exterior discharges
Sonar Dome Discharge

8

are presented in Table 7.

4.2 Environmental Concentrations

Table 8 compares the concentrations of constituents in sonar dome discharge with the

most stringent water quality criteria (WQC) for that constituent. For sonar dome discharge, the

constituents known to be present are TBT, DBT, MBT, copper, nickel, tin, and zinc. As a result

of the comparison, the mean concentrations of TBT, copper, nickel, and zinc each exceed their

respective Federal and most stringent state acute WQC. The interior concentrations can be

compared to acute values and the exterior concentrations compared to chronic values. Neither

DBT, MBT, nor tin has a relevant WQC.

4.3 Potential for Introduction of Non-Indigenous Species

Most sonar domes do not have the potential for the transfer of non-indigenous species in

discharge of water from the interior of the sonar dome, or for transfer from the external surface.

Non-indigenous species transfer would occur primarily during the emptying and replenishment of

water in the interior of the sonar dome, and that is normally performed at a vessel's homeport or a

shipyard. TBT on the interior surface of older rubber sonar domes and the exterior of all rubber

sonar domes prevents attachment of marine organisms and could inhibit their growth.

Sonar domes filled with freshwater have little potential to be a mechanism for transfer of

non-indigenous species in the water that fills the dome. There is minimal exchange with

seawater. Only a small volume of water from the ship's potable water or surrounding seawater is

added to the existing potable water in the dome between emptying and replenishment events to

make up for any loss of sonar dome water during operations. Therefore, the opportunity to

introduce non-native organisms into the surrounding water is limited.

Non-free-flood sonar domes filled with seawater have the potential for transfer of nonindigenous species. These types of sonar domes are found on FFG 7 Class Navy frigates.

However, the non-indigenous species transfer potential is considered very low for the following

reasons: 1) the maintenance requiring sonar dome emptying and replenishment is normally

performed at the ship’s home port, so water taken on will be discharged in the same locality; 2)

most of the sonar domes have TBT on the interior surface because the ships were built prior to

1990; and 3) the residence time inside these sonar domes is long (on the order of 6 months),

making the probability of survival of non-indigenous species more remote.1

5.0 CONCLUSIONS

Discharges from sonar domes has a low potential for causing adverse environmental

effect. Although concentrations of organotins (MBT, DBT, and TBT), copper, nickel, and zinc

discharged from sonar dome interiors exceed water quality criteria mass loadings of these

substances are small (3.7, 23, 11, and 122 pounds per year, respectively). Exterior releases of

TBT are also expected to be small (12.6 pounds annually).
Sonar Dome Discharge

9

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 9

lists data sources for this report.

Specific References

1. UNDS Equipment Expert Meeting Minutes. Sonar Dome. September 10, 1996.

2. UNDS MPCD Practicability Meeting. Sonar Dome. June 26, 1997.

3. U.S. Navy. Marine Environmental Support Office, Naval Command, Control and Ocean

Surveillance Center RDT&E Division (NRaD). Sonar Dome Discharge Evaluation. San

Diego, California, February, 1997.

4. U.S. Navy. Pearl Harbor Naval Shipyard. Uniform National Discharge Standards

Information. Pearl Harbor, Hawaii. Memorandum, September 1996.

5. Norfolk Naval Shipyard. Uniform National Discharge Standards Information.

Portsmouth, Virginia. UNDS Questionnaire and Attachments, September 1996.

6. U.S. Navy. Naval Sea Systems Command (SEA 03VB). Tributyl Tin Contaminated

Sonar Dome Water. Arlington, Virginia. Memorandum to SEA 91W4 and SEA 03M, 29

April 1994.

7. Sharpe, Richard. Jane’s Fighting Ships. Jane’s Information Group, Ltd., 1996-97

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Sonar Dome Discharge

10

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Sonar Dome Discharge

11

Figure 1. SQS-26 Sonar Dome in the Cruiser Belknap (CG 26)
Sonar Dome Discharge

12

Figure 2. SQS-26 Sonar Dome on the Frigate Knox.
Sonar Dome Discharge

13

Figure 3. SQS-53 Transducer Housing on a Spruance-Class Destroyer.
Sonar Dome Discharge

14

Figure 4. Spherical, Bow-Mounted Array Housing for the BSY-2 Combat System.
Sonar Dome Discharge

15

Figure 5. Surface Ship Rubber Sonar Dome Prior to Installation.
Sonar Dome Discharge

16

Figure 6. Surface Ship Rubber Sonar Dome Layers.
Sonar Dome Discharge

17

Table 1. Types and Characteristics of Sonar Domes1,2,7

Sonar Type Ship Class No. of

Vessels

Dome

Material

Dome Water Volume

(gal, approx.)

Discharge Volume

per Event (est.)

AN/SQS-53 CG 47, DDG 51, DD

963, DDG 993

80 Rubber/TBT 24,000 30,000

AN/SQS-26 CGN 36, 38 3 Rubber/TBT 24,000 30,000

AN/SQS-56 FFG 7 43 Rubber/TBT 5,000 * 6,000

AN/BQQ-5 SSN 688 (through

750), SSN 637, SSN

671

47 GRP or steel 35,000 35,000

AN/BQQ-6 SSBN 726 17 GRP or steel 74,000 74,000

AN/BQR-7 SSN 640 2 GRP or steel 35,000 35,000

AN/BSY-1 SSN 688 (from 751) 23 GRP or steel 35,000 35,000

EM100 MSC T-AGS 51 2 GRP N/A * N/A (free flood)

EM1000 MSC T-AGS 60 (62 &

63)

2 GRP N/A * N/A (free flood)

EM121A MSC T-AGS 60 4 GRP 300 300**

SEABEAM MSC T-AGS 26 2 GRP 511 300**

TC-12NB MSC T-AGS 60 4 GRP 25 300**

TR-109 MSC T-AGS 60 4 GRP 75 300**

* Filled with seawater

** 300 gallons is representative of the two larger sonar dome types on MSC ships

Table 2. Sonar Dome Materials1,2

Component/Compound External to dome Internal to dome

Surface Ships Submarines Surface Ships Submarines

Tributyltin X X

Copper-nickel piping X X

Tin (other than TBT, DBT, MBT) X X

Zinc anodes X X

Glass-reinforced plastic X X X X

Steel components X X X X

Epoxy-based paints X X X

Rubber X X X X

Antifouling paint (Cu & other based) X X

Note: Not all surface ships have TBT internal or external to the sonar dome(s).
Sonar Dome Discharge

18

Table 3. Ships With TBT-Free Sonar Dome Interiors1,2

Class Vessels in Class Number in Class

CG 47 Class CG 51, CG 73 2 of 27 ships

DD 963 Class DD 972, 979, 987 3 of 31 ships

DDG 51 Class DDG 54, 56-67, 69, 71, 74 16 of 18 ships

DDG 993 Class DDG 993 1 of 4 ships

T-AGS 26, 51, 60 Classes All 8 of 8 ships

SSNs & SSBNs All 89 of 89 vessels

Based on equipment experts and sampling analysis results.

Table 4. Annual Sonar Dome Interior Discharge by Ship Class1,2,4,5,6

Ship Class Total

Ships

Ships with

Internal

TBT

Gallons per

Drainage

Event (est.)

Drainage

Events per

Year

Gallons per Year

(ships with internal

TBT*)

Gallons per

Year

(all vessels)

CG 47 27 25 30,000 2 1,500,000 1,620,000

CGN 36 2 2 30,000 2 120,000 120,000

CGN 38 1 1 30,000 2 60,000 60,000

DDG 51 18 3 30,000 2 180,000 1,080,000

DD 963 31 28 30,000 2 1,680,000 1,860,000

DDG 993 4 3 30,000 2 180,000 240,000

FFG 7 43 20 6,000 2 240,000 516,000

T AGS 8 0 300 2 0 4,800

SSN 637 13 0 35,000 1 0 455,000

SSN 640 2 0 35,000 1 0 70,000

SSN 671 1 0 35,000 1 0 35,000

SSN 688 56 0 35,000 1 0 1,960,000

SSBN 726 17 0 74,000 1 0 1,258,000

TOTAL: 223 82 N/A N/A 3,960,000 9,278,800

* Could have TBT inside sonar dome, based on Table 6.

N/A = not applicable

Table 5. Tributyltin Release Rates from Exterior of Sonar Domes3

Sampled Vessel Sample Date Tributyl tin (TBT)

Release Rate

μg/cm2/day grams/day

DDG 53 USS John Paul Jones 12-96 0.89 0.62

CG 59 USS Princeton 12-96 0.06 0.09

DD 976 USS Merrill 12-96 0.14 0.10

 Average: 0.36 0.27
Sonar Dome Discharge

19

Table 6. Constituent Concentrations in Sonar Dome Interior Discharge

(parts per billion, or μg/L, except as noted)3,4,5

Vessel

Date of

Sample

Tributyltin

(TBT)

Dibutyltin

(DBT)

Monobutyltin

(MBT)

Copper Nickel Tin Zinc

Chemical

Oxygen

Demand

Total

Suspended

Solids

Total

Organic

Carbon

CGN 40 USS Mississippi 2-7-94 85 - - - - - - - - -

DDG 52 USS John Barry 3-28-94 470 - - - - - - - - -

FF 1079 USS Bowen 4-1-94 82 - - - - - - - - -

CGN 37 USS South Carolina 5-23-94 - - - - - - - 170*** - -

CGN 37 USS South Carolina 5-23-94 - - - - - - - 120*** - -

CGN 37 USS South Carolina 5-23-94 - - - - - - - 20*** - -

CGN 37 USS South Carolina 5-23-94 - - - - - - - 180*** - -

DD 968 USS Radford 6-30-94 58 - - - - - - - - -

DD 968 USS Radford 6-30-94 35 - - - - - - - - -

CG 48 USS Yorktown 7-7-94 58 - - - - - - - - -

CG 74 USS Ticonderoga 7-25-94 48 - - - - - - - - -

DD 988 USS Thorn 8-26-94 41 - - - - - - - - -

DD 963 USS Spruance 12-1-94 14 33 5 - - - - - - -

DD 984 USS Leftwich 10-94 - - - 920 660 <DL 110 - - -

SSN 648 USS Aspro 11-94 - - - 220 <DL <DL 5390 - - -

SSN 717 USS Olympia 11-94 - - - 220 <DL <DL 1040 - - -

CG 73 USS Port Royal 1-95 - - - 1350 300 <DL 1520 - - -

SSN 672 USS Pintado 2-95 - - - 190 <DL 250 1870 - - -

SSN 697 USS Indianapolis 3-95 - - - 160 <DL 190 2370 - - -

FFG 37 USS Crommelin 4-95 - - - <DL <DL 210 <DL - - -

DDG 53 USS John Paul Jones 4-95 - - - 660 140 <DL 2900 - - -

FFG 37 USS Crommelin 5-95 - - - 190 160 <DL 1010 - - -

SSN 724 USS Louisville 6-95 - - - <DL <DL 160 130 - - -

SSN 677 USS Drum 7-95 - - - 130 <DL 260 5310 - - -

SSN 715 USS Buffalo 8-95 - - - <DL <DL 240 <DL - - -
Sonar Dome Discharge

20

Table 6. (Continued)

Vessel

Date of

Sample

Tributyltin

(TBT)

Dibutyltin

(DBT)

Monobutyltin

(MBT)

Copper Nickel Tin Zinc

Chemical

Oxygen

Demand

Total

Suspended

Solids

Total

Organic

Carbon

CG 65 USS Chosin 9-95 - - - 1630 590 <DL 2130 - - -

DDG 59 USS Russell 12-95 - - - <DL <DL <DL 180 - - -

DD 979 USS Conolly 1-31-96 - - - - - - - - <4*** 5***

DD 979 USS Conolly 1-31-96 - - - - - - - - <4*** 6***

DD 979 USS Conolly 1-31-96 - - - - - - - - <4*** 5***

DD 979 USS Conolly 1-31-96 - - - - - - - - <4*** 4***

DDG 60 USS Hamilton 1-96 - - - 180 <DL <DL 8300 - - -

SSN 675 USS Bluefish 1-96 - - - <DL 500 1100 260 - - -

DDG 60 USS Hamilton 1-96 - - - 450 <DL <DL 880 - - -

SSN 717 USS Olympia 3-96 - - - 100 <DL 290 570 - - -

SSN 715 USS Buffalo 3-96 - - - <DL <DL 280 830 - - -

FFG 57 USS Reuben James 5-96 - - - <DL <DL 100 300 - - -

SSN 752 USS Pasadena 6-96 - - - <DL 130 280 <DL - - -

SSN 680 USS Wm H. Bates 6-96 - - - <DL 100 310 220 - - -

DDG 56 USS John McCain 9-96 - - - 120 <DL <DL 630 - - -

DDG 53 USS John Paul Jones 12-96 36.67 - - - - - 1500 - - -

CG 59 USS Princeton 12-96 30.53 - - - - - 2600 - - -

DD 976 USS Merrill 12-96 0.62 - - - - - 800 - - -

DD 984 USS Leftwich 12-96 2.8 - - - - - - - - -

MINIMUM* 1 N/A** N/A** 50 50 50 50 20*** <4*** 4***

MAXIMUM 470 N/A** N/A** 1,630 660 1100 8,300 180*** <4*** 6***

AVERAGE* 74 33** 5** 303 145 194 1577 123*** <4*** 5***

A hyphen (-) denotes the sample was not analyzed for that parameter

DL = detection limit (50 μg/L)

N/A = not applicable

* Measurements below Detection Limit (DL) were set equal to the DL

** DBT and MBT based on only one sample

*** Units are mg/L
Sonar Dome Discharge

21

Table 7. Estimated Sonar Dome Mass Loadings

Constituent Loading (lbs/yr) Discharge Origin

External Internal

Copper 23.4 X

Nickel 11.2 X

Tin 15.0 X

Zinc 121.9 X

TBT 2.4 X

TBT 12.6 X

DBT 1.1 X

MBT 0.2 X

Table 8. Comparison of Measured Values in Sonar Dome Interior Discharge

with Water Quality Criteria (μg/L)

Constituent Mean / Max

Reported

Concentration

Federal

Acute WQC

Federal

Chronic WQC

Most Stringent

State Acute WQC

Most Stringent

State Chronic

WQC

TBT 74 / 470 0.37a0.01a0.001 (VA) 0.001 (VA)

Copper 303 / 1,630 2.4 2.4 2.4 (CT, MS) 2.4 (CT, MS)

Nickel 145 / 660 74 8.2 8.3 (FL, GA) 7.9 (WA)

Zinc 1,577 / 8,300 90 81 84.6 (WA) 76.6 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

CT = Connecticut

FL = Florida

GA = Georgia

MS = Mississippi

VA = Virginia

WA = Washington

a

 Proposed water quality criteria, August 7, 1997
Sonar Dome Discharge

22

Table 9. Data Sources

Data Source

NOD Report Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

Navy 3M MRC* X

2.2 Releases to the Environment Navy 3M MRC* X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate Design

Documentation

X X

3.3 Constituents Naval Shipyards X

3.4 Concentrations NRaD San Diego

4.1 Mass Loadings NRaD San Diego X

4.2 Environmental Concentrations X X

4.3 Potential for Introducing NonIndigenous SpeciesX

* MRC: Maintenance Requirement Card
Steam Condensate

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Steam Condensate
Steam Condensate

2

2.0 DISCHARGE DESCRIPTION

This section describes steam condensate discharge and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Many surface ships in the Navy and Military Sealift Command (MSC) use steam from

shore facilities when in port to operate auxiliary systems, such as laundry facilities, heating

systems, and other hotel services.1 Shore steam is piped above ground from land based boiler

plants at pressures between 100 and 150 pounds per square inch (psi) to connections on the pier.

The steam is routed via hoses from pier connections to topside connections on the ships.1 Within

the ship, the steam is routed through the ship’s auxiliary steam lines to the equipment. The heat

exchangers and shipboard piping are usually fabricated of copper/nickel alloy and carbon steel,

but can also contain titanium, copper, or nickel. Steam distribution systems on all naval ships

use comparable designs and consistent standards for system materials; therefore, there is little

variation in steam distribution and condensate collection system design between ships. In the

process of supplying heat to the ship systems, the steam cools and most condenses into water.

This condensed water is referred to as condensate.

The condensate passes through a series of traps and orifices and collects in insulated drain

collection tanks in the lowest points of the machinery spaces. The tanks are usually made of

carbon steel or galvanized carbon steel. When a ship is making its own steam, the condensate in

these drains is recycled as boiler feedwater. When taking on shore steam, this condensate is

discharged overboard because shore facilities do not have infrastructure to receive returned

condensate from ships. The condensate normally is pumped to a topside riser connection for

discharge overboard. The overboard discharge pump is controlled automatically, by means of a

float switch or similar device in the collection tank. In limited cases, the condensate is combined

with non-oily machinery wastewater in the non-oily machinery wastewater drain tank for

discharge overboard below the waterline. Discharge of steam condensate as a component of nonoily machinery wastewater is discussed in the non-oily machinery wastewater NOD report.

The naval facilities that provide shore steam to ships are designed and operated in

accordance with Navy standards.2 These facilities are required to sample and test shore steam

and provide certification to ships that the steam meets the following requirements:3

• pH 8.0 to 9.5

• conductivity 25 μmho/cm2 max. (micromhos per square centimeter)

• dissolved silica 0.2 ppm max. (parts per million)

• hardness 0.10 epm max. (equivalents per million)

• total suspended solids 0.10 ppm max.
Steam Condensate

3

2.2 Releases to the Environment

Steam condensate discharge can contain metals or treatment chemicals entrained in or

eroded from the shore facilities and ships’ steam systems. Steam condensate is discharged at

elevated temperatures relative to the receiving waters. The discharge can be periodic or

continuous based on the condensate flow rate, size of the condensate collection tank, and design

of the collection tank’s pumping control system. The discharge occurs 5 to 10 feet above the

waterline. A portion of the condensate flashes into steam when discharged at ambient air

pressure.

2.3 Vessels Producing the Discharge

Currently 179 Armed Forces surface ships discharge steam condensate. The classes and

numbers of Navy and MSC ships that discharge shore-supplied steam condensate overboard are

listed in Table 1. Submarines do not take on shore steam and do not discharge steam condensate

because the design of their steam systems do not provide shore steam connections. The U.S.

Coast Guard (USCG) does not discharge steam condensate because USCG vessels run their

auxiliary boilers on a continuous basis. Also, most USCG homeports do not have readily

available shore steam.1 Army, Air Force, and Marine Corps vessels do not discharge steam

condensate in port.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Steam condensate is discharged only in port when shore steam is supplied to ships. There

are 179 ships that produce steam condensate discharge located in 10 ports along the coastal U.S.

The larger ships producing this discharge are located in the ports of Norfolk, VA, Mayport, FL,

San Diego, CA, Pearl Harbor, HI, and Everett and Bremerton, WA. In some ports, the ships are

at several locations within the port instead of being centered at one set of piers.

3.2 Rate

The discharge rate of steam condensate is directly related to the amount of shore steam

provided per hour to a ship. Table 2 provides the total estimated heating load for each ship class.

These loads were obtained from a handbook on dockside utilities and reflect the sum of the

constant (year round, such as, galley, laundry, hot water) and intermittent (seasonal) heating

loads for the ship.2 This handbook contains estimated steam load requirements for various ship

classes at 10, 30, 50 and 70 degrees Fahrenheit (°F). For estimating purposes, the condensate
Steam Condensate

4

discharge volumes were based on an average outside air temperature of 50 °F (Table 2). A

survey of meteorological data indicates that the 50 °F data is estimated to represent the average

outside air temperature of most naval ports. Column (b) in Table 2 shows the equivalent number

of gallons per year of condensate discharged at 180 °F that was obtained by applying the

appropriate conversion factors to the figures in Column (a) and multiplying it by the number of

days in port as listed in Table 1 (taken from the Ship Movement Data4) as shown below.

Condensate Drain, gal/yr = (Loads, lbs/hr)(0.12 gal/lb)(24 hr/day)(No. of days in port per year)

Column (c) is obtained by multiplying the figures in Column (b) by the number of ships

in the class. Condensate flow rates for ships where steam requirement data was unavailable were

interpolated based on the ship’s size and similarities to other ship classes. Based upon the

calculations presented in Table 2 for an average air temperature of 50 °F, the average steam

condensate flow rate for all ship classes is 4,500 gallons per day per ship. As mentioned in

Section 2.2, a small portion of the condensate will flash to steam as it is discharged; however, no

data are available to determine the exact amount of the discharge that is steam. Therefore, to

provide an upper bound on the flow that will enter the water, it is assumed that all of the

discharge will be water.

3.3 Constituents

Steam condensate is primarily water that contains materials from the shore steam piping,

ship piping, and heat exchangers and boiler water chemicals. This discharge was sampled for

constituents that had a potential for being in the discharge. Based on the steam condensate

process, system designs, and analytical data available, analytes in the metals, organics, and

classicals classes were tested.1,5 Sampling was conducted on the LHD 1, CG 68, LSD 51, and TAO 198 in accordance with the Rationale for Discharge Sampling Report.5

 The results of the

sampling are provided in reference 6. Table 3 provides a list of all constituents and their

concentrations that were detected in the discharge. Discharges of steam condensate are expected

to be warmer than ambient water temperatures with a maximum overboard discharge temperature

of 180 °F because this is the maximum operational temperature that condensate discharge pumps

can withstand.

Antimony, arsenic, cadmium, copper, lead, nickel, selenium, thallium, zinc, benzidine

and bis(2-ethylexyl) phthalate are priority pollutants that were detected in this discharge. There

were no bioaccumulators detected in this discharge.

3.4 Concentrations

The concentrations of detected constituents are presented in Table 3. This table shows

the constituents, the log-normal mean, the frequency of detection for each constituent, the

maximum and minimum concentrations, and the mass loadings for each constituent. For the

purposes of calculating the log-normal mean, a value of one-half the detection limit was used for

nondetected results.
Steam Condensate

5

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria.

Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings

Based on the discharge volume estimates developed in Table 2, mass loadings are

presented in Table 3. Table 4 is present in order to highlight constituents with log-normal mean

concentrations that exceed water quality criteria. A sample calculation of the estimated annual

mass loading for copper is shown here:

Mass Loading for Copper (Dissolved)

Mass Loading = (Net Positive Log-normal Mean Concentration)(Flow Rate)

(13.44 μg/L)(3.785 L/gal)(296,000,000 gal/yr)(g/1,000,000 μg)(lb/453.593 g) ≅ 33 lbs/yr

4.2 Environmental Concentrations

The constituent concentrations in the steam condensate discharge and their corresponding

Federal and the most stringent state water quality criteria (WQC) are listed in Table 5. The

copper and nickel concentrations exceed the Federal and the most stringent state WQC.

Ammonia, nitrogen (as nitrate/nitrite and total kjeldahl nitrogen), and phosphorous exceeds the

Hawaii WQC. Benzidine and bis(2-ethylhexyl) phthalate exceed the Georgia WQC.

4.3 Thermal Effects

The potential for steam condensate to cause thermal environmental effects was evaluated

by modeling the thermal plume generated by the discharge and then comparing the model results

to state thermal discharge water quality criteria. Thermal plumes from steam condensate

discharge were modeled primarily using the Cornell Mixing Zone Expert System (CORMIX)

model. Additional modeling of discharge plume characteristics was conducted using CH3D, a

three-dimensional hydrodynamic and transport model. The models were used to estimate the

plume size and temperature gradients in receiving water bodies.7, 8 Modeling was performed for

discharges from an aircraft carrier (CVN – 68 Class) and an underway replenishment vessel

(AOE-1 Class).

The discharge plumes were modeled for the Navy ports in Norfolk, VA and Bremerton,

WA. Virginia and Washington State are the only states that have established thermal mixing

zone criteria in the form of allowable plume dimensions and ambient temperature increases in the

receiving water body. Other coastal states require thermal mixing zones be established on a case-
Steam Condensate

6

by-case basis during the discharge permitting process, taking into account site- and dischargespecific information. Typically, criteria are developed to restrict the increase in the ambient

water temperature and the extent of the plume in the water body to limit the duration of exposure

for organisms passing through the plume, to prevent mortalities of bottom-dwelling organisms,

and to prevent long-term effects such as migratory or community changes. State criteria for

Virginia and Washington are summarized in Table 6.

The Virginia thermal regulations state that the discharge shall not cause the receiving

ambient water temperature to increase by more than 3 °C at the edge of an allowable mixing

zone. Virginia’s allowable mixing zone for a thermal plume permits the plume to extend over no

more than one-half the width of the receiving watercourse. In addition, the plume shall not

extend downstream a distance greater than five times the width of the receiving watercourse at

the point of discharge.7

The Washington thermal criteria vary depending upon the waterbody classification

established by the State. The water in the vicinity of the Navy port at Bremerton has been

classified by Washington as a Class A waterbody. The State thermal criteria for a Class A

waterbody requires that discharges shall not result in the receiving water temperature exceeding

16 °C at the edge of an allowable mixing zone. If the water temperature exceeds 16 °C due to

natural conditions, no discharge shall raise the receiving water temperature by greater than 0.3 °C

at the edge of an allowable mixing zone. If the water temperature does not exceed 16 °C due to

natural conditions, the Washington criteria provide a formula to determine the allowable

incremental temperature increase at the mixing zone boundary. Washington has established the

mixing zone to permit the plume to extend over a horizontal distance no greater than 200 feet

plus the depth of the water over the discharge point, and no greater than 25% of the width of the

water body.7

The aircraft carrier and amphibious vessel were modeled for Norfolk in winter conditions

because these situations result in the greatest steam condensate discharge. Modeling for

Bremerton was performed for all months of the year because, while cold (i.e., winter) conditions

result in the greatest flow rate, the warm (i.e., summer) conditions result in the lowest allowable

temperature increase.

Based on the CORMIX modeling, steam condensate discharges do not exceed Virginia

thermal mixing zone criteria. CORMIX model predictions do indicate that steam condensate

discharge from an aircraft carrier into the inlet in Bremerton can exceed Washington’s thermal

mixing zone criteria. The model predictions indicate that the discharge from AOE-1 Class

vessels are not expected to exceed criteria. The AOE-1 Class is the next largest generator of

steam condensate typically found in Bremerton.

There are several real-world considerations applicable to this discharge that CORMIX is

not designed to simulate. These limitations result in over-conservative predictions. Such

considerations include the effect of tidal action and turbulent mixing beyond the plunge zone (i.e.

area of initial mixing from a discharge above the waterline) on the discharge plume. The

additional mixing from tidal action and turbulence would be expected to reduce plume size. In
Steam Condensate

7

addition, when applied to steam condensate discharge, CORMIX underestimates the initial

mixing that occurs when the discharge enters the water. Since the version of CORMIX used for

this exercise is designed for submerged release, the modeling effort was performed assuming the

discharge hose touches the water surface. The fact that the discharge is known to occur 5-10 feet

above the surface could not be simulated. The result is that the entry velocity assigned by

CORMIX, based on flow rate and discharge pipe diameter, does not reflect accurately the true

entry velocity, which is expected to be greater due to the acceleration from gravity. With higher

entry velocities, the initial mixing would be greater and the plume size would be smaller. To

illustrate, the CORMIX prediction for Bremerton Harbor estimates a plume depth of only 4 cm

based on an initial discharge velocity of 1.67 meters per second (m/s). If the acceleration due to

gravity from a 5-10 foot drop were considered, the entry velocity would increase significantly, to

5.7 m/s. The resulting plume depth would be considerably deeper and would result is more

mixing with receiving water. Another occurrence that the CORMIX model can not simulate is

the loss of heat to the atmosphere, especially during free-fall.

Because of the CORMIX model limitations for this discharge, the Navy and EPA

modeled the steam condensate thermal plume from an aircraft carrier in Bremerton Harbor using

the hydrodynamic and transport model CH3D. CH3D is expected to predict more accurately the

plume dimensions than CORMIX because CH3D simulates the mixing of the buoyant plume

with ambient flows by ways of advection and turbulent mixing both horizontally and vertically in

the water column. CH3D is still expected to provide an overestimate of the plume size because

this model does not account for the full extent of initial mixing in the plunge zone. CH3D

estimates that the thermal plume for an aircraft carrier moored at the pier at Bremerton would

extend a distance of 80 m from the discharge port along the vessel hull, not extending past the

end of the hull. The plume would also extend outward no more than a distance of 30 m from the

vessel hull at any point along the hull. CH3D predicts that, during the first 24 hours after

discharge, the plume would cover only 5% of the width, 2% of the length, and 0.07% of the total

surface of Sinclair Inlet.

Although the modeling described above indicates that the thermal plume from steam

condensate released from an aircraft carrier may exceed Washington criteria in a small, localized

area, the EPA and Navy do not consider that the plume results in a significant environmental

impact. Such a localized plume would have a low potential for interfering with the passage of

aquatic organisms in the water body and would have a limited impact on the organisms that

reside in the upper water layer (sea surface boundary layer). In addition, because the discharge is

freshwater (no salinity) and warmer than the receiving water, the plume floats in the surficial

layer of the water body and has no impact on bottom-dwelling organisms. Therefore, EPA and

DOD do not consider that the thermal loads from steam condensate discharge have the potential

to cause an adverse environmental impact.
Steam Condensate

8

4.4 Potential for Introducing Non-Indigenous Species

This discharge does not present the potential for the transport of non-indigenous species

because: the source of the steam is potable water from the same geographic area; it is discharged

in the same vicinity; and it enters the ship as steam above 212 °F.

5.0 CONCLUSIONS

Steam condensate discharge has a low potential to cause an adverse environmental

impact. This conclusion is based on the following two findings:

1) Although concentrations of copper, nickel, benzidine, bis(2-ethylhexyl) phthalate,

phosphorous, and nitrogen exceed the most stringent water quality criteria, the

mass loadings for these constituents are small. The distribution of the ships

among several ports and within the ports themselves disperses the discharge

(multiple discharge points) into a variety of receiving waters.

2) There are only two states that have established thermal mixing zone criteria in the

form of codified plume dimensions (Washington and Virginia). The thermal

criteria of other coastal states require thermal mixing zones be established on a

case-by-case basis during the permitting process. The discharge is predicted to

meet Virginia and Washington State thermal criteria with the exception of an

aircraft carrier in the port at Bremerton, Washington.. However, conservative

modeling of discharge from an aircraft carrier at Bremerton predicts thermal

plumes that would cover only 5% of the width, 2% of the length, and 0.07% of

the total surface of Sinclair Inlet. Since the plume is restricted to such a localized

area, the EPA and DoD do not consider that the plume results in an adverse

environmental impact and no further analyses are required.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained.

Information from a military handbook on dockside services was used to calculate the rate of

discharge. Sampling data from four surface ships provided concentrations, and mass loadings

were calculated from the rate and the concentrations. Table 7 shows the sources of data used to

develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Steam Condensate Drain, September 12,

1996.

2. Military Handbook - 1025/2, Dockside Utilities for Ship Service, 1 May 1988.
Steam Condensate

9

3. Naval Ship’s Technical Manual (NSTM), Chapter 220, Vol. 2, Revision 7, Boiler

Water/Feed Water Test & Treatment. pp 22-6, 22-7, and 22-50. December 1995.

4. Pentagon Ship Movement Data for Years 1991-1995, March 4, 1997.

5. UNDS Rationale for Discharge Sampling, Undated.

6. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

7. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed

Services. Versar, Inc. July 3, 1997.

8. NAVSEA. Supplemental Thermal Effects Analysis. March 1999.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.
Steam Condensate

10

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Baumeister, Theodore; Avallone, Eugene; Baumeister III, Theodore; Marks' Standard Handbook

for Mechanical Engineers, Eighth Edition. McGraw-Hill Book Company, 1978. .

Rawson, K.J.; and E.C. Tupper. Basic Ship Theory 2, Second Edition, Longman Group London

and New York. 1978.

Jane's Information Group, Jane's Fighting Ships. Capt. Richard Sharpe, Ed. Sentinel House:

Surrey, United Kingdom, 1996.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. 23 March 1995.

Summary of Meteorological Data to Determine Air and Water Temperatures, October 1997.

UNDS Ship Database, August 1, 1997.
Steam Condensate

11

Table 1. Vessel Classes Generating Steam Condensate Discharge

VESSEL

CLASS

VESSEL DESCRIPTION QUANTITY OF

VESSELS PER

CLASS

NUMBER OF

DAYS IN PORT

PER YEAR

CVN 68 Nimitz Class Aircraft Carriers 7 147

CV 63 Kitty Hawk Class Aircraft Carriers 3 137

CVN 65 Enterprise Class Aircraft Carriers 1 76

CV 59 Forrestal Class Aircraft Carriers 1 143

CG 47 Ticonderoga Class Guided Missile Cruisers 27 166

CGN 38 Virginia Class Guided Missile Cruiser 1 161

CGN 36 California Class Guided Missile Cruisers 2 143

DDG 993 Kidd Class Guided Missile Destroyers 4 175

DD 963 Spruance Class Destroyers 31 178

AGF 11 Austin Class Miscellaneous Command Ship 1 183

AGF 3 Raleigh Class Miscellaneous Command Ship 1 183

LCC 19 Blue Ridge Class Amphibious Command Ship 2 179

LHD 1 Wasp Class Amphibious Assault Ship 4 185

LHA 1 Tarawa Class Amphibious Assault Ship 5 173

LPH 2 Iwo Jima Class Amphibious Assault Ship 2 186

LPD 4 Austin Class Amphibious Transport Docks 3 178

LSD 49 Harpers Ferry Class Dock Landing Ships 3 170

LSD 41 Whidbey Island Class Dock Landing Ships 8 170

LSD 36 Anchorage Class Dock Landing Ships 5 215

MCM 1 Avenger Class Mine Countermeasures Vessels 14 232

T-AE 26 Kilauea Class Ammunition Ships 8 26

T-AFS 1 Mars Class Combat Stores Ships 8 148

AO 177 Jumboised Cimarron Class Oilers 5 188

T-AO 187 Henry J. Kaiser Class Oilers 12 78

AOE 1 Sacramento Class Fast Combat Support Ships 4 183

AOE 6 Supply Class Fast Combat Support Ships 3 114

T-AG 194 Mission Class Navigation Research Ships 2 151

T-AGM 22 Compass Island Class Missile Range Instrumentation Ships 1 133

T-ARC 7 Zeus Class Cable Repairing Ships 1 8

ARS 50 Safeguard Class Salvage Ships 4 208

T-AH 19 Mercy Class Hospital Ships 2 184

AS 33 Simon Lake Class Submarine Tenders 1 229

AS 39 Emory S Land Class Submarine Tenders 3 293

Notes:

 Number of days inport per year for each ship class taken from the Ship Movement Database.

 Vessel classes receiving shore steam are identified in Military Handbook 1025/2, Dockside Utilities for Ship

Service.
Steam Condensate

12

Table 2. Steam Condensate Discharge By Vessel Class At Outdoor Temperatures of 50 Degrees F

VESSEL CLASS ACTIVE

(a)

Total Heating Load in

lbs/hr per vessel

(b)

Condensate Drain in

gallons/yr per vessel

(c)

Condensate Drain in

gallons/yr per vessel class

CVN 68 7 15,000 6,582,090 46,074,627

CV 63 3 13,000 5,316,418 15,949,254

CVN 65 1 15,000 3,402,985 3,402,985

CV 59 1 13,000 5,549,254 5,549,254

CG 47 27 1,100 545,075 14,717,015

CGN 38 1 3,400 1,634,030 1,634,030

CGN 36 2 3,400 1,451,343 2,902,687

DDG 993 4 1,800 940,299 3,761,194

DD 963 31 1,800 956,418 29,648,955

AGF 11 1 2,650 1,447,612 1,447,612

AGF 3 1 2,650 1,447,612 1,447,612

LCC 19 2 7,700 4,114,328 8,228,657

LHD 1 4 6,300 3,479,104 13,916,418

LHA 1 5 6,300 3,253,433 16,267,164

LPH 2 2 5,800 3,220,299 6,440,597

LPD 4 3 4,400 2,337,910 7,013,731

LSD 49 3 3,600 1,826,866 5,480,597

LSD 41 8 3,600 1,826,866 14,614,925

LSD 36 5 3,600 2,310,448 11,552,239

MCM 1 14 1,000 692,537 9,695,522

T-AE 26 8 2,300 178,507 1,428,060

T-AFS 1 8 3,350 1,480,000 11,840,000

AO 177 5 3,350 1,880,000 9,400,000

T-AO 187 12 3,350 780,000 9,360,000

AOE 1 4 5,600 3,059,104 12,236,418

AOE 6 3 5,600 1,905,672 5,717,015

T-AG 194 2 1,500 676,119 1,352,239

T-AGM 22 1 2,700 1,071,940 1,071,940

T-ARC 7 1 2,700 64,478 64,478

ARS 50 4 500 310,448 1,241,791

T-AH 19 2 500 274,627 549,254

AS 33 1 6,500 4,443,284 4,443,284

AS 39 3 6,500 5,685,075 17,055,224

Total = 295,504,776

Notes:

 Source: Military Handbook 1025/2, Dockside Utilities for Ship Service.

 Total heating load values include constant loads and intermittent loads.

 Intermittent loads were taken at 50 °F outside air temperature.

 Calculations based on water at 212 °F.
Steam Condensate

13

Table 3. Summary of Detected Analytes

Constituent Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Mass

Loading

CLASSICALS (mg/L) (mg/L) (mg/L) (lbs/yr)

Alkalinity 2.78 4 of 4 1 15 6,852

Ammonia as Nitrogen 0.18 4 of 4 0.12 0.37 444

Biochemical Oxygen Demand 6.56 3 of 4 BDL 21 16,169

Chemical Oxygen Demand

(COD)

16.87 2 of 4 BDL 54 41,581

Chloride 3.60 3 of 4 BDL 14 8,873

Nitrate/Nitrite 0.44 4 of 4 0.3 0.81 1,085

Sulfate 1.98 3 of 4 BDL 3.6 4,880

Total Dissolved Solids 18.9 2 of 4 BDL 102 46,585

Total Kjeldahl Nitrogen 0.80 4 of 4 0.24 2 1,972

Total Organic Carbon (TOC) 4.07 3 of 4 BDL 12 10,032

Total Phosphorous 0.09 3 of 4 BDL 0.27 222

Total Recoverable Oil and

Grease

1.15 4 of 4 0.6 2.3 2,835

Total Sulfide (Iodometric) 13.3 4 of 4 4 40 32,880

Volatile Residue 18.9 2 of 4 BDL 102 46,585

METALS (μg/L) (μg/L) (μg/L) (lbs/yr)

Antimony

 Total 7.13 1 of 4 BDL 26.8 18

Arsenic

 Total 0.74 2 of 4 BDL 2.3 2

Barium

 Dissolved 1.02 1 of 4 BDL 4.4 3

 Total 0.8 1 of 4 BDL 1.65 2

Cadmium

 Total 2.86 1 of 4 BDL 6.1 7

Calcium

 Dissolved 98.6 3 of 4 BDL 336 243

 Total 146 4 of 4 61.6 334 359

Copper

 Dissolved 13.4 2 of 4 BDL 49.0 33

 Total 20.1 3 of 4 BDL 91.0 49

Iron

 Dissolved 20.0 2 of 4 BDL 262 49

 Total 22.6 2 of 4 BDL 527 56

Lead

 Dissolved 3.58 3 of 4 BDL 12.7 9

 Total 4.38 3 of 4 BDL 18.9 11

Magnesium

 Dissolved 77.8 1 of 4 BDL 982 192

 Total 77.2 1 of 4 BDL 949 190
Steam Condensate

14

Constituent Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Mass

Loading

METALS (μg/L) (μg/L) (μg/L) (lbs/yr)

Manganese

 Dissolved 1.17 2 of 4 BDL 6 3

 Total 2.57 4 of 4 1.85 5.1 6

Molybenum

 Dissolved 1.72 1 of 4 BDL 3.7 4

Nickel

 Dissolved 10.3 1 of 4 BDL 22 25

 Total 11.6 1 of 4 BDL 34.7 28

Selenium

 Total 2.87 1 of 4 BDL 3.5 7

Sodium

 Dissolved 482 3 of 4 BDL 8220 1,188

 Total 432 2 of 4 BDL 8280 1,065

Thallium

 Dissolved 1.18 2 of 4 BDL 13.3 3

Titanium

 Total 2.73 1 of 4 BDL 6.4 7

Vanadium

 Dissolved 5.25 1 of 4 BDL 10.5 13

Zinc

 Dissolved 13.94 4 of 4 7.15 21.9 34

 Total 11.35 3 of 4 BDL 23.0 28

ORGANICS (μg/L) (μg/L) (μg/L) (lbs/yr)

4-Chloro-3-Methylphenol 6.84 1 of 4 BDL 30 17

Benzidine 32.8 1 of 4 BDL 73.5 81

Bis(2-Ethylhexyl) Phthalate 19.4 2 of 4 BDL 112 48

BDL = Below Detection Limit

Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or

more samples with the analyte below detection levels (i.e., “non-detect” samples), estimated analyte concentrations

equivalent to one-half of the detection levels were also used to calculate the log-normal mean. For example, if a

“non-detect” sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the lognormal mean calculation.
Steam Condensate

15

Table 4. Estimated Annual Mass Loadings of Constituents

Constituent* Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Mass

Loading

CLASSICALS (mg/L) (mg/L) (mg/L) (lbs/yr)

Ammonia as Nitrogen 0.18 4 of 4 0.12 0.37 444

Nitrate/Nitrite 0.44 4 of 4 0.3 0.81 1085

Total Kjeldahl Nitrogen 0.80 4 of 4 0.24 2 1972

Total NitrogenA1.24 3057

Total Phosphorous 0.09 3 of 4 BDL 0.27 222

ORGANICS (μg/L) (μg/L) (μg/L) (lbs/yr)

Benzidine 32.8 1 of 4 BDL 73.5 81

Bis(2-Ethylhexyl) Phthalate 19.4 2 of 4 BDL 112 48

METALS (μg/L) (μg/L) (μg/L) (lbs/yr)

Copper

 Dissolved 13.4 2 of 4 BDL 49.0 33

 Total 20.1 3 of 4 BDL 91.0 49

Nickel

 Dissolved 10.3 1 of 4 BDL 22 25

 Total 11.6 1 of 4 BDL 34.7 28

* Mass loadings are presented for constituents that exceed WQC. See Table 3 for a complete listing of mass

loadings.

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Steam Condensate

16

Table 5. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Constituent Log-normal

Mean

Minimum

Concentration

Maximum

Concentration

Federal

Chronic WQC

Most Stringent State

Chronic WQC

(μg/L) (μg/L) (μg/L) (μg/L) (μg/L)

Ammonia as

Nitrogen

180 120 370 None 6 (HI)A

Nitrate/Nitrite 440 300 810 None 8 (HI)A

Total Kjeldahl

Nitrogen

800 24 2000 None -

Total NitrogenB1240 None 200 (HI)A

Total Phosphorous 90 BDL 270 None 25 (HI)A

Benzidine 32.8 BDL 73.5 None 0.000535 (GA)

Bis(2-Ethylhexyl)

Phthalate

19.4 BDL 112 None 5.92 (GA)

Copper

 Dissolved 13.4 BDL 49.0 2.4 2.4 (CT, MS)

 Total 20.1 BDL 91.0 2.9 2.9 (GA, FL)

Nickel

 Dissolved 10.3 BDL 22 8.2 8.2 (CA, CT)

 Total 11.6 BDL 34.7 8.3 7.9 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA = California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington

BDL = Below Detection Limit
Steam Condensate

17

Table 6. Summary of Thermal Effects of Steam Condensate Discharge

Ship

Modeled

Discharge

Temp

(°F)

Average

Air Temp

(°F)

Discharge

Flow

(gallons per

hour)

Ambient

Winter

Water

Temp (°F)

Predicted

Plume Length

(m)

Allowable

Plume

Length (m)

Predicted

Plume

Width (m)

Allowable

Plume Width

(m)

Washington State (1.5°C ΔT)

CVN* 180 50 1,866 50 80 73 30 400

AOE 180 50 672 50 2.3 73 10** 400

Virginia (3.0°C ΔT)

CVN 212 40 2,207 40 689 32,000 203 3,200

LCC 212 40 1,007 40 180 32,000 70.1 3,200

Note: Flow rates for Virginia were calculated based on a linear interpolation of the data available

in reference 2 for 30°F and 50°F air temperature.

*Indicates CH3D model predictions after the first 24 hours after discharge. All other

predictions are based on CORMIX model results.

**CORMIX output displays the plume width to the point where ΔT ≅ 0°C.

Table 7. Data Sources

Data Sources

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Thermal Effects X X

4.4 Potential for Introducing NonIndigenous SpeciesX
Stern Tube Seals & Underwater Bearing Lubrication

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Stern Tube Seals & Underwater Bearing Lubrication
Stern Tube Seals & Underwater Bearing Lubrication

2

2.0 DISCHARGE DESCRIPTION

This section describes the stern tube seals and underwater bearing lubrication discharge

and includes information on: the equipment that is used and its operation (Section 2.1), general

description of the constituents of the discharge (Section 2.2), and the vessels that produce this

discharge (Section 2.3).

2.1 Equipment Description and Operation

Vessels of the Armed Forces have one or two propeller shafts, except for aircraft carriers,

which have four shafts. Stern tube seals, stern tube bearings, and intermediate and main strut

bearings are components associated with the propeller shaft. Figure 1 shows the location of these

components. The stern tube seals prevent seawater entry into the vessel at the inboard end of the

stern tube bearing. Stern tube bearings support the weight of the propeller shaft where the shaft

exits the vessel. Intermediate and main strut bearings are outboard bearings that support the

weight of the propeller and shafting outboard of the vessel. Submarines do not have strut

bearings. Instead, submarines have a self-aligning bearing aft of the stern tube that supports the

weight of the propeller. Both stern tube and strut bearings are constructed with a bronze backing,

and lined with rubber strips (called staves), or babbitt metal. Babbitt is an alloy of tin and lead

and is commonly used as a bearing material. However, babbitted bearings are oil lubricated and

the lube oil is circulated in a closed system with no discharge to the environment. Babbitt wear

material is collected in the oil filter of stern tube oil lubricated systems. Depending on the vessel

type, lubrication for the stern tube seals, stern tube, and strut bearings is accomplished by

seawater, freshwater, or oil.1

Some small boats and crafts use surrounding seawater for cooling and a greased bearing

for lubrication. As such, the surrounding seawater is at a greater pressure than the greased

bearing on small boats, and if there is any leakage, seawater will leak into the bilge of the small

boat instead of the grease being discharged to the surrounding seawater. Any grease released into

the bilge of small boats and crafts is discussed in the Surface Vessel Bilgewater/OWS Discharge

NOD report.

2.1.1 Seawater Lubrication

Seawater lubrication is used in all Navy and U.S. Coast Guard (USCG) vessels. Seawater

is supplied from either the firemain or auxiliary machinery cooling water system on surface ships

and is supplied from the auxiliary seawater system on submarines. Submarines flood their trim

tanks with seawater and use this water to cool and lubricate the stern tube seals while in port.

For all surface ships and submarines, seawater enters a seal cavity, where some of it is used to

lubricate the seal faces. The remainder passes aft through channels between staves in the stern

tube bearing, cooling and lubricating the bearing, and finally exiting to the sea at the aft end of

the bearing. Seawater flow through the stern tube bearing is maintained at all times, except when

conducting maintenance or disassembly, regardless of whether the vessel is in port or underway.

The residence time of the seawater flow is short. For example, the residence time of water in the

stern tube of a DDG 51 Class ship is approximately 13 seconds.2 Similar short residence times
Stern Tube Seals & Underwater Bearing Lubrication

3

for stern tube lubricating water on other vessel classes is expected. Strut bearings are not

provided with forced cooling or lubrication. Instead, strut bearings use the surrounding seawater

flow for lubrication and cooling when the vessel is underway.

On surface vessels, copper-nickel alloy (70% copper/30% nickel) piping is normally used

for the stern tube seal lubrication system. On submarines, nickel/chromium piping is used. The

lubricating seawater also comes into contact with the propeller shaft, bearing surfaces, zinc

anodes, bearing staves, the seals, and bearing bushings.

Shafts are made of forged steel. Bearing surfaces are sleeved with copper-nickel (80%

copper / 20% nickel) or fiberglass. Zinc anodes provide corrosion protection in the bearing

housings. Stern tube and strut bearing staves are made of bonded synthetic rubber (typically

Buna-N (nitrile)). The estimated life of the staves is 5 to 7 years. Although the staves surround

the shaft on all sides, the bottom staves (approximately 40% of the staves) support the shaft

weight and are susceptible to maximum wear. In submarines, the wear rate of the rubber is

approximately 10 to 20 mils (one mil equals 0.001 inch) per year. In surface vessels with

controllable pitch propellers, the wear rate is 40 mils per year, and in surface vessels with fixed

pitch propellers, the wear rate is 20 to 30 mils per year.3

The rotating seat of a typical stern tube seal on a surface vessel is made of phosphor

bronze (an alloy of bronze and phosphorous). The stationary face insert was originally made of

Teflon-impregnated asbestos. However, a majority of the asbestos components have been

replaced with a phenolic material.1 Seals used in submarines are comprised of silicon carbide

and carbon graphite because they are exposed to more severe operating conditions. The life of

stern tube seals is approximately 5 years and they have a very small area exposed to wear,

compared to the bearings. Therefore, wear products from seal components constitute a very

small percentage of this discharge.

The lubricated components of a propeller shaft are shown in Figure 1. A cross-section

diagram of a typical seal is provided as Figure 2.

2.1.2 Freshwater Lubrication

On very rare occasions in port, freshwater may be used for lubricating the shaft seal on

submarines. This occurs on approximately four submarines per year, for one week each.4

Normally, while a submarine is in port, shaft seal lubrication is provided from seawater stored in

the submarine’s trim system. After an extended in port period, this supply of seawater will

eventually become depleted. At that time, freshwater is used to fill the trim system to provide

shaft seal lubrication. On these occasions, a potable water fill hose from the pier is connected to

the trim tank. This freshwater is typically mixed with the residual seawater in the tank (estimated

at a 50% mixture of seawater and freshwater), and is used for lubricating the shaft seals. The

cooling water is discharged to the sea in the manner described in Section 2.1.1.
Stern Tube Seals & Underwater Bearing Lubrication

4

2.1.3 Ambient Water Lubrication

All Army watercraft use ambient water for lubrication of stern tube seals and underwater

bearings. Ambient water, either freshwater or saltwater, is used in all operational locations,

depending upon where the vessel is located (i.e., in fresh or saltwater). Army watercraft do not

use potable water for lubrication while in port and do not use pressurized water to force feed

underwater bearings.

2.1.4 Oil Lubrication

A number of Military Sealift Command (MSC) vessels are fitted with oil-lubricated stern

tube and strut bearings, which do not produce any of the discharge described in this report. Oillubricated seals exist in a variety of configurations. All have anti-pollution design features, that

prevent oil from leaking to the sea under normal operating conditions.5 On the T-AO 187 Class

ships, each of the two shaft systems contains 2,300 gallons of oil. Some common system design

features to prevent oil releases are:1

• Use of multiple sealing rings at both the inboard and outboard ends of the stern tube.

• Methods to maintain pressure in the stern tube cavity lower than the sea water pressure

outside. This ensures that, in the event that the outboard seal leaks, water will leak into

the cavity rather than oil leaking out. Any water which accumulates as a result of a leak

into the cavity is managed as Surface Vessel Bilgewater/OWS Discharge.

• Positive methods for determining seal leakage.

2.2 Releases to the Environment

For surface vessels, this discharge consists of seawater from the firemain system or

auxiliary machinery water cooling water system with the additional constituents described in

Section 2.1 that are entrained as the seawater flows through the system. The lubricating water is

released to the environment through the after end of the stern tube bearing. In the case of

submarines, the discharge will occasionally consist of freshwater with chlorine.

2.3 Vessels Producing the Discharge

Almost all classes of surface vessels and submarines of the Armed Forces have shaft seals

and bearings that require lubrication. The exceptions are a few vessel classes such as the MHC

51 Class, that use unconventional means of propulsion such as cycloidal propellers.1 Army

watercraft use packing rings to seal hull penetrations of the shaft and do not use mechanical seals

for this purpose.
Stern Tube Seals & Underwater Bearing Lubrication

5

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Flow of water through the shaft seals and stern tube bearings is maintained at all times.

Therefore, this discharge occurs both within and beyond 12 nautical miles (n.m.).

3.2 Rate

3.2.1 Seawater Lubrication

For surface ships, flow rates of seawater through the stern tube bearing are approximately

2 gallons per minute (gpm) per foot of bearing length and 3 gpm for seal lubrication. The

seawater flow rate through submarine shaft seals while underway is 16 gpm for SSN 688 Class

and 18 gpm for SSBN 726 Class submarines. A discharge of 10 to 20 gpm per shaft is typical for

most vessels.1 For purposes of this report, a flow rate of 20 gpm has been used. It was assumed

that there are 274 surface ships, each with two shafts and 89 submarines, each with one shaft.

Based on operational knowledge, 5% of the vessels’ underway time is spent within 12 n.m. and

50% of the vessels’ time is spent pierside.6 These are conservative estimates, because most

vessels have flow rates that are lower than 20 gpm and though there are 24 four-shaft vessels in

the Navy, there are 65 single-shaft vessels that were considered to be two-shaft vessels. Thus,

this analysis overestimates the number of shafts producing this discharge by 17. When surface

ships are idle in port, full water flow is maintained through the stern tube bearing and seals. The

total annual fleetwide discharge volume was calculated as follows:

Total fleetwide annual discharge (gallons/year) = (20 gallons/minute flow rate) (60 min/hr) (24

hr/day) (365 days/year) [(274 surface ships) (2 shafts/ship) + (89 submarines) (1 shaft per

submarine)] (0.55 (5% of vessel’s underway time is within 12 n.m. and 50% of vessels’ time is in

port)) = 3,682,879,200 gal/year

3.2.2 Freshwater Lubrication

When submarines are idle in port, flow is maintained at 4 gpm for attack submarines (e.g.

SSN 688 Class) and 9 gpm for Missile Submarines (e.g. SSBN 726 Class).3,7 Approximately

81% of active submarines are attack submarines (SSNs) and 19% are ballistic missile submarines

(SSBNs). Hence, the weighted freshwater flow rate per submarine is approximately (0.81)(4

gpm) + (0.19)(9 gpm) ≈ 5 gpm.
Stern Tube Seals & Underwater Bearing Lubrication

6

Total fleetwide annual discharge (gallons/year) = (5 gallons/minute flow rate) (60 min/hr) (24

hr/day) (7 days/year) (1 week per year) [(4 submarines) (1 shaft per submarine)] = 201,600

gal/year

3.3 Constituents

3.3.1 Seawater Lubrication

Seawater for lubrication of stern tube bearings is supplied either from the firemain or the

auxiliary seawater cooling main, depending on the vessel class. Additional information on

firemain systems and the seawater cooling system can be found in their respective NOD reports.

When the shaft is turning, the most likely constituent to be present in the discharge is

rubber. Metals, if any, can be present in the discharge and include copper and nickel, the

materials of construction of the stern tube. The priority pollutants in this discharge include

copper and nickel. None of the potential constituents in this discharge are bioaccumulators.

3.3.2 Freshwater Lubrication

Because the shaft is not turning under idle conditions, there is no wearing of the bearing

materials. The freshwater from the port facility is typically chlorinated for disinfection.

Therefore, the discharge could contain small amounts of chlorine plus the same priority

pollutants listed in Section 3.3.1. None of the potential constituents are bioaccumulators.

3.4 Concentrations

Firemain and freshwater are used to lubricate stern tube seals and bearings. The

lubricating water briefly contacts the bearings and seals when compared to the rest of the

firemain; the firemain piping system is much longer than the length of the stern tubes (5.5 feet

each) and hence the residence time of seawater in the firemain system is much greater than the 13

second residence time in the stern tube seal and bearing lubrication system of a typical surface

vessel. Freshwater data were also used.

3.4.1 Seawater Lubrication

The concentrations of the constituents, as shown in Table 2, were estimated using

corrosion rates for the materials of construction, the surface area of the materials exposed to

seawater, and the rate of seawater lubricating the stern tube.2

3.4.2 Freshwater Lubrication

Water treatment plants typically add sufficient chlorine or monochloramine so that the

finished water leaving the plant has a total residual chlorine (TRC) level of approximately 2.0

mg/L.8 As water flows through the distribution system, TRC is depleted through its bactericidal

action and due to reactions with other chemicals in the water and on piping and other surfaces.
Stern Tube Seals & Underwater Bearing Lubrication

7

By the time the water reaches the tap, TRC levels have been reduced to approximately 1.0 mg/L.

After water is taken aboard a submarine into the trim tank and before its discharge after being

used as a stern tube seal lubricant, several factors cause the TRC level to continue to decline. For

example, the TRC-containing freshwater is mixed with the seawater that remains in the trim tank

and as a result, is diluted by about 50% based on the fact that trim tanks are about 50% full of

seawater while pierside. This results in an immediate reduction of the TRC concentration to

approximately 0.5 mg/L. In addition, organic matter in the residual seawater in the trim tank will

cause further rapid depletion of TRC levels. Although not measured specifically, the amount of

TRC in the trim tank water used to lubricate the shaft seal is likely to be at least as low as the

levels measured in the freshwater used to layup condensers in submarines. TRC levels in such

systems were reduced from 1.2 mg/L to 0.028 mg/L in two hours. Please refer to the Freshwater

Layup NOD report for additional information. Using the average flow rate from the trim tank, it

requires approximately 17 hours to drain the trim tank.

The estimated contributions of the freshwater lubrication process to the discharge are

unknown but thought to be minor. This is because the shaft is not turning while pierside so there

is no bearing wear. In addition, the lubricating water only contacts the lubrication system

components for a short period of time because of the constant flow of water from the trim tank,

through the bearing, and then to the sea. For a typical surface ship (DDG 51 Class) the residence

time of water in the stern tube is approximately 13 seconds2 and similar residence times for stern

tubes on other vessel classes is expected. With residence times of this order, there is little time to

accumulate erosion or corrosion products from the bearing lubrication system materials of

construction.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

4.1.1 Seawater Lubrication

An estimate of the rubber discharge was made based on data for DDG 51 Class vessels.

The DDG 51 Class was chosen because it is a mid-size vessel with a significant population in the

fleet. The available data includes:

Stern Tube Strut

Bearing Length 66 inches 96 inches

Number of Staves 26 26

Stave Width 3.18 inches 3.18 inches
Stern Tube Seals & Underwater Bearing Lubrication

8

Using this data, the total length of rubber material exposed to wear was calculated to be 351 feet

per shaft by the equation:

((66 inches + 96 inches) bearing length per shaft) (26 staves per shaft)/(12 inches per foot)

= 351 feet of bearing material per shaft

DDG 51 Class ships have two shafts; therefore, the total length of bearing material per

ship is 702 feet. Because DDG 51 Class ships have controllable pitch propellers, a wear rate of

40 mils (0.04 inch) on each stave occurs per year. Approximately 40% of the staves carry the

weight of the shafting and thus are subjected to this wear rate. The total volume of rubber that is

worn annually from the staves per ship was calculated as follows:

Volume of Rubber Per Ship = (702 feet of rubber) (3.18 inches/(12 inches/foot) width of staves)

(0.04 inch/(12 inches/foot) wear depth) (0.4 percentage of staves subject to wear) = 0.25 cubic

feet

The density of Buna-N (nitrile) rubber is 61.8 pounds per cubic feet (lbs/ft3). Therefore,

15.4 pounds [(61.8 lbs/ft3) (0.25 ft3)] of rubber are contained in the discharge from each ship

annually. Based upon the assumptions described in Section 3.2.1, ships spend approximately 5%

of their underway time within 12 n.m.6 Thus, 0.76 pound of rubber is discharged by each vessel

within 12 n.m. Bearing wear does not occur while the vessel is alongside the pier or at anchor

because the shafts are not turning.

Using 0.76 pound of rubber as an average for each surface ship and 0.38 pound for each

submarine (due to the single shaft configuration of submarines), the total annual mass loading for

274 ships (excluding boats and crafts) and 89 submarines was calculated by the equation:

Total Annual Mass Loading of Rubber = (0.76 pound/ship) (274 ships) + (0.38

pound/submarine) (89 submarines) = 242 pounds

A total of 242 pounds of rubber is discharged annually for all vessels. This is a

conservative estimate because many vessels have a wear rate of less than 40 mils per year and

many surface vessels do not have two shafts.

Concentrations of rubber were then calculated as follows:

Concentration of rubber in mg/liter = (242 pounds per year) (453,600 mg/pound) / [(334,807,200

gallons per year) (3.785 liters/gallon)] = 0.09 mg/liter

The total annual mass loadings for the metal constituents of seawater lubrication was

calculated based on materials of construction in the stern tube, corrosion rates for those materials,

and the surface area of the material exposed to seawater for a DDG 51 Class ship. The material
Stern Tube Seals & Underwater Bearing Lubrication

9

of construction is a copper-nickel alloy (80% copper and 20% nickel). The available data

includes2:

Surface area exposed to seawater = 7,254 square inches (in2)

Corrosion rate of copper nickel = 7.0 micrometers per year (μm/yr)

Density of copper nickel = 8.9 x 106 grams per meter cubed (g/m3)

Total Annual Mass Loading of Copper and Nickel = (corrosion rate) (density) (area) (percent of

time within 12 n.m.) = 160.4 grams per year

Based on these analyses, one DDG 51 stern tube has the potential to discharge 128.3 grams or

0.28 pound of copper and 32.1 grams or 0.07 pound of nickel annually within 12 n.m. of shore.

Applying this estimate to all vessels of the Armed Forces results in a total annual mass loading of

180 pounds of copper and 45 pounds of nickel.

4.1.2 Freshwater Lubrication

The weighted average of the freshwater flow rate to the stern tube bearings on a

submarine is approximately 5 gallons per minute (19 liters per minute) when the submarine is

idle in port. Assuming a 1.0 mg/L TRC concentration in the freshwater (see Section 3.4.2) and

that the freshwater will be diluted by an equal amount of seawater remaining in the trim tank

when the freshwater is added, the TRC mass loading per submarine per day was calculated by the

equation:

TRC Mass Loading = (Freshwater flow rate) (TRC concentration) (Dilution factor) = (19 L/min)

(0.001 grams/L) (50%) (60 min/hour) (24 hours/day)

= 13.7 grams TRC per day per submarine

Because submarines rarely use freshwater to lubricate the shaft seal, it is assumed that

there are four submarines that use this method annually for shaft seal lubrication and each for a

total of one week. Based on the assumptions in Section 2.1.2, the total annual TRC mass loading

for submarines was calculated by the equation:

Annual TRC Mass Loading = (13.7 grams TRC/day/sub) (7 days/year) (4 subs) = 383 grams

TRC/year = 0.383 kg TRC/yr = 0.84 pounds TRC/yr

The estimated mass loadings for this discharge are provided in Table 1.

4.2 Environmental Concentrations

Table 2 shows the concentration of the priority pollutants that are present in the discharge

from seawater-lubricated bearings compared to acute water quality criteria (WQC). Only copper

exceeds water quality criteria. – The concentration of copper is derived from corrosion rates for

copper, the surface area of the material exposed to seawater, and the rate of seawater lubricating

the stern tube.
Stern Tube Seals & Underwater Bearing Lubrication

10

The freshwater lubrication discharge from submarines consists of freshwater that could

have low concentrations of TRC. Although not measured specifically, the amount of TRC in the

trim tank water used to lubricate the shaft seal is likely to be at least as low as the levels

measured in the freshwater used to lay up boilers and condensers in submarines. TRC levels in

such systems were reduced from 1.2 mg/L to 0.028 mg/L in two hours.

The rubber staves are abraded during the shaft rotation into small particles that do not

dissolve, are relatively inert, and hence are largely not bioavailable.

4.3 Potential for Introducing Non-Indigenous Species

The transport of non-indigenous species is not a concern for this discharge because the

flow through the shaft seals is continuous, the residence time of seawater is 13 seconds for a

DDG 51 Class ship, and the seawater is not held on board for this purpose; therefore, there is

little opportunity to transfer non-indigenous species. Similar residence times are expected for all

other vessel classes.

5.0 CONCLUSIONS

The constituents in stern tube seal and underwater bearing lubrication have a low

potential to cause an adverse environmental effect because:

1) Oil lubricated stern tube seals and bearings cannot release oil to the environment under

normal ship operations.

2) For seawater lubricated stern tube seals and bearings, there is very little contribution of

constituents to the seawater lubrication fluid from the stern tube seal system, other than

rubber, copper, and nickel because of the very short time that the fluid is in contact with

the stern tube seal system. Rubber is released to the environment because the rubber

bearing staves wear. Copper and nickel are introduced because they are materials of

construction of the stern tube. While copper concentrations can exceed chronic WQC,

the mass loadings are not considered sufficient to pose an adverse environmental effect.

3) Freshwater lubricated stern tube seals and bearings are used only on submarines and only

rarely (estimated to be four submarines, each for one week per year) when the seawater in

the trim tanks normally used for lubrication is exhausted. The freshwater lubrication

discharge TRC concentration is expected to be as least as low as the levels measured in

the freshwater used to lay up condensers in submarines.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 3

shows the sources of data used to develop this NOD report.
Stern Tube Seals & Underwater Bearing Lubrication

11

Specific References

1. UNDS Equipment Expert Meeting Minutes - Shaft Seal Lube/Stern Tube

Seals/Underwater Bearing Lubrication. September 10, 1996.

2. Personal Communication Between Miles Kikuta (MR&S) and David Kopack (SEA 00T)

and Gordon Smith (SEA 03L). December 11, 1998.

3. Personal Communication Between George Stewart (MR&S) and Sanjay Chandra

(Versar). April 25, 1997.

4. Personal Communication between Bruce Miller (MR&S) and LCDR Warren Jederberg,

Submarine Force, Pacific Environmental Officer of 15 October, 1997.

5. Personal Communication Between George Stewart (MR&S) and Sanjay Chandra

(Versar). March 14, 1997.

6. UNDS Ship Database, August 1, 1997.

7. Commander Submarine Force, U.S. Atlantic Fleet Letter 5090 Serial N451A/4270 of 13

December 1996 in Response to UNDS Data Call.

8. American Water Works Association. Optimizing Chloramine Treatment. AWWA

Research Foundation, 1993.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.
Stern Tube Seals & Underwater Bearing Lubrication

12

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, pg 15366. March 23, 1995.

Committee Print Number 95-30 of the Committee of Public Works and Transportation of the

House of Representatives, Table 1.
Stern Tube Seals & Underwater Bearing Lubrication

13

Figure 1. Port and Starboard Shaft Lines
Stern Tube Seals & Underwater Bearing Lubrication

14

Figure 2. Type MX9 Inboard Water Lubricated Fully Split Seal
Stern Tube Seals & Underwater Bearing Lubrication

15

Table 1. Estimated Fleet-Wide Mass Loadings for Stern Tube Seals and Underwater

Bearing Lubrication

Constituent Estimated Mass Loadings (lbs/yr)

TRC 0.84

Rubber 242

Copper 180

Nickel 45

Table 2. Comparison of Calculated Data with Water Quality Criteria (μg/L)

Constituents Calculated

Concentration

Log-normal

Mean Effluent

Federal

Chronic WQC

Most Stringent State Chronic

WQC

TRC NA* 7.5 (CT, HI, MS, NJ, VA, WA)

Total Copper 5.8 2.9 2.9 (FL, GA)

Total Nickel 1.5 8.3 7.9 (WA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

CT = Connecticut MS = Mississippi

FL = Florida NJ = New Jersey

GA= Georgia VA = Virginia

HI = Hawaii WA = Washington

NA* = Not available. Concentrations estimated in Section 3.4.2.
Stern Tube Seals & Underwater Bearing Lubrication

16

Table 3. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents X X

3.4 Concentrations X X

4.1 Mass Loadings X X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Submarine Acoustic Countermeasures Launcher Discharge

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Submarine Acoustic Countermeasures Launcher Discharge
Submarine Acoustic Countermeasures Launcher Discharge

2

2.0 DISCHARGE DESCRIPTION

This section describes the submarine acoustic countermeasures launcher discharge and

includes information on: the equipment that is used and its operation (Section 2.1), general

description of the constituents of the discharge (Section 2.2), and the vessels that produce this

discharge (Section 2.3).

2.1 Equipment Description and Operation

Navy submarines are equipped with acoustic countermeasures devices that, once

launched, improve submarine survivability by generating sufficient noise to be observed by

hostile torpedoes, sonars, or other monitoring devices. The only acoustic countermeasure

systems used by the Navy that result in a discharge are Countermeasures Set Acoustic (CSA) Mk

2 launch systems. Other countermeasures systems do not generate a discharge within 12 nautical

miles because their launch tubes are always open to the ocean.1 Countermeasures devices are

launched from the CSA Mk 2 systems for training purposes.

The CSA Mk 2 system encompasses the countermeasure device, a gas generator, an

externally-mounted launch tube, and all associated electronic controls for the countermeasure

device. Figures 1 and 2 provide the location of the launch tubes on submarine hulls, and the

location of components within the launch tube, respectively. Figure 3 shows the mechanism by

which gas is captured within the launch tube. A gas generator at the rear of the launch tube

provides the propulsive charge for launch of the countermeasure device. When the generator is

activated, hot gasses expand, forcing a metal “ram” plate and the countermeasure device out of

the launch tube. The ram plate lodges in the end of the launch tube, which forms a watertight

end cap after launch. For vessel and crew safety, a check valve and bleed holes in the ram plate

are used to allow equalization of internal gasses and liquids with external pressures that vary as

the submarine changes depth. The one-way check valve allows seawater to flow into the tube

after launch, but does not allow any of the liquids to be released through the opening. The

seawater that flows into the tube mixes with the gasses generated by the ammonia perchlorate gas

generation propellant, which results in an acidic liquid. The ram plate contains three 3/8-inch

diameter bleed holes with plugs that dissolve approximately 3 days after the launch, allowing

limited contact between the tube contents and the environment.2

 Each launch assembly, with the

exception of the acoustic countermeasure device, is identical on all submarines, regardless of

vessel class or hull location.

While the submarine is underway and the launch tubes are underwater, the bleed holes

allow some exchange of the launch tube liquid contents with the seawater outside of the launch

tube. Actual discharge rates are very difficult to obtain due to the non-homogeneous nature of

the liquid mixture, the continuous dilution of the liquid contents through the bleed holes, and

variations in seawater flow surrounding the bleed holes due to changes in submarine speed and

maneuvers. On some submarines, launch assemblies are located above the waterline when the

submarine is traveling on the ocean surface. On these submarines, most of the liquid contents of

the launch assemblies drain freely from the bleed holes onto the submarine hull before entering

the water. The location of the bleed plug holes prevent the expended launch tube from
Submarine Acoustic Countermeasures Launcher Discharge

3

completely draining; approximately one-quarter to one-half gallon (1 to 2 liters) of the liquids

remain, depending on the orientation of the ram plate within the launch tube.1 On other

submarines where the launch assembly is always below the water surface, the liquid drains

through the same bleed holes directly into the harbor during the assembly’s replacement.

In order to protect workers from exposure to the potentially acidic water that remains in

the tube subsequent to launch, the Navy has started adding a one-pound packet of sodium

bicarbonate to the system to neutralize pH levels.3 Also, the Navy is reducing cadmium in the

discharge by removing hardware with cadmium-containing coatings from Navy stock.3 All

launchers will be equipped with these changes by the end of March 1999.4

2.2 Releases to the Environment

Within three days following the launch of a countermeasure device, bleed hole plugs in

the ram plate dissolve, which allows pressure equalization of the launch assembly contents with

the external seawater environment. The liquid contents of the launch tube are slowly exchanged

with seawater through these bleed holes while the submarine is moving. While the submarine is

stationary, little or no exchange with seawater occurs. For the submarines where the launch

tubes are located above the waterline, most of the liquid contents of the launch tube freely drain

through the bleed holes each time the submarine surfaces. For the submarines with launch tubes

located below the waterline, the major discharge occurs when the tubes are replaced pierside

while the submarine is stationary. The largest potential volume discharge event would occur

when all countermeasure launch tubes have been expended, there has been no discharge through

the bleed holes while the submarine was underway, and all launch tube contents are released at

one time in port. Therefore, for this analysis, it was assumed that all of the discharge from the

CSA Mk 2 system occurs during pierside replacement of the launch assembly.

2.3 Vessels Producing the Discharge

The CSA Mk II system is installed on 24 Navy submarines of two different classes: four

vessels of the Ohio (SSBN 726) Class, and 20 vessels of the Los Angeles (SSN 688) Class.

Launch assemblies on Ohio Class vessels are located above the waterline when the submarine is

surfaced; assemblies on Los Angeles Class vessels are located below the waterline. In addition,

the number of launch assemblies differs by vessel class. Ohio Class vessels have 16 launch

assemblies while Los Angeles Class vessels have 14 assemblies.2 Neither the Army, Air Force,

U.S. Coast Guard, nor Military Sealift Command own or operate submarines.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
Submarine Acoustic Countermeasures Launcher Discharge

4

3.1 Locality

Submarine countermeasures operations during training exercises typically occur outside

of 12 n.m. in the open ocean. Discharges from launch tubes located above the waterline may

occur within and beyond 12 n.m. while the submarine is underway on the surface as the effluent

drains from the bleed holes. Some additional leakage from these launch tubes could occur

pierside while the launch tubes are removed from the submarine. Discharges from launch tubes

located below the waterline could also occur pierside when the launch tubes are offloaded. A

small amount of exchange between all submerged launch tubes and the surrounding waters could

occur continuously within and beyond 12 n.m.

3.2 Rate

The volume of the launch tube is approximately 17 gallons (65 liters). Approximately 60

expended launch tubes are removed annually fleetwide.2 Therefore, approximately 1020 gallons

of effluent is generated per year. For the purposes of this report, the discharge event volume was

assumed to be 17 gallons, although in the cases where launch assemblies are above the waterline,

some of the launch tube effluent would be discharged prior to a launch assembly replacement

operation, and under normal circumstances even those tubes located below the waterline do not

discharge their entire contents.

When a submarine is traveling on the ocean surface, liquid contents of the launch

assemblies that are located above the waterline were estimated to discharge at a rate of one gallon

per minute through bleed holes. During a discharge event in port, the liquid contents are released

through the same bleed holes while being transported from the submarine to the pier, and

therefore also discharge at a rate one gallon per minute. For the purposes of this report, it was

assumed that all liquids in the launch assembly are discharged into surrounding waters before the

assembly is placed on the pier.

3.3 Constituents

Table 1 summarizes the analytical data from sampling of an actual gas generator and

launch tube assembly, with a sodium bicarbonate packet in place and no cadmium-containing

coatings.5 The constituents detected in sampling, i.e., lead, copper, cadmium, and silver, were

expected based upon the known components of the gas generator (e.g., ammonia perchlorate

propellant), hardware coating components, and solder within the system electronics.1 In addition

to analyzed concentrations, based upon knowledge of the components of the gas generator,

exhaust gas products that may become a part of the discharge can include hydrochloric acid,

carbon dioxide, water vapor, carbon monoxide, nitrogen, alumina, iron (II) chloride, titanium

dioxide, hydrogen, and iron (II) oxide.6 Table 2 provides a complete listing of the types and

quantities of gas generator exhaust gas products. Of the discharge constituents, lead, copper,

cadmium, and silver are priority pollutants. There are no bioaccumulators that have been

identified in this discharge.

3.4 Concentrations
Submarine Acoustic Countermeasures Launcher Discharge

5

Table 1 provides a summary of the analytical results obtained from sampling of the

launch tube water immediately following a launch, and sampling five days after launch.5 Of the

two data sets, the analytical data from sampling five days after launch is more representative of

the actual pierside discharge because typical submarine operational schedules do not allow for

immediate replacement of the launched countermeasures devices. In reality, submarines usually

continue for months until a scheduled maintenance port call results in a launch tube change out

and discharge of launch tube water. For the data shown in Table 1, where a concentration value

was found to be below the detection limit, the mean concentration value was calculated using

one-half of the detection limit. The pH of the launch tube water five days after launch was 7.2,

which is similar to the pH of seawater (~8).

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The total annual discharge volumes provided in Section 3.2 were used to estimate

potential constituent mass loadings as follows:

Analytical data from sampling five days after launch was used to calculate mass loadings

because that data set is more representative of the actual pierside discharge than data from

sampling immediately following launch. Even this overstates the potential mass loading, as most

submarines will continue to operate for months after the launch, before changing the launch

tubes. For example, the mass loading for copper was estimated as:

(80 μg/L)(1020 gal/yr)(3.785)(2.205)(10-9) ≈ 7 x 10-4 lbs/yr, or approximately 2 ten-thousandths

of an ounce per discharge event

Table 3 provides annual fleet-wide mass loadings and discharge event mass loadings for

the metallic constituents listed in Table 1.

4.2 Environmental Concentrations

Mass Loading (lbs/yr) =

(avg. concentrations in μg/L) (discharge in gal/yr) (3.785 L/gal) (2.205 lb/kg) (10-9 kg/μg)
Submarine Acoustic Countermeasures Launcher Discharge

6

Table 4 compares the concentrations of the Mk 2 system discharge to Federal and the

most stringent state water quality criteria (WQC). Copper, cadmium, and silver concentrations

are above both the Federal and most stringent state WQC. Lead was detected in only one of the

ten samples; lead in this sample exceeded the most stringent state WQC.

4.3 Potential For Introducing Non-Indigenous Species

There is a low potential for this discharge to transport non-indigenous species because:

1) the 17-gallon launch tube is capped immediately following the launch of a

countermeasure device, with the only means of seawater entry being a one-way check

valve and three 3/8-inch diameter bleed holes. Therefore, there is limited opportunity

for organisms to ever enter the launch tube;

2) because launches of countermeasure devices are estimated to take place 60 times a

year fleetwide and typically take place in the open ocean;

3) any deep ocean water organism would be unlikely to survive in near-shore waters.7

4) the total volume of the discharge per year is small.

5.0 CONCLUSION

Submarine acoustic countermeasures launcher discharge has a low potential to cause an

adverse environmental effect from constituents and the introduction of non-indigenous species

because:

1) The constituent mass loading is low. For example, the mass loading of copper into

receiving waters during one of the 60 discharge events per year would be two tenthousandths of an ounce.

2) The small volume of the discharge, combined with the low likelihood that the

organisms taken on could survive in port, make it unlikely that the discharge could

transport viable non-indigenous species.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained.

Equipment expert information was used to estimate the rate of discharge. The constituents and

concentrations in this discharge were obtained from process knowledge and analytical data.

Table 5 shows the sources of the data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting - Submarine Acoustic Countermeasures Launcher

Discharge, 12 June, 1998.
Submarine Acoustic Countermeasures Launcher Discharge

7

2. UNDS Data Call Response, Countermeasure Set, Acoustic (CSA) Mk 2, PMS415D5,

Naval Sea Systems Command, 20 February 1998.

3. Engineering Change Proposal (ECP) CR-GG77-E0002, Naval Surface Warfare Center

(NSWC) Crane Division, 5 April 1997.

4. Personal Communication between Ken Burt, PMS415, Naval Sea Systems Command,

and Gordon Smith, SEA 03L, Naval Sea System Command, 23 February 1998.

5. Analysis of Products from Expended Propellant Billet Gas Generators, Naval Surface

Warfare Center, Crane, Code 4052, Ser 4052/7073, 13 May 1997.

6. Excerpts from Naval Surface Warfare Center (NSWC) Crane Division Preliminary

Report for the Saltwater Immersion and Pressure Testing of the ADC Mk 3 Mod 0 with

Lithium Battery, EDD 95-068, NSWC Crane Division, May 1995.

7. “Stemming the Tide,” Controlling Introductions of Nonindigenous Species by Ships’

Ballast Water, Committee on Ships’ Ballast Operations, National Academy Press,

Washington D.C., 1996, p. 36.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.
Submarine Acoustic Countermeasures Launcher Discharge

8

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Submarine Acoustic Countermeasures Launcher Discharge

9

UNCLASSIFIED

Launched Rack

Detailed View Launch Control Panel

CSA MK 2 MOD 0

Trident

Configuration

CSA MK 2 MOD 1

SSN 688I Dihedral

Configuration

Dihedral

Detailed View

Figure 1. Configuration of CSA Mk 2 Launchers

on SSBN 726 and SSN 688 Class Vessels
Submarine Acoustic Countermeasures Launcher Discharge

10

UNCLASSIFIED

Gas Generator Ram Plate Countermeasure Launch Tube

One Way Check Valve Bleed Plug

Figure 2. Location of Countermeasures Launcher Components Within a Launch Tube
Submarine Acoustic Countermeasures Launcher Discharge

11

7.5”

Cap

Countermeasure

122.3”

Gas Generator

Ram Plate

Stop Ramp

Captured Gas

UNCLASSIFIED

Figure 3. Countermeasure Launch Process
Submarine Acoustic Countermeasures Launcher Discharge

12

Table 1. Constituent Concentration Data

Immediately and Five Days Following Launch 5

Constituent Dissolved Concentrations Immediately

Following Launch

Mean

value

Dissolved Concentrations Five Days

Following Launch

Mean

value

Metals μg/L

Barium BDLa BDL BDL BDL BDL BDL BDL BDL BDLa BDL BDL BDL BDL BDL BDL BDL

Lead BDLb BDL BDL BDL BDL BDL 200 110 BDLb BDL BDL BDL BDL BDL BDL 100

Copper 100 160 290 800 180 860 260 380 70 40 70 90 60 170 80 80

Cadmium 70 630 60 740 120 290 440 340 40 150 100 20 20 90 30 60

Chromium BDLc BDL BDL BDL BDL BDL BDL BDL BDLc BDL BDL BDL BDL BDL BDL BDL

Silver BDLd

20 BDL 20 BDL 40 20 20 20 BDLd BDL BDL BDL 30 BDL 10

Other

pH 7.2 6.0 6.0 5.7 6.3 5.3 5.9 5.8* 7.5 7.1 6.9 7.0 7.4 7.2 7.5 7.2*

a BDL = below detection limit; detection limit for barium is 1000 μg/L

b Detection limit for lead is 200 μg/L

c Detection limit for chromium is 80 μg/L

d Detection limit for silver is 20 μg/L

* Mean pH calculated using arithmetic average of [H+] values

Table 2. Gas Generator Exhaust Gas Products 6

Exhaust Gas

Product

Mass per Gas

Generator (g)

HCl 23.036

CO2 21.860

H2O 16.846

CO 14.096

N2 9.345

Al2O3 2.832

FeCl2 2.068

TiO2 1.998

H2 1.803

FeO 1.523

P2 0.002

PN 0.054

CH4 0.004

NH3 0.001

FeCl3 0.001

PO2 0.001

PO <0.001

PH3 <0.001

Table 3. Estimated Annual Mass Loadings
Submarine Acoustic Countermeasures Launcher Discharge

13

Constituent Loading (lbs/yr) Loading per Discharge Event*

(ounce/event)

Cadmium 0.0005 0.0001

Copper 0.0007 0.0002

Lead 0.0009 0.0002

Silver 0.00009 0.00002

* based upon 60 maximum-volume discharge events per year

Table 4. Comparison of Discharge Constituents with Water Quality Criteria (μg/L)

Constituent Mean Concentration

or Value

Federal Acute WQC Most Stringent State

Acute WQC

Cadmium 60 42 9.3 (FL, GA)

Copper 80 2.4 2.4 (CT, MS)

Lead 100 210 5.6 (FL, GA)

Silver 10 1.9 1.2 (WA)

FL = Florida

GA = Georgia

CT = Connecticut

MS = Mississippi

WA = Washington

Table 5. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the

Discharge

UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents X X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Submarine Bilgewater

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Submarine Bilgewater
Submarine Bilgewater

2

2.0 DISCHARGE DESCRIPTION

This section describes the submarine bilgewater discharge and includes information on:

the equipment that is used and its operation (Section 2.1), general description of the constituents

of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Bilgewater in submarines is a mixture of discharges and leakage from a wide variety of

sources, which drain to the lowest compartment (bilge) of the submarine. Bilgewater includes

seawater accumulation, normal water leakage from machinery, and fresh water washdowns. It

can contain a variety of constituents including cleaning agents, solvents, fuel, lubricating oils,

and hydraulic oils.1

The submarine’s drain system has a series of non-oily bilge collecting tanks, oily bilge

collecting tanks, and a waste oil collecting tank or tank complex. The Ohio (SSBN 726) Class

ballistic missile submarines and the planned New Attack Submarine (NSSN) use a waste oil

collecting tank complex partitioned into oily and clean sides. Los Angeles Class (SSN 688)

attack submarines use a waste oil collecting tank without the partitioning, where gravity

separation of oil occurs.1

Non-oily waste is sent via a segregated drain system to the nonoily bilge collecting tanks,

where it is discharged overboard. Waste that is oily or could possibly be oily, goes to the waste

oil collecting tank (WOCT) through a separate drain system. Submarine classes with partitioned

tanks, as listed above, use gravity separation enhanced by tank baffles to achieve some measure

of oil/water separation. The SSN 688 Class submarines use the aft bilge collecting tank (ABCT)

to receive and settle the bilgewater and non-oily drainage. The bottom portion of the water as

separated in the tank is discharged overboard.2 The upper portion of the ABCT which would

have any potential for containing oily waste is transferred to the WOCT. The lower portion of

the WOCT can be pumped overboard outside of 50 nautical miles (n.m.), but the upper portion

must be held for future transfer to appropriate shore/disposal facilities.1

While most submarines of the U.S. fleet operate as described above, the Sturgeon Class

(SSN 637) has bottomless bilge collecting tanks open to the sea, from which water is discharged

by displacement whenever bilge pumps are activated. Watches are set to monitor for a sheen

whenever oily water is to be pumped to the tank in port; pumping to the bilge collecting tank is to

cease if a sheen is reported.1

2.2 Releases to the Environment

Onboard SSN 688 Class submarines, clean drains and the lower portion, or water phase,

of the separated bilgewater in the ABCT are pumped overboard as necessary regardless of

distance from shore. The lower portion of the liquid in the WOCT can be disposed of outside of

50 n.m.2 The upper portion, or oily waste, from all of the drains, bilge water, and other sources

must be held on board until the submarine has access to appropriate shore or disposal facilities.
Submarine Bilgewater

3

2.3 Vessels Producing the Discharge

The Navy currently operates five classes of submarines (presented in Table 1) that

generate bilgewater. However, not all of these classes discharge bilgewater to the environment.

Pierside, submarine bilgewater is transferred to shore facilities. In transit, SSBN submarines do

not discharge bilgewater within 12 n.m. SSN 688 Class submarines discharge some of the water

phase of the bilgewater collecting tank between 3 and 12 n.m.3

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

In most submarine classes, submarine drain and plumbing drain systems are used to

receive all drains and route them to their respective holding tanks. In these classes, discharges

which may contain any oily waste are not to be released within 50 n.m., except in emergencies.

Per OPNAVINST 5090.1B, submarines are instructed to: 2

...pump all oily waste to the waste oil collection tank (WOCT). When the tank is full,

after allowing for adequate separation time, and the ship is outside 50 n.m. [nautical

miles], submarines shall pump the bottom, water phase of the WOCT overboard.

The upper, oil phase from the WOCT is discharged only to authorized shore facilities.

The location of this discharge varies by class and the activities of the submarine. The

operational factors that affect the location of bilgewater discharge include the operating depth,

type of operations, the submarine’s requirement for quiet operations, and the duration of the

operations.

SSBN 726 Class submarines discharge all bilgewater either to shore facilities when

pierside, or hold bilgewater for discharge when outside 50 n.m. The SSN 688 Class discharges

some of the water phase of the bilgewater collecting tank between 3 and 12 n.m. due to the

limited size of the holding tank.3 For the SSN 637 Class submarines, discharges of bilgewater

can occur at any location when the bilge pumps are activated.1

3.2 Rate

The rate of this discharge varies considerably by class and with the submarine activities.

The volume of bilgewater generated can depend on the crew size, operating depth, the
Submarine Bilgewater

4

submarine’s requirement for quiet operations, the type of operations, the duration of operations,

and their location.

As shown in Table 1, there are three major submarine classes which generate bilgewater.

These are the SSBN 726 Class, the SSN 688 Class, and the SSN 637 Class. The SSN 637 Class

submarines are currently being phased out of service. At the present time, the entire class is

expected to be retired by the year 2001.4 Because of this, total discharge rates for SSN 637 Class

submarines will not be estimated.

Pearl Harbor Naval Station estimates that 2,000 to 3,000 gallons of bilgewater are

generated per submarine per day when pierside; the classes of vessels were not specified.5 For

the SSBN 726 and SSN 688 Class submarines, the following annual per-vessel flow estimates

were provided:3

SSBN 726 31,500 gallons to shore facilities

0 gallons while transiting within 12 n.m.

300,000 gallons outside 12 n.m.

SSN 688 54,000 gallons to shore facilities

80,540 gallons while transiting within 12 n.m.

400,200 gallons outside 12 n.m.

Available data indicate that for the other submarine classes, no bilgewater is discharged

within 50 n.m. Since bilgewater transferred to shore facilities is not released to the environment,

the above information indicates that only the SSN 688 Class submarines actually discharge

submarine bilgewater within 12 n.m. from shore.

Based on the value of 80,540 gallons per submarine per year discharged from the SSN

688 Class vessels between 3 and 12 n.m., a total flow was calculated as follows:

(80,540 gal/vessel/year) (56 SSN 688 Class subs) = 4.5 million gallons/year

3.3 Constituents

Potential constituents which have been detected in previous studies include oil and

grease, copper, cadmium, lead, nickel, iron, zinc, mercury, lithium bromide, citric acid, chlorine,

phenol, cyanide, sodium bisulfite, and the pesticides heptachlor and heptachlor epoxide.

Submarine bilgewater could possibly have high levels of total suspended solids (TSS) and

chemical oxygen demand (COD).6,7

Heptachlor, heptachlor epoxide, phenol, cyanide, copper, cadmium, lead, nickel, silver,

and zinc are priority pollutants. Mercury is the only bioaccumulator.

3.4 Concentrations
Submarine Bilgewater

5

Table 2 summarizes concentration data from a sampling effort involving 10 submarines.

Samples in that program were analyzed for oil, 13 metals, pesticides, PCBs, and 46 organics

(vinyl chloride and 45 semivolatile organics).6,7 The sampling involved four SSBN 726 Class

submarines, four SSN 688 Class submarines, and two SSN 637 Class submarines. Samples were

taken from submarines that held their bilgewater while operating. Samples are representative of

discharges normally made outside 12 n.m.

Samples from open bilge compartments on all three classes of submarines were found to

contain an average of 20 parts per million (ppm) oil; bilgewater tanks averaged 76 ppm oil. In

calculating arithmetic averages, six samples having values of greater than 1,000 ppm oil were

excluded. These were considered not representative of bilgewater discharged within 12 n.m. and

would be handled normally as waste oil and retained for shore disposal. These six samples

ranged from 1,030 to 820,000 ppm of oil. The arithmetic average of the 52 oil samples, ranging

between the detection limit of 5 ppm and 1,000 ppm, is 30 ppm. Including the 23 nondetects, the

result would be an arithmetic mean of 22.3 ppm when each non-detect sample was set equal to

the detect limit of 5 ppm.

Each sample was also analyzed for 13 metals. Eighteen pesticides, 7 PCBs, 45

semivolatile organics (base neutral aromatics), and one volatile organic (vinyl chloride) were

analyzed for in the 81 samples. Table 2 presents concentration ranges and the average

concentration calculated. No PCBs, semivolatiles, or vinyl chloride were detected in any sample.

Six of the 81 samples contained detectable levels of the pesticides heptachlor and heptachlor

epoxide.6,7

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with the water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The total annual mass loadings were calculated based upon the estimated discharge

volume for SSN 688 Class vessels and the average concentrations of constituents in submarine

bilgewater. The results are presented in Table 3.

4.2 Environmental Concentrations

Concentration data presented in Table 2 are measured concentrations in the discharge,

and do not reflect any dilution afforded by the receiving water.

Table 4 shows the water quality criteria (WQC) that are relevant to submarine bilgewater,
Submarine Bilgewater

6

and compares measured concentrations of constituents to WQC. Reported levels of oil and

grease for bilgewater exceed the Federal and the most stringent state WQC. Mercury, heptachlor,

and heptachlor epoxide exceed the most stringent state WQC. Average measurements of

constituents in the discharge exceed the Federal and the most stringent state WQC for copper,

nickel, silver, and zinc. While there is no relevant Federal WQC, chlorine concentrations exceed

the most stringent state WQC. Cadmium concentrations exceed the most stringent state WQC,

but do not exceed the Federal WQC.

4.3 Potential for Introducing Non-indigenous Species

Non-indigenous species are not likely to be transported by submarine bilgewater. There

is limited seawater access to bilge compartments. Bilgewater storage capacity limitations require

processing bilgewater on a frequent basis, resulting in discharge in the same geographic area in

which it was generated.

5.0 CONCLUSIONS

Concentration data from submarine bilgewater were used to estimate constituent loadings

within 12 n.m. from shore. These data and estimates were based on the existing management

practices (i.e. shoreside bilgewater collection, discharging only the water phase, and refraining

from discharging within 12 n.m.). Discharges between 3 and 12 n.m. occur while the vessels are

underway thereby dispersing the pollutants. Removal of the existing practices could significantly

increase amounts of constituents discharged above WQC and discharge standards, especially oil.

Submarine bilgewater could potentially be discharged in port if these existing practices were not

in place. Therefore, submarine bilgewater, uncontrolled, has the potential to cause an adverse

environmental effect.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 5

shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes, Submarine Bilgewater. August 12, 1996.

2. OPNAVINST 5090.1B. Environmental and Natural Resources Program Manual.

November 1, 1994.

3. Data Call Response, Commander, Submarine Force, U.S. Atlantic Fleet. Submarine

Discharge Questionnaire. December 13, 1996.

4. Personal Communication Between Mr. R.B. Miller (M. Rosenblatt & Son, Inc.) and Mr.
Submarine Bilgewater

7

Paul Murphy (NAVSEA PMS 392A33) of October 15, 1997.

5. Data Call Response, Pearl Harbor Naval Station. October 11, 1996.

6. Bilge Water Sampling Study. Final Report. September 30, 1996. Electric Boat

Corporation.

7. NSSN Review, June 5, 1996. Subject: Fleet Bilge Water Sampling. Presented by: James

Triba, NSSN Seawater Systems, Electric Boat Corporation.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Submarine Bilgewater

8

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. 23 March 1995.
Submarine Bilgewater

9

Table 1. Submarines Producing Bilgewater Discharges

Vessel Class Description of Vessel Number of Vessels

SSBN 726 Ohio Class Ballistic Missile Submarine 17

SSN 637 Sturgeon Class Attack Submarine 13

SSN 640 Benjamin Franklin Class Attack Submarine 2

SSN 671 Narwhal Class Attack Submarine 1

SSN 688 Los Angeles Class Attack Submarine 56

Table 2. Concentrations of Contaminants in Submarine Bilgewater Discharge (mg/L)6,7

Parameter Range (mg/L) Arithmetic Mean (mg/L)*

Oil <5 - 820,000 30 mg/L (note a)

Arsenic <0.01 <0.01

Barium <0.01 - 3.3 0.014

Cadmium <0.005 - 0.2 0.02

Chromium <0.01 - 1.7 0.050

Copper 0.065- 15 1.42

Iron <0.2 - 20 1.89

Lead <0.01 - 0.074 0.01

Manganese <0.01 - 1.7 0.12

Mercury <0.0002 - 0.0007 0.00007

Nickel <0.04 - 11 0.98

Selenium <0.005 - 0.021 0.005

Silver <0.01 - 0.035 0.006

Zinc <0.02 - 11 1.36

Heptachlor 0.000005

17 other pesticides note b

Heptachlor epoxide 0.000003

PCBs <0.001 <0.001

1 VOA plus 45 SVOAs note cnote b

Ammonia <0.1 - 68 6.95

Chlorine 0.0 - 1.6 0.21

COD <15 - 4500 595

Cyanide <0.01 - 0.03 0.004

pH 2.94 - 8.95 6.9

Phenols <0.01 - 5.4 0.19

Surfactants ND - 0.807 0.16

TSS <7 - 2400 177

Note a - The average of 30 mg/L provided in the primary reference6 omitted all nondetects and all (six) oil values >

1,000 milligrams per liter (mg/L). The average of the 75 samples less than 1,000 ppm (including nondetects,

assumed to equal the detection limit) is 22.3 mg/L.

Note b - No samples had detectable levels.

Note c - VOA is volatile organic analyte; SVOA is semivolatile organic analyte

Values preceded by “<” are non-detects
Submarine Bilgewater

10

Table 3. Estimated Mass Loadings of Constituents

from Submarine Bilgewater Discharges (lbs/yr)

Pollutant Concentration (mg/L) 688 Class 3-12 n.m.

Oil 30.01 1130

Copper 1.42 53.4

Lead 0.01 0.38

Nickel 0.98 36.9

Silver 0.006 0.23

Zinc 1.36 51.2

Ammonia 6.95 262

Chlorine 0.21 7.90

Barium 0.014 0.53

Cadmium 0.02 0.75

Chromium 0.05 1.9

Mercury 0.00007 0.0026

Selenium 0.005 0.19

Heptachlor 0.000005 0.00019

Cyanide 0.004 0.15

Phenol 0.19 7.15

Surfactants 0.16 6.02
Submarine Bilgewater

11

Table 4. Comparison of Measured Constituent Values and Water Quality Criteria (μg/L)

Constituent Average

Concentration

Federal Acute WQC Most Stringent State

Acute WQC

Mercury*0.07 1.8 0.025 (FL, GA)

Heptachlor 0.005 0.053 0.00011 (GA)

Heptachlor epoxide 0.003 0.053 0.00021 (FL)

Phenol 190 - 170 (HI)

Cyanide 4 1 1 (CA, CT, FL, GA, HI,

MS, NJ, VA, WA)

Oil 3,0010 visible sheena

 / 15,000b

5000 (FL)

Copper 1420 2.4 2.4 (CT, MS)

Nickel 980 74 8.3 (FL, GA)

Silver 6 1.9 1.2 (WA)

Zinc 1360 90 84.6 (WA)

Chlorine 210 - 10 (FL)

Cadmium 20 42 9.3 (FL, GA)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

CA = California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

NJ = New Jersey

VA = Virginia

WA = Washington

*

 Bioaccumulator

a Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen

on receiving waters.

b

International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as

implemented by the Act to Prevent Pollution from Ships (APPS)
Submarine Bilgewater

12

Table 5. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment Data Call responses X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality Data Call responses X

3.2 Rate Data Call responses X

3.3 Constituents X X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
Submarine Emergency Diesel Engine Wet Exhaust

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Submarine Emergency Diesel Engine Wet Exhaust
Submarine Emergency Diesel Engine Wet Exhaust

2

2.0 DISCHARGE DESCRIPTION

This section describes the submarine emergency diesel engine wet exhaust liquid

discharge and includes information on: the equipment that is used and its operation (Section

2.1), general description of the constituents of the discharge (Section 2.2), and the vessels that

produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

All submarines have emergency diesel engines for use during emergency situations, such

as providing electric power or emergency ventilation. However, emergency diesel engines are

routinely used during training exercises, pre-underway checks, and quarterly performance

analyses. All submarines have air induction and diesel exhaust systems for emergency diesel

engines. Air induction systems bring in outside air for combustion in the emergency diesel

engines, while exhaust systems discharge the combustion by-products overboard. Prior to

discharge, the exhaust gases are cooled by seawater injection into the exhaust. Water is injected

to reduce radiant energy from the exhaust piping and to reduce corrosion of the exhaust piping

from high temperatures.

Each submarine is equipped with one emergency diesel engine. Refer to Figure 1 and

Figure 2 for a representation of the wet exhaust system.

2.2 Releases to the Environment

The exhaust-water mixture is vented from the exhaust stack into the atmosphere. Some

of the water mist with entrained or dissolved exhaust products will settle into the seawater

surrounding the exhaust stack. For the purposes of this analysis, it is assumed that all of the

discharge settles to the water’s surface.

2.3 Vessels Producing the Discharge

The Navy is the only branch of the Armed Forces that operates submarines. All active

submarines in the fleet produce this discharge. For this report, information on the discharge rates

from the three main submarine classes was used, representing 86 of the 89 active submarines.

The classes of submarines producing emergency diesel wet exhaust discharge analyzed in this

report are summarized in Table 1.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
Submarine Emergency Diesel Engine Wet Exhaust

3

3.1 Locality

Each vessel operates the emergency diesel engine an average of 60 hours annually within

12 n.m. of shore.

3.2 Rate

Table 1 provides discharge rates for individual classes of submarines. Discharge rates

vary for each vessel class, from approximately 7 gallons per minute (gpm) to 15 gpm, and are

dependent on the water injection rate into the exhaust system.1,2,3,4 For this analysis, it was

assumed that all of the water injected into the exhaust system is eventually discharged to the

receiving water body. This represents an overestimate for total flow volumes, because much of

the injected seawater has the potential to vaporize.

3.3 Constituents

Constituents of exhaust from diesel engines include both organic and inorganic

substances. These substances originate primarily from the diesel fuel and also from engine

lubricants. Most of the substances that originate from the diesel fuel are products of combustion.

Some diesel fuel can pass through the engine unburned, along with combustion products in the

exhaust.5

Inorganic substances in diesel exhaust include combustion products such as carbon

dioxide (CO2), carbon monoxide (CO), oxides of nitrogen (NOx), oxides of sulfur (SOx), and

metals. The specific substances and their concentrations in the exhaust depend on a number of

factors, including the composition of the fuel, engine temperature, engine use, and engine

condition. Many of the organic substances in diesel exhaust condense into particulates, that is,

the oily soot visible in the exhaust. 6

Standard air emissions factors for large stationary diesel industrial engines were used to

study the constituents in this discharge. EPA has published emission factors for large stationary

diesel engines 600 hp and over. These emissions factors relate quantities of released materials to

fuel input, as nanograms per Joule (ng/J), or as power output, as in grams per horsepower-hour

(g/hp-hr). Although intended for stationary industrial diesel engines, these emission factors can

be used to approximate emergency diesel engine emissions. 6

Table 2 lists the emission factors for constituents present in the air exhaust of large diesel

engines.6 As the cooling water is injected into the air exhaust, many of these constituents have

the potential to be introduced into the water. Of the compounds shown in Table 2, benzene,

toluene, acrolein, naphthalene, acenaphthylene, acenaphthene, fluorene, phenanthrene,

anthracene, fluoranthene, pyrene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene,

benzo(k)fluoranthene, benzo(a)pyrene, indeno(1,2,3-cd)pyrene, dibenzo(a,h)anthracene, and

benzo(g,h,i)perylene are priority pollutants. This discharge is not expected to contain

bioaccumulators.
Submarine Emergency Diesel Engine Wet Exhaust

4

3.4 Concentrations

Using submarine diesel engine power output specifications, the concentrations of the

chemical constituents in the engine exhaust were estimated for each submarine class. By making

the assumption that all constituents in the discharge liquid resulted from exhaust gases dissolving

in the cooling water under equilibrium conditions, it is possible to estimate the concentration of

constituents in the liquid using Henry’s Law. Henry’s Law describes the solubility of gases in a

liquid and relates the concentration of a constituent in a liquid to the partial pressure of the

constituent in the gaseous phase surrounding the liquid. The calculation sheet at the end of this

report presents the assumptions made for this approach and provides a sample calculation for the

concentration of benzene in the wet exhaust of a SSN 688 class submarine. Estimated

concentrations are presented in Table 3.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

after release to the environment are estimated and compared with water quality criteria. In

Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Mass loadings were calculated for constituents that exceed WQC using annual flow

volumes (Table 1) and estimated constituent concentrations (Table 3). Annual flow volumes

were calculated using the cooling water injection rate (Table 1) and an average operational time

of 60 hours annually within 12 n.m. of shore, per submarine.1 Fleet-wide mass loadings for

individual chemical constituents were calculated through the following equation and are shown

in Table 4.

 Annual Mass Loading (kg)

 = (Concentration in Discharge (mg/L))(Annual Discharge (gal))(3.785 L/gal)(10-6 kg/mg)

The mass loading calculations are an overestimate. Calculations using Henry’s Law

assumed that equilibrium conditions exist. However, due to the low residence time (<1 second)

of both exhaust products and water in the wet exhaust system, equilibrium conditions are

unlikely.7 Therefore, constituent concentrations are expected to be lower than calculated.

4.2 Environmental Concentrations

A comparison of estimated constituent concentrations to corresponding Federal and most

stringent state water quality criteria (WQC) is presented in Table 5. The estimated

concentrations of phenanthrene, benzo(a)anthracene, chrysene, indeno(1,2,3-cd)pyrene,

dibenzo(ah)anthracene, and benzo(g,h,i)perylene individually exceed the most stringent state
Submarine Emergency Diesel Engine Wet Exhaust

5

(Florida) WQC. Concentrations have been based on a water temperature of 60oF. Since the

majority of submarines are located in warm water ports, it is believed that 60oF is a reasonable

assumption for an average water temperature. Concentrations may increase at colder

temperatures because of increased constituent solubilities. However, even if concentrations

triple, none of the individual constituents will exceed federal water quality criteria and only one

additional individual compound (benzo(a)pyrene) will exceed Florida criteria for total PAHs. All

other constituent concentrations are below relevant WQC.

4.3 Potential for Introducing Non-Indigenous Species

Because water intake and discharge occur at the same location, there is no significant

threat of non-indigenous species introduction to receiving waters.

5.0 CONCLUSION

This analysis concluded that submarine emergency diesel engine wet exhaust has a low

potential for adverse environmental effect. Although total PAHs (the total of the following

individual PAH compounds: acenaphthylene, benzo-(a)anthracene, benzo(a)pyrene,

benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene,

dibenzo(a,h)anthracene, indeno(1,2,3-cd)pyrene, and phenanthrene) exceeded water quality

criteria for the most stringent state (Florida), the annual Fleet-wide mass loading was only 0.056

pounds from 86 vessels.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 6

shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Data Call Package Submission from COMSUBLANT, 688 & 726 Class

Submarine. December 13, 1996.

2. Gerry Viers, Newport News Shipbuilding. Submarine Diesel Exhaust System, 5 February

1997, Doug Hamm, Malcolm Pirnie, Inc.

3. Perry Buckberg, NAVSEA 03X33. Submarine Diesel Exhaust Temperatures, 13

November 1997, Russ Hrabe, M. Rosenblatt & Son, Inc.

4. UNDS Equipment Expert Meeting - Submarine Emergency Diesel Engine Exhaust. 3

September 1996.
Submarine Emergency Diesel Engine Wet Exhaust

6

5. Faukner, M.G.; E.B. Dismukes; and J.R. McDonald. Assessment of Diesel Particulate

Control: Filters, Scrubbers, and Precipitators. U.S. Environmental Protection Agency.

EPA-600/7-79-232a. October, 1979.

6. United States Environmental Protection Agency Office of Air Quality Planning and

Standards. Compilation of Air Pollution Emission Factors. AP-42, Fifth Addition,

November, 1996.

7. Doug Hamm (MPI). Interoffice Memo: Estimation of Residence Time. March 4, 1998.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.
Submarine Emergency Diesel Engine Wet Exhaust

7

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.
Submarine Emergency Diesel Engine Wet Exhaust

8

Figure 1. Typical Submarine Diesel Exhaust System
Submarine Emergency Diesel Engine Wet Exhaust

9

Figure 2. Typical Submarine Diesel Seawater System
Submarine Emergency Diesel Engine Wet Exhaust

10

Table 1. Emergency Diesel Engine Applicable Vessels,

Air Exhaust and Cooling Water Flow Rates, and Estimated Annual Discharge

Submarine Class

No. of

Submarines

Air Exhaust

Flow Rate

(cubic feet

per minute)

Cooling Water

Injection Rate

(gallons per

minute)

Annual

Discharge per

Submarine

(gallons)*

Annual

Discharge for

Class (million

gallons)

SSN 688 (Los Angeles Class) 56 6500 11.5 41,400 2.3

SSBN 726 (Ohio Class) 17 8600 15.0 54,000 0.92

SSN 637 (Sturgeon Class) 13 3600 7.0 25,200 0.33

Total 86 N/A N/A N/A 3.55

* Based on 60-hour operating time annually per submarine

Table 2. Emission Factors for Large Uncontrolled Stationary Diesel Engines6

Constituent Emission Factor

(lb/MMBtu)a

(ng/J)b

Benzene 7.76E-04 0.3337

Toluene 2.81E-04 0.1208

Xylenes 1.93E-04 0.0830

Formaldehyde 7.89E-05 0.0339

Acetaldehyde 2.52E-05 0.0108

Acrolein 7.88E-06 0.0034

NOx 3.2 1376

CO 0.85 365.5

CO2 165 70950

Naphthalene 1.30E-04 0.0559

Acenaphthylene 9.23E-06 0.0040

Acenaphthene 4.68E-06 0.0020

Fluorene 1.28E-05 0.0055

Phenanthrene 4.08E-05 0.0175

Anthracene 1.23E-06 0.0005

Fluoranthene 4.03E-06 0.0017

Pyrene 3.71E-06 0.0016

Benzo(a)anthracene 6.22E-07 0.0003

Chrysene 1.53E-06 0.0007

Benzo(b)fluoranthene 1.11E-06 0.0005

Benzo(k)fluoranthene 2.18E-07 0.0001

Benzo(a)pyrene 2.57E-07 0.0001

Indeno(1,2,3-cd) pyrene 4.14E-07 0.0002

Dibenz(a,h) anthracene 3.46E-07 0.0001

Benzo(g,h,i) perylene 5.56E-07 0.0002

 a Gaseous emission factors expressed in pounds per million British thermal unit (lb/MMBtu)

 b To convert from lb/MMBtu to ng/J, multiply by 430
Submarine Emergency Diesel Engine Wet Exhaust

11

Table 3. Estimated Concentrations of Exhaust Constituents in Wet Diesel Exhaust (mg/L)

Submarine Class:

Engine Power/Exhaust Rate:

SSN688, LA Class

(800kW, 6500 cfm)

SSBN 726, Ohio Class

(1000kW, 8600 cfm)

SSN 637, Sturgeon

(460kW, 3600 cfm)

Exhaust Constituents

Benzene .000018 .000017 .000019

Toluene .000005 .000005 .000006

Xylenes .000004 .000004 .000004

Formaldehyde .005749 .005431 .005969

Acetaldehyde .00018 .00017 .000187

Acrolein .000006 .000006 .000006

NOx .013364 .008234 .009049

CO .001814 .001714 .001884

CO2 9.028866 8.530179 9.373719

Naphthalene .000038 .000036 .00004

Acenaphthylene .0000004 .0000004 .0000005

Acenaphthene .000002 .000002 .000003

Fluorene .000019 .000018 .00002

Phenanthrene .000129 .000122 .000134

Anthracene .000003 .000002 .000003

Fluoranthene .0000002 .0000002 .0000002

Pyrene .000039 .000037 .000041

Benzo(a)anthracene .000039 .000036 .00004

Chrysene .000105 .000099 .000109

Benzo(b)fluoranthene .000007 .000006 .000007

Benzo(k)fluoranthene .0000004 .0000004 .0000004

Benzo(a)pyrene .000012 .000011 .000012

Indeno(1,2,3-cd) pyrene .000434 .00041 .00045

Dibenz(a,h) anthracene .000339 .00032 .000352

Benzo(g,h,i) perylene .000751 .00071 .00078

Note: Concentrations have been based on a water temperature of 600F. Bold indicates that water quality criteria is

exceeded (see Table 5).
Submarine Emergency Diesel Engine Wet Exhaust

12

Table 4. Fleet-Wide Estimated Annual Mass Loadings of Wet Diesel Exhaust Constituents

Within 12 n.m. of Shore

Submarine Class: SSN688 Class SSBN 726 Class SSN 637 Class

Engine Power: 800 kW 1000 kW 460 kW TOTAL

Exhaust Rate: 6500 cfm 8600 cfm 3600 cfm FLEET WIDE

No. Vessels: 56 Vessels 17 Vessels 13 Vessels

Constituent (kg) (kg) (kg) (kg) (lbs)

Polycyclic Aromatic

Hydrocarbons (PAHs)

Naphthalene 0.00033 0.00013 0.00005 0.00051 0.00112

Acenaphthylene 0.000004 0.000001 0.000001 0.000006 0.00001

Acenaphthene 0.00002 0.00001 0.000003 0.00003 0.00007

Fluorene 0.00017 0.00006 0.00002 0.00025 0.00056

Phenanthrene 0.00112 0.00042 0.00017 0.00171 0.00378

Anthracene 0.00002 0.00001 0.00000 0.00003 0.00008

Fluoranthene 0.000002 0.0000008 0.0000003 0.000003 0.00001

Pyrene 0.00034 0.00013 0.00005 0.00052 0.00115

Benzo(a)anthracene 0.00034 0.00013 0.00005 0.00051 0.00113

Chrysene 0.00091 0.00035 0.00014 0.0014 0.00308

Benzo(b)fluoranthene 0.00006 0.00002 0.00001 0.00009 0.0002

Benzo(k)fluoranthene 0.000003 0.000001 0.0000005 0.00001 0.00001

Benzo(a)pyrene 0.00010 0.00004 0.00002 0.00016 0.00035

Indeno(1,2,3-cd) pyrene 0.00377 0.00143 0.00057 0.00577 0.01272

Dibenz(a,h) anthracene 0.00295 0.00112 0.00044 0.00451 0.00995

Benzo(g,h,i) perylene 0.00654 0.00247 0.00098 0.01 0.02204

Note: Bold indicates that water quality criteria is exceeded (see Table 5).
Submarine Emergency Diesel Engine Wet Exhaust

13

Table 5. Comparison of Discharge Concentrations and Water Quality Criteria (μg/L)

Constituent Estimated Discharge

Concentration1

Federal Acute

WQC

Most Stringent State

Acute WQC

Polyaromatic

Hydrocarbons (PAHs)

Acenaphthylene 0.0005 None 0.031 (FL)2

Phenanthrene 0.134 None 0.031 (FL)2

Benzo(a)anthracene 0.04 None 0.031 (FL)2

Chrysene 0.109 None 0.031 (FL)2

Benzo(b)fluoranthene 0.007 None 0.031 (FL)2

Benzo(k)fluoranthene 0.0004 None 0.031 (FL)2

Benzo(a)pyrene 0.012 None 0.031 (FL)2

Indeno(1,2,3-cd) pyrene 0.45 None 0.031 (FL)2

Dibenzo (a,h) anthracene 0.352 None 0.031 (FL)2

Benzo(g,h,i) perylene 0.78 None 0.031 (FL)2

Total PAHs21.89 0.031 (FL)2

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most

stringent (dissolved or total) state water quality criteria.

Bold number indicates that water quality criteria is exceeded.

HI = Hawaii

FL = Florida

1: Highest concentration of three submarine classes

2: Florida criteria for total PAHs is for the total of the following individual PAH compounds:

acenaphthylene, benzo-(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene,

benzo(k)fluoranthene, chrysene, dibenzo(a,h)anthracene, indeno(1,2,3-cd)pyrene, and phenanthrene.

Estimated discharge concentrations for total PAHs represent a sum of these chemicals.

Table 6. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and Operation X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X

3.3 Constituents X X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX X
Submarine Emergency Diesel Engine Wet Exhaust

14

Calculation Sheet

Benzene

Background:

Henry’s Law was used to estimate the concentration of components in wet exhaust from submarine

emergency diesel engines. This calculation sheet shows the calculation for the concentration of benzene in

the wet exhaust of SSN 688 Class submarines. Calculations for the other exhaust components were similar.

An energy balance was used to determine the approximate wet exhaust equilibrium temperature. The

resulting temperature was determined using an air exhaust flow rate of 6,500 cfm at 200 °F, and a water

injection rate of 11.5 gpm at 60 °F. For this calculation, we assume the exhaust gas to have similar thermal

properties to air.

ΔH: Change in enthalpy, m: mass of air or water, Cp: Specific heat capacity of air or water

ΔHexhaust gas = ΔHwater

ΔHexhaust gas = mCp (200°F-T)

= (6,500 ft3/min.) (0.0601 lbm/ft3 ) (0.24 Btu/lbm°F) (200°F - T)

= 93.76 Btu/°F-min. ( 200°F-T) (1)

ΔHwater = mCp (T-60°F) = (11.5 gal/min.) (8.345 lbm /gal) (1 Btu/ lbm °F) (T-60°F)

= 95.97 Btu/°F-min. (T-60°F) (2)

Setting (1) = (2) we obtain the following:

93.76 Btu/°F-min. (200°F -T) = 95.97 Btu/°F-min. ( T-60°F)

93.76 (T) + 95.97 (T) = 200°F (93.76) + 95.97 (60°F)

T = 129.18 °F = (9/5) °C + 32 = 54°C

This temperature was then used to determine the appropriate values for Henry’s Law

constants, which vary with temperature.

At dilute concentrations, the concentration of benzene dissolved in water can be found from Henry’s Law:

Xa, exhaust = (Ha) (Xa, water) / (Pt)

Where:

Xa, exhaust : Mole Fraction of Benzene in Exhaust

Ha : Henry’s Law Constant (atm)

Xa, water : Mole Fraction of Benzene in Water

Pt : Total Exhaust Pressure (atm)

Rearranging, Henry’s Law can be rewritten as:

Xa, water = (Xa, exhaust ) (Pt) / Ha

The mole fraction of benzene in exhaust can then be converted into a concentration of benzene in the wet

exhaust in mg/L using the molecular weight of benzene.

Given Conditions and Assumptions:

55.56 moles H2O in 1 liter [ (mole H2O / 18 g H2O) (1000g / Liter H2O) = 55.56 moles H2O/L ]

Exhaust temperature of 200°F (Reference 3)
Submarine Emergency Diesel Engine Wet Exhaust

15

6,500 cfm air exhaust flow rate for 800 kW diesel engine

0.334 ng/J generation rate of benzene

Backpressure on engine is approximately 70% above atmospheric when surfaced (Pt = 1.70 atm)

Molecular weight of benzene is 78.11 grams per mole (78,110 mg/mole)

Based on a water temperature of 54 °C (327.15 K), Henry’s Law constants (in atm) for the constituents are

the following:

Constituent Ha (atm)

Benzene 7.30 E+03

Toluene 8.89E+03

Xylenes 8.56E+03

Formaldehyde 2.30E+00

Acetaldehyde 2.34E+01

Acrolein 2.22E+02

Nox

4.01E+04

CO 7.85E+04

CO2

3.06E+03

Naphthalene 5.71E+02

Acenaphthylene 3.45E+03

Acenaphthene 3.19E+02

Fluorene 1.13E+02

Phenanthrene 5.31E+01

Anthracene 7.96E+01

Fluoranthene 2.92E+03

Pyrene 1.59E+01

Benzo(a)anthracene 2.70E+00

Chrysene 2.44E+00

Benzo(b)fluoranthene 2.77E+01

Benzo(k)fluoranthene 9.17E+01

Benzo(a)pyrene 3.61E+00

Indeno(1,2,3-cd) pyrene 1.60E-01

Dibenz(a,h) anthracene 1.71E-01

Benzo(g,h,i) perylene 1.24E-01

The conversion of Henry’s Law constants into common units is presented at the end of the calculation sheet.

Solution:

1) Total number of moles per cubic foot in the air exhaust, including constituents and circulated air, nt

The number of moles per cubic foot can be determined using the ideal gas law; PV = ntRT

Where:

P: Pressure within the exhaust piping, 1.7 atm

V: Volume of space occupied by gas (assume 1 ft3)

R: Gas constant, 0.08206 L-atm/ K-mol

T: Temperature, 327.15 K

Rearranging the ideal gas law equation and solving for nt/V yields:

nt /V = P/RT

nt /V = (1.7atm) (28.32 L/ ft3) / (( 0.08206 L-atm/ K-mol) (327.15 K))

= 1.79 moles/ ft3

2) Concentration of benzene in air exhaust, Ab
Submarine Emergency Diesel Engine Wet Exhaust

16

Ab= (0.334 ng/J) (800 kW) (3.6 x 106 J/kW-Hr) (10-9g/ng) (1000 mg/g) (min./6500 ft3) (Hr/60 min.)

Ab= 2.47 x 10-3 mg/ft3 = (2.47 x 10-3 mg/ft3) ( g/1000 mg) ( mole benzene / 78.11 g)

= 3.17 x 10-8 moles benzene/ft3 exhaust

3) Mole fraction of gas in exhaust, Xa, exhaust

Xa, exhaust = Ab/total molar concentration

Xa, exhaust = (3.17 x 10-8 moles benzene/ ft3 exhaust) / (1.79 total moles/ ft3 exhaust)

Xa, exhaust = 1.77 x 10-8 moles benzene/ mole exhaust

4) Mole fraction of gas in water, Xa, water

Xa, water = (Xa, exhaust) (Pt) / Ha

Xa, water = (1.77 x 10-8) (1.70 atm) / 7300 (atm)

Xa, water = 4.12 x 10-12 moles benzene / mole water

5) Concentration of gas in water:

Per 1 liter of water;

Moles benzene = (4.12 x 10-12 moles benzene / mole H2O) (55.56 moles H2O/ 1 liter) = 2.29 x 10-10 moles/L

(2.29 x 10-10 moles/L ) (78.11 g benzene/mole) = 1.8 x 10-8 g/L benzene

(1.8 x 10-8 g/L) (1000 mg/g) = 1.8 x 10-5 mg/L benzene
Submarine Emergency Diesel Engine Wet Exhaust

17

Determination of Henry’s Constants

Henry’s constants for the constituents of concern were available, but units and temperature for the constants varied

between the references used. Henry’s constants with the following units were available:

1) H1, atm

2) H2, atm-m3/mol

For purposes of clarity, the same calculation was used for each constituent of concern. It was therefore

necessary to convert all of Henry’s constants to atm units, (1).

1) Conversion from H2 (atm-m3/mol) to H1(atm):

H1 = (H2 in atm-m3/mol) (55.6 mol water / L) (L / 10-3 m3 water) = H2 * (55,600)

Henry’s constants with the following temperatures in degrees Celsius were available:

(1) 20 oC

(2) 24 oC

(3) 25 oC

(4) 40 oC

Henry’s constants increase on average about threefold for every 10 oC rise in temperature for most volatile

hydrocarbons.a Therefore, the constants will increase by a factor of ΔH = 3(ΔT/10). All of the constants were

converted to 54 oC constants using the following conversions

For Henry’s constant at 54 oC, and converting from Henry’s constants at 20 oC, 24 oC, and 25 oC

respectively:

H54 = (H20) (41.9)

H54 = (H24) (27)

H54 = (H25) (24.2)

H54 = (H40) (4.66)

Example - Henry’s Constant Calculation

For Acrolein, Henry’s constant was available in atm-m3/mol for 20 oC (Ha = 9.54 x 10-5)

Therefore, at 54°C, Henry’s constant will be:

Ha (atm) = (9.54 x 10-5 atm-m3/mol) (55,600 mol/m3) (41.9)

Ha = 222 atm

Using this approach, the constants were converted to atm units as shown in the table on the following page.
Submarine Emergency Diesel Engine Wet Exhaust

18

Table of Henry’s Constants

Temperature 54 oC 20 oC 25 oC 40 oC Ha for 54 oC

Source Cooperb USEPAc Mackayd CH2M Hille

Units (atm) (atm-m3/mol) (atm-m3/mol) (atm-m3/mol) (atm)

Benzene 5.43E-03 7.30 E+03

Toluene 6.61E-03 8.89E+03

Xylenes 6.37E-03 8.56E+03

Formaldehyde 9.87E-07 2.30E+00

Acetaldehyde 9.05E-05 2.34E+01

Acrolein 9.54E-05 2.22E+02

NOx 4.01E+04 4.01E+04

CO 7.85E+04 7.85E+04

CO2 3.06E+03 3.06E+03

Naphthalene 4.24E-04 5.71E+02

Acenaphthylene 1.48E-03 3.45E+03

Acenaphthene 2.37E-04 3.19E+02

Fluorene 8.39E-05 1.13E+02

Phenanthrene 3.95E-05 5.31E+01

Anthracene 5.92E-05 7.96E+01

Fluoranthene 2.17E-03 2.92E+03

Pyrene 1.18E-05 1.59E+01

Benzo(a)anthracene 1.16E-06 2.70E+00

Chrysene 1.05E-06 2.44E+00

Benzo(b)fluoranthene 1.19E-05 2.77E+01

Benzo(k)fluoranthene 3.94E-05 9.17E+01

Benzo(a)pyrene 1.55E-06 3.61E+00

Indeno(1,2,3-cd) pyrene 6.86E-08 1.60E-01

Dibenz(a,h) anthracene 7.33E-08 1.71E-01

Benzo(g,h,i) perylene 5.34E-08 1.24E-01

Bold: Original Referenced Number

a. Kavanaugh, Michael C. and R. Rhodes Trussell, Design of Aeration Towers to Strip Volatile

Contaminants from Drinking Water. American Water Works Association, December, 1980.

b. Cooper, David and F. Alley, Air Pollution Control, A Design Approach. Waveland Press, Inc., 1986.

c. United States Environmental Protection Agency Office of Air Quality Planning and Standards.

Ground-Water and Leachate Treatment Systems Manual. R-94, January 1995.

d. Mackay, Donald and Wan Ying Shiu, A Critical Review of Henry’s Law Constants for Chemicals of

Environmental Interest. University of Toronto, Canada, 1981.

e. CH2M Hill. Bay Area Sewage Toxic Emissions Model. Version 3, 1992.
Submarine Outboard Equipment Grease and External Hydraulics

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS are being developed in three phases. The first phase (which this

report supports) will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs) -- either equipment or management practice. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Submarine Outboard Equipment Grease and External Hydraulics
Submarine Outboard Equipment Grease and External Hydraulics

2

2.0 DISCHARGE DESCRIPTION

This section describes the submarine outboard equipment grease and external hydraulics

discharge and includes information on: the equipment that is used and its operation (Section

2.1), general description of the constituents of the discharge (Section 2.2), and the vessels that

produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

This discharge occurs when grease applied to a submarine’s outboard equipment is

released to the environment by erosion from the mechanical action of the seawater while the

submarine is underway and, to a much lesser extent, by slow dissolution of the grease into

seawater. The discharge also includes any hydraulic oil that could leak past the seals of the

hydraulically operated external components of a submarine.

2.1.1 Grease from Outboard Equipment

Submarine outboard equipment that requires lubrication includes steering and diving

control mechanisms and control surface bearings. Grease is applied quarterly while a submarine

is in port.1 Figure 1 shows the various grease points on a submarine that can come into contact

with seawater under partially or completely submerged conditions. Of these, the ones that are

operated within 12 nautical miles (n.m.) and could release grease to the environment are the

retractable bow planes, and the fairwater (sail planes). The retractable bow plane components

require the largest amount of grease for operation. Figure 2 is a cut-away diagram of the

retractable bow plane cavity where grease is applied to its various components.

Bow Plane Mechanisms. The retractable bow planes are a set of fins or control surfaces

that are housed within the envelope of the hull and are extended to provide depth control while

the submarine is moving underwater. These bow planes have mechanisms that slide in and out

causing the bow planes to change position in response to commands from the helm. The sliding

components are lubricated by an automatic system that applies grease every time they move back

and forth. This movement may cause some grease to loosen and detach from the components

and deposit in the bow plane compartment (20 feet wide by 6 feet long by 5 feet high) which is in

contact with the sea through a narrow, half-inch-wide gap around each bow plane. Because of

this relatively narrow opening to the sea as well as a protective brush that covers this gap

completely around the retractable bow plane, the probability of loose grease in the cavity

washing out of the compartment is low. Currently, only 22 submarines have retractable bow

plane compartments, but future design trends will increase this number.2

Fairwater Plane Mechanisms. Submarines that do not have retractable bow planes have

control surfaces that perform a similar function, but which are located on the sail structure.

These are the fairwater planes. Currently, there about 72 submarines in the fleet with fairwater

planes. Fairwater planes have components similar to the retractable bow planes that also

lubricated by greasing, but the components do not contact seawater while the submarine is within
Submarine Outboard Equipment Grease and External Hydraulics

3

12 n.m. because the fairwater planes are located well above the water line when the submarine is

surfaced.

2.1.2 External Hydraulics

The external hydraulic system on a submarine supplies hydraulic fluid under pressure to

operate the following equipment:

• masts (e.g. radio antennas, radar, electronic counter measures, etc.), periscopes, and

their associated fairings (e.g., hydrodynamic covers for the various masts and

periscopes needed to reduce the turbulence while the submarine is running submerged

with the masts and/or periscopes raised);

• retractable bow plane actuator mechanisms; and

• secondary propulsion motor hoist cylinders located outside the pressure hull.

Figure 3 shows the location of masts, antennas, and periscopes on a submarine’s hull.

The secondary propulsion motor hoist cylinders (not shown in the figure) are located in an aft

ballast tank.

Navy submarines use specially formulated oil in their external hydraulic systems. The

hydraulic oil is normally pressurized to approximately 1,400 pounds per square inch (psi) and

stored in a reservoir that holds approximately 200 gallons. The total amount of hydraulic oil in

the system, including that in piping and the reservoir, is approximately 250 gallons. On

submarines that have hydraulically-operated retractable bow planes (22 of 94 submarines), the

total amount of hydraulic oil is approximately 400 gallons.3 Of those items identified above

operated by the external hydraulic system, only the retractable bow plane actuator mechanisms

will have any possible release to the environment. In the case of the masts, antennas, and

periscopes, they are located well above the waterline, well away from any contact with the

seawater, where there is no possible erosion of the any oil film generated by the equipments’

operation. In the case of the secondary propulsion motor, it is only operated in rare emergency

situations, and as such is not covered by the UNDS criteria.

2.2 Releases to the Environment

Grease transport is produced through the mechanical action of the water against

components covered with grease. Underway, some of the loose grease in the bow plane

compartment can be eroded by the mechanical action of the flowing seawater. The amount of

grease released is directly proportional to the force of turbulent water in the vicinity of the grease

resulting in erosion, which, in turn, is directly proportional to submarine speed. Within 12 n.m.,

a submarine’s speed is low by comparison to its speed when submerged. It increases speed once

it submerges. Therefore, the amount of mechanical erosion within the 12 n.m. zone is less than

when the submarine is in open ocean.
Submarine Outboard Equipment Grease and External Hydraulics

4

Very little, if any, grease is discharged when a submarine is pierside because the outboard

equipment is not being actuated, and the erosive action of seawater is minimal when the

submarine is stationary.

Periodically, when the submarine is dry docked (typically every two years), grease that

has accumulated in the retractable bow plane compartment is removed and disposed of in an

approved manner by a qualified shore facility.1

Under normal operating conditions, little hydraulic oil is released within 12 n.m. of shore.

Within this zone, the snorkel masts and the antennas are above the water line and do not contact

seawater (except for an occasional sea spray). Hydraulic oil may be released when the external

hydraulic systems are tested during outbound transits. Leaked oil, if any, is likely to be small

quantities that adhere to the component surface. Only when the submarine submerges (beyond

12 n.m.) will the oil be washed away. Oil releases from bow planes generally remain in the

upper area of the cavities surrounding the planes. Because of the small size, configuration,

location of the bow plane cavity opening, and minimal seawater turbulence, transport of trapped

oil to the sea is unlikely. Further, only 22 of the 94 submarines in service have hydraulically

operated bow planes. The secondary propulsion motor is available as a backup option to

maneuver close to port when needed. Typically, tugs are available for this purpose and the

secondary propulsion motor is not used under normal operating circumstances.

2.3 Vessels Producing the Discharge

All submarines have lubricated outboard equipment and external hydraulic systems.

Because all submarines belong to the Navy, this discharge is not produced by vessels belonging

to the Army, Air Force, U.S. Coast Guard, and the Military Sealift Command.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas; Section 3.2 describes the rate of the discharge; Section 3.3 lists the constituents in

the discharge; and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Outboard equipment grease can be discharged within 12 n.m. of shore. The amount is

dependent on how much contact there is between the seawater and the greased components, and

how fast the vessel is traveling. Most hydraulically operated outboard equipment does not

contact seawater within 12 n.m. of shore because submarines usually run surfaced in this zone

and the outboard equipment is mostly above the waterline. Submarine dive points are outside the

12 n.m. zone except for those dive points off the coast of the Hawaiian islands and Washington

state.4,5
Submarine Outboard Equipment Grease and External Hydraulics

5

3.2 Rate

This discharge is the washout of oil and grease when lubricated components and

components with hydraulic oil come in contact with flowing seawater.

Grease. A rough estimate of grease discharge can be made based on the total amount

used. Each attack submarine (SSN) uses approximately 425 pounds of grease annually, while

each missile submarine (SSBN) uses an estimated 800 pounds annually.2 Approximately 81% of

the submarine fleet are SSNs and 19% are SSBNs. On a weighted average basis, therefore, each

submarine uses approximately 496 pounds of grease each year.

The grease is released primarily by the mechanical action of the seawater against the

greased submarine components and, therefore, happens only when the submarine is underway.

Each submarine enters and leaves port approximately six times per year.3,6 A typical one-way

trip through the 12 n.m. zone lasts approximately 4 hours; therefore, the total annual transit time

through that zone is 48 hours per submarine ((6) (4) (2) = 48).6 A submarine typically spends 6

months, or 183 days, moving in the water so transit time accounts for less than 1.1% of this total

time at sea. Therefore, 1.1% of the total grease used can be assumed to be released during

transits.3,4. The resulting 1.1% of the 496 pounds of grease per vessel per year is equivalent to a

discharge rate of approximately 5.5 pounds of grease for each vessel per year within 12 n.m.

Hydraulic Oil. Hydraulic oil is retained in the system by internal and external seals; the

former prevents hydraulic oil from leaking into the submarine, while the latter prevents oil from

leaking outside the hull. Because some leaks still occur, the Navy has established acceptable

leak rates.7 For newly installed seals, the specification allows “a slight wetting of the tailrod or

other visible part of the sealing area.” In addition to the “slight wetting” qualitative criterion, the

specification also provides a quantitative leak rate standard of one drop every 25 cycles for each

inch (or fraction) of rod (length) or seal diameter. For example, a cylinder with a 2.25-inch

diameter rotating tailrod would be allowed to leak at a rate of three drops every 25 cycles. A

cycle is defined as moving from a fully retracted position to a fully extended position and back.7

The specification also contains seal replacement criteria. If leaks occur when a

component is not operating, the seal should be replaced when the leak rate is four milliliters (mL)

or more per hour for each inch (or fraction) of seal diameter. If leaks occur when a component is

cycled, the seal should be replaced when a leak rate of one mL or more per inch of seal diameter

(or fraction) for every 10 cycles is observed.

Leak rate standards can be used to estimate the amount of oil that leaks into the sea from

external hydraulic systems seals. For example, the two bow planes, when deployed, are each 7.5

feet long. At a rate of one drop of oil every 25 cycles for each inch of rod length, the acceptable

leak rate for the two diving planes, which are a combined 15 feet long, is 180 drops (15 feet =

180 inches) every 25 cycles. Assuming that 10 drops are equivalent to one mL,2

 18 mL of oil

will leak every 25 cycles. Therefore, each time the bow planes are extended and retracted (one

cycle), approximately 0.72 mL (18 mL/ 25 cycles) of oil will be released but will likely remain in

the bow plane cavity. Assuming six outbound transits per year for each vessel and that the vessel
Submarine Outboard Equipment Grease and External Hydraulics

6

cycles its retractable bow planes twice during each transit, this would result in a discharge rate of

8.64 mL of oil discharged per vessel per year. This calculation assumes that external hydraulic

systems are tested during outbound transits only.

3.3 Constituents

This discharge consists of Termalene #2 grease and hydraulic oil. Termalene #2 consists

of mineral oil, a calcium-based rust inhibitor, an antioxidant, and dye.8 Hydraulic oil consists of

heavy paraffinic distillates and additives.

In general, greases are made from lubricating stocks generated during petroleum

fractionation. These fractions contain organic compounds (C17 or higher). Lubricating oils are

composed of aliphatic, olefinic, naphthenic (cycloparaffinic), as well as aromatic hydrocarbons,

depending on their specific use. Lubricating oil additives include antioxidants, bearing

protectors, wear resisters, dispersants, detergents, viscosity index improvers, pourpoint

depressors, and antifoaming and rust-resisting agents.9 Lubricating oils and greases could have

priority pollutants. No bioaccumulators are expected.

3.4 Concentrations

The discharge consists of 100% grease and oil in their pure form as they are washed away

from the vessel’s surface due to mechanical action of water. Because the oil or grease do not

become mixed with water until they contact the surrounding seawater, concentrations in the

discharge cannot be defined in the conventional sense. It is known that the hydraulic oil consists

of 95-99% heavy paraffinic distillates.10 The remainder consists of additives.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of discharge

and its potential impact on the environment can be evaluated. The estimated mass loadings are

presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents after release

to the environment are estimated and compared with the water quality criteria. In Section 4.3,

the potential for transfer of non-indigenous species is discussed.

4.1 Mass Loading

4.1.1 Grease From Outboard Equipment

Using the assumption that 100% of the applied grease is washed away, the annual amount

of grease discharged by each submarine within 12 n.m. is 1.1% of the total grease used (Section

3.2), or approximately 5.5 pounds per vessel per year. Based on 94 submarines, the total amount

of grease discharged within 12 n.m. on an annual basis is 517 pounds.

4.1.2 External Hydraulics
Submarine Outboard Equipment Grease and External Hydraulics

7

Based on a per vessel discharge rate of 1.44 mL per vessel per transit (six transits per

vessel per year) or 8.64 mL per vessel per year and given that there are 22 submarines currently

existing in the fleet that contribute to this discharge, the fleet wide mass loading is 190 mL per

year. This is equivalent to 0.0029 pound (lb) per vessel per transit (at a density of 7.51 lb/gallon)

or 0.3755 lb of oil released per year by the entire submarine fleet.

4.2 Environmental Concentrations

As a submarine moves, it creates a disturbance in the surrounding seawater. This

disturbed volume of seawater may be thought of as a mixing zone in which discharges from the

submarine would be dispersed. This volume of seawater was estimated and used in

concentration calculations. A sample calculation for a SSN 688 Class submarine is presented

below. The calculation was based on the following assumptions:

• SSN 688 Class submarine has a total width of 33 feet.11

• Width is the diameter of the vessel’s cross section.

• A mixing zone of 10 feet around the hull, based on the width of wake behind a

typical SSN.

• The discharge is mixed uniformly throughout the mixing zone over the entire

transit.

• The submarine is only partially submerged, at an approximate depth of 28 feet

The width of submarines ranges from 31.8 feet (SSN 637 Class) to 42.3 feet (SSN 21

Class).11 Therefore, the range of volume of water swept, using similar calculations to those

above, would be 118 million cubic feet to 158 million cubic feet per submarine per transit.

4.2.1 Grease from Outboard Equipment

To develop environmental concentration estimates for grease, it is assumed that the 5

pounds of grease discharged per year are evenly distributed over the 12 transits through the 12

n.m. zone. Therefore, for each transit, approximately 0.46 pound (5.5 pounds of grease per

submarine per year divided by 12 transits per year) of grease is discharged. Based on the

previous calculations, the smallest volume of water swept by a submarine is 118 million cubic

feet by the SSN 637 Class. Therefore, the concentration in the environment was estimated as

1) Cross-sectional area = (area of submarine cross section and disturbed width) - (area of the

chord representing that portion of the circle above the surface of the water)

area = [(3.14) (33/2 + 10)2] - [area of a chord of height 15 ft of a circle of radius 26.5 ft]

area = 2,206 ft2 - 514 ft2 = 1692 ft2

2) Volume of water swept = (area) (12 n.m. distance)

volume = (1,692 ft2) (72, 960 ft) = 1.23 x 108 ft3, or 123 million cubic feet
Submarine Outboard Equipment Grease and External Hydraulics

8

presented below: (Note: The calculations were based on the area swept by the SSN 637 class

hull as it represents the smallest swept area.)

0.46 pound of grease ÷ 1.18 x 108 ft3 of water

= 208.6 g of grease in 3.34 x 109 Liters of water

= 6.2 x 10-8 g/L = 0.062 μg/L

This estimated concentration was based on 100% of the grease being washed away. Most

grease discharged remains in hull cavities and is removed from the submarine during

maintenance. Although open to seawater, the 0.5-inch-wide gaps around retractable bow planes

are well shielded by close-fitting brushes, and the seawater in the compartment or cavity is

quiescent compared to water moving over the hull. Therefore, the rate of grease erosion will be

lower than the amount calculated.

4.2.2 External Hydraulics

To estimate environmental concentrations for hydraulic oil, the following assumptions are

made:

- Volume of water swept by the submarine is 118 million ft3 or 3.34 x 109 liters per

transit.

- The discharge rate of hydraulic oil is 0.0029 lb per vessel per transit uniformly

distributed throughout the transit.

Based on the above assumptions, the environmental concentration can be estimated as follows:

1) Oil released = 0.0029 lbs = 1.32 g of oil released per vessel per transit

2) Concentration = (g of oil released) ÷ (liters of water)

 = (1.32 g) ÷ (3.34 x 109 L)

 = 3.95 x 10-10 g/L = 3.95 x 10-4 μg/L

4.2.3 Total Releases

Based on the environmental concentrations estimated above, the total oil & grease

concentration in the surrounding water would be the sum of individual concentrations, i.e., 0.062

μg/L + 0.000395 μg/L = 0.062395 μg/L, or approximately 0.06 μg/L. This concentration does

not exceed federal discharge standards and state water quality criteria as shown in Table 1.

4.3 Potential for Introducing Non-Indigenous Species

Non-indigenous species are not introduced by this discharge because seawater is not

taken aboard or discharged when this discharge is generated.
Submarine Outboard Equipment Grease and External Hydraulics

9

5.0 CONCLUSIONS

The submarine outboard equipment grease and external hydraulics system discharge has a

low potential to cause an adverse environmental effect. This is due to the small amounts of

lubricant released when the vessel is underway is dispersed to concentrations below water quality

criteria. The estimated concentrations of oil and grease in the environment that results from

movement of submarines, is 0.06 ppb, which is far below Federal and most stringent state water

quality criteria. These concentrations were estimated based on the volume of water (3.3 billion

liters) swept by a submarine while in transit through the 12 n.m. zone, and the conservatively

estimated amount of oil and grease released during transit (1.44 mL and 0.46 pounds,

respectively).

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information and assumptions were used to estimate the rate of discharge. Based on this estimate

and on the reported concentrations of oil and grease components, the concentrations of oil and

grease in the environment resulting from this discharge were then estimated. Table 2 shows the

sources of the data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting, Submarine Outboard Equipment Grease. September

1, 1996.

2. UNDS Round 2 Equipment Expert Meeting Minutes, March 24, 1997.

3. Personal Communication between Commander, Submarine Forces, Atlantic Fleet, Staff

Environmental Officer, LCDR L. McFarland and Bruce Miller, MR&S. April 28, 1997.

4. Commander, Submarine Forces, Atlantic Fleet, Staff Environmental Officer, LCDR L.

McFarland. CINCLANTFLT meeting with SEA 00T/03L, May 13, 1997.

5. Personal Communication between Commander, Submarine Forces Pacific Fleet, Staff

Environmental Officer, LCDR W. Jederberg and Bruce Miller, MR&S, Sept 11, 1997.

6. Pentagon Ship Movement Data for Years 1991-95, March 4, 1997.

7. Naval Ship's Technical Manual (NSTM), Chapter 556, Revision 2, Hydraulic Equipment

Power Transmission and Control. pp 11-1 and 11-2. March 1, 1993.

8. Bel-Ray Company, Inc., Material Safety Data Sheet for Termalene #2, May 5, 1998.
Submarine Outboard Equipment Grease and External Hydraulics

10

9. Patty’s Industrial Hygiene and Toxicology, Volume IIB, 3rd Revised Edition, 1981, pp

3369, 3397.

10. Material Safety Data Sheet, Imperial 2075 TH Petroleum Base Hydraulic Fluid, January

1998.

11. Jane's Information Group, Jane's Fighting Ships. Capt. Richard Sharpe, Ed. Sentinel

House: Surrey, United Kingdom, 1996.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.
Submarine Outboard Equipment Grease and External Hydraulics

11

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. 23 March 1995.
Submarine Outboard Equipment Grease and External Hydraulics

12

Table 1. Comparison of Environmental Concentration with Relevant Water Quality

Criteria

Constituent Concentration Federal Discharge Standard Florida Acute Water

Quality Criteria

Oil & Grease 6 μg/L visible sheena

 / 15,000 μg/L b 5,000 μg/L

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

a Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen

on receiving waters.

b

International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as

implemented by the Act to Prevent Pollution from Ships (APPS)

Table 2. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents X

3.4 Concentrations X X

4.1 Mass Loadings X

4.2 Environmental Concentrations X X

4.3 Potential for Introducing NonIndigenous Species

X X
Submarine Outboard Equipment Grease and External Hydraulics

13

Figure 1. Submarine Points of Contact of Grease and Seawater
Submarine Outboard Equipment Grease and External Hydraulics

14

Figure 2. Retractable Bow Plane Arrangement (Typical)
Submarine Outboard Equipment Grease and External Hydraulics

15

Figure 3. Location of Masts, Antennas, and Periscopes
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the armed forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that

have been identified as candidates for regulation under UNDS. The NOD reports were

developed based on information obtained from the technical community within the Navy and

other branches of the armed services with vessels potentially subject to UNDS, from information

available in existing technical reports and documentation, and, when required, from data

obtained from discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contain sections on: Discharge Description,

Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data Sources and

References.

Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

2

2.0 DISCHARGE DESCRIPTION

This section describes the bilgewater/OWS discharge and includes information on: the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

2.1.1 The Bilge Area

The lowest inner part of the hull where liquid drains from the interior spaces and the

upper decks of the vessel is referred to as the bilge. The primary sources of drainage into the

bilge are the main engine room(s) and the auxiliary machinery room(s), which house the vessel’s

propulsion system and auxiliary systems (i.e., steam boilers and water purification systems),

respectively. Other spaces that collect and contain fluid drainage in their bilge are the shaft alley,

steering gear rooms, pump rooms, and air conditioning and refrigeration machinery rooms.

Some oil lab sink drains are also directed to the bilge. The liquid collected in the bilge is known

as “bilgewater” or “oily wastewater”.

2.1.2 Composition of Bilgewater

The composition of bilgewater varies from vessel to vessel; the composition of bilgewater

also varies from day to day on the same vessel. Certain wastestreams, including steam

condensate, boiler blowdown, drinking fountain water, and sink drainage located in various

machinery spaces, can drain to the bilge. The propulsion system and auxiliary systems use fuels,

lubricants, hydraulic fluid, antifreeze, solvents, and cleaning chemicals, as part of routine

operation and maintenance. Small quantities of these materials enter the bilge as leaks and spills

in the engineering spaces. On some older vessels, excess potable water produced by onboard

water purification systems is directed to the bilge, although this practice is being phased out.1 On

some Navy and Coast Guard vessels, water from gas turbine washdowns can contribute to

bilgewater generation; these washdowns are described in the Gas Turbine Water Wash NOD

report.

2.1.3 Bilgewater Treatment and Transfer System

Every surface vessel has an onboard system for collecting and transferring bilgewater.

Vessels pump collected bilgewater to a holding tank which the Navy refers to as the oily waste

holding tank (OWHT). Some vessels are capable of transferring bilgewater from the OWHT to

shore facilities while pierside. OWS systems are installed on vessels, as appropriate, to reduce

the oil content of bilgewater prior to overboard discharge. These systems receive bilgewater

from the OWHT and use gravity-phase separation, coalescence, centrifugal separation, or

combinations of these technologies to treat the waste.

A commonly used Navy OWS is a coalescing plate gravity separator. This type of

separator has a horizontal set of oleophilic plates. Oil droplets rise and coalesce as they flow
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

3

through the plates. The droplets cling to and wet the oleophilic plates once they rise to a plate’s

underside. When sufficient oil has accumulated, large oil droplets rise through weep holes in the

plates and flow to the top of the OWS. The separated oil is then transferred to a waste oil tank

(WOT). Figure 1 is a process flow diagram of the standard OWS system used on most Navy

vessels.

On some vessels, oil content monitors (OCMs) are installed to prevent the discharge of

unacceptable effluent. If the oil content is above the set point limit, the OCM alarms and diverts

the OWS effluent back to the OWHT for reprocessing until an acceptable oil concentration

reading is obtained.

In addition to the oil removed by the OWS, waste oil from routine maintenance is also

collected in the WOT and held for pierside disposal.

Synthetic lubricant oils (SLOs) are not collected in the WOT, and measures are taken to

prevent their introduction into the bilge. SLOs have a specific gravity close to that of water and

cannot be separated in the OWS. These oils are normally found in engine spaces and are

collected in drip pans located underneath the engines. The drip pans drain through segregated

piping to dedicated collection tanks. SLOs within these tanks are disposed of on-shore separately

from non-synthetic waste oils. Therefore, SLOs, except for tank overflows, are not likely to be in

bilgewater at significant levels.

Some ships (e.g., DDG 51 Class destroyers) use non-oily machinery wastewater

collection systems that segregate oily wastewater from non-oily wastewater. These ships collect

non-oily machinery wastewater in dedicated collection tanks instead of the bilge, and discharge it

directly overboard. All oily wastewater collects in OWHTs and is processed by a shipboard

OWS or off-loaded for shore facility treatment.

2.2 Releases to the Environment

Untreated bilgewater is expected to contain oil and grease (O&G), an assortment of

oxygen-demanding substances, and organic and inorganic materials. These materials include

volatile organic compounds (VOCs), semi-volatile organic, inorganic salts, and metals. OWS

effluent releases to the environment contain the same constituents present in bilgewater but with

lower concentrations of O&G and oil-soluble components.

2.3 Vessels Producing the Discharge

All vessels produce bilgewater. OWS systems have been installed on most vessels of the

Armed Forces. Some small boats and craft are not outfitted with OWS systems; thus, bilgewater

is stored for shore disposal. Table 1 lists all surface vessels equipped with OWSs. Submarine

bilgewater is addressed in the Submarine Bilgewater NOD report.

3.0 DISCHARGE CHARACTERISTICS
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

4

This section contains qualitative and quantitative information which characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

The Armed Forces do not discharge untreated bilgewater to surface waters. On ships

without OWS systems, untreated bilgewater is held for transfer to a shore treatment facility.

Bilgewater treated by an OWS can be discharged within or beyond 12 nautical miles (n.m.). On

Navy vessels with an OWS and OCM, oil concentrations must be less than 15 parts per million

(ppm) prior to discharge. However aboard Navy vessels, discharge of bilgewater with an oil

concentration less than 100 ppm is allowed outside 12 n.m. if concentrations less than 15 ppm

cannot be achieved because of operating conditions.

3.2 Rate

Bilgewater generation rates vary by vessel and vessel class because of the differences in

vessel age, shipboard equipment (e.g., type of propulsion system), operations, and procedures.

Vessels with non-oily machinery wastewater collection systems will generate significantly less

bilgewater because of their capability to keep non-oily waste streams out of the bilges. The DDG

51 and CVN 68 class ships are two examples of ship classes that have non-oily machinery

wastewater collection systems. Other factors influencing bilgewater generation rates are whether

a vessel is operating in-port or at-sea, and when in port, whether it is operating in an auxiliary

steaming mode or receiving shore electrical/steam power (cold iron mode). In the auxiliary

steaming mode, a vessel provides its own services while moored at the pier (i.e., power,

freshwater, etc.). In the cold iron mode, a vessel receives these services from shore facilities,

minimizing the amount of shipboard equipment in operation. Older vessels without non-oily

machinery wastewater collection systems have historically generated more bilgewater while

operating in the auxiliary steaming mode than in the cold iron mode because of the discharge of

utilities wastewater to the bilge.

Table 2 shows the in-port bilgewater generation rates for certain destroyers (DD 963 and

DDG 51 Classes) and aircraft carriers (CVN 68 Class). For the destroyers, bilgewater generation

rates were developed by monitoring the levels of bilgewater in the bilges.1,2 Aircraft carrier class

(CVN 68) data was gathered from an analysis of a carrier’s (CVN 74) OWS operator log sheets

in order to determine the amount of bilgewater that had passed through the OWS over an

extended period of time, thus providing an estimate of the bilgewater generation rate.3

Table 3 summarizes the bilgewater/OWS flow rates that were developed for an aircraft

carrier class (CVN 68), “other ship classes,” and the overall fleet based on the average values

from Table 2. The assumptions that were made in developing the estimates are summarized as

follows:
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

5

1. The average and maximum daily bilgewater OWS discharge flow rates for a carrier

(CVN 74) of 3,000 and 25,000 gallons per day (gpd), respectively, represents the

average and maximum daily bilgewater/OWS flow for all aircraft carriers.

2. The destroyer (DD 963) bilgewater flow estimate of 1,000 to 3,000 gpd represents a

typical range of flows for other U.S. Navy surface ship classes. An average of 2,000

gpd is assumed to be the average bilgewater generation rate.

3. Aircraft carriers spend approximately 147 days in port annually.

4. Other ships are in port for approximately 193 days annually.

The calculations used to estimate the total fleet bilgewater OWS effluent discharge to

surface waters within 12 n.m. are presented as follows:

CVN 68 Class

FCVN(flow rate) = (RCVN)(DCVN) (NCVN)

RCVN = ship flow rate, gpd

DCVN = days in port annually per ship

NCVN = number of ships

FCVN = (3,000) (147) (11) = 4.9 million gallons per year

Other Ship Classes

FO(flow rate) = (RO) (DO) (NO)

FO = (2,000) (193) (220) = 84.9 million gallons per year

Overall Fleet

FFLEET = FCVN (million gals/year) + FO (million gals/year)

FFLEET = 4.9 + 84.9 = 89.8 million gallons per year

It should be noted that bilgewater generation rates are based on data available from

existing reports for U.S. Navy ships and does not include “estimates of bilgewater” from ships of

other services.

3.3 Constituents

Information about the constituents of bilgewater comes from several studies conducted

aboard Navy vessels and at Navy ports, in addition to the UNDS Phase I testing. During these
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

6

previous studies, samples of bilgewater were collected from a variety of Navy vessels, including

aircraft carriers, cruisers, destroyers, dock landing ships, tank landing ships, amphibious assault

ships, amphibious transport docks, and submarines. There have been no similar studies or

documentation available for the other services.

Bilgewater samples collected in the previous studies were analyzed for a variety of

parameters, such as classicals, metals, and organics (including pesticides). Over 25 priority

pollutants were identified from these samples, including metals such as arsenic, copper,

cadmium, chromium, lead, mercury, selenium, and zinc; and organics such as benzene, the BHC

isomers (isomers of hexachlorocyclohexane), ethyl benzene, heptachlor, heptachlor epoxide,

naphthalene, phenols, phthalate esters, toluene, trichlorobenzene, and trichloroethane. The

bioaccumulators identified in these samples were the BHC isomers and mercury. A variety of

substances that are neither priority pollutants nor bioaccumulators were also detected, including

metals such as barium and manganese and organics such as chloroform and xylene.

The analytical results from these studies are shown in Tables 4 through 8. The results

provide a general overview of the constituents that have historically been detected in bilgewater

and the effluent from bilgewater OWS treatment.

3.4 Concentrations

The concentrations of constituents detected during UNDS Phase I testing of

bilgewater/OWS effluent samples collected aboard an aircraft carrier (CVN 74) are summarized

in Table 9. Many of the same constituents that were detected in the previous studies were also

detected in the aircraft carrier samples. This includes classicals, oil & grease as indicated by

hexane extractable materials (HEM) or total petroleum hydrocarbons (TPH) as indicated by silica

gel treated hexane extractable materials (SGT-HEM), certain metals, and the bioaccumulator,

mercury. Neither pesticides nor PCBs were detected in the aircraft carrier bilgewater/OWS

samples. Table 10 presents the general statistics of the aircraft carrier data.

Analytical results from previous bilgewater studies are shown in Tables 4 through 8.

These tables provide concentrations of constituents that have historically been detected in

bilgewater and the effluent from bilgewater OWS treatment.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. Estimated constituent

mass loadings are presented in Section 4.1. In Section 4.2, the available concentration data for

the discharge constituents are evaluated, including comparison with federal and state water

quality criteria. In Section 4.3, the potential for the transfer of non-indigenous species is

discussed.

4.1 Mass Loading
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

7

Validated bilgewater/OWS constituent concentration data from the aircraft carrier 4 and

the flow rate estimates referenced in NOD report Section 3.2 were used to estimate the mass

loading of pollutants to the environment. Historical data were not used to estimate mass loadings

because these data were not validated.

Table 11 provides a bilgewater/OWS effluent mass loading summary for all constituents

detected in the aircraft carrier samples. Sampling data have identified copper, nickel, and zinc as

exceeding Federal water quality criteria (in addition to the most stringent state criteria) in the

bilgewater/OWS samples analyzed. Also, the concentrations for ammonia, nitrogen (as

nitrate/nitrite and total kjeldahl nitrogen), phosphorous, iron, and total petroleum hydrocarbons

exceeds the most stringent state water quality criteria.

The constituent loading estimates are based on the assumption that vessels with an onboard OWS system will always process bilgewater through the system and discharge the effluent

overboard while in-port, rather than off-loading untreated bilgewater to shore facilities for

disposal.

Sample calculations for TPH, as indicated by SGT-HEM, are provided to show how the

total fleet constituent discharges to surface waters less than 12 n.m. from shore were calculated.

The assumptions and calculations are presented below.

1. The total amount of OWS effluent discharged annually from aircraft carriers is 4.9 million

gallons (Table 3).

2. The sample data from CVN 74 (Table 10) are assumed to be representative of all aircraft

carriers.

The mass loading of constituents for the entire fleet can be estimated by multiplying the estimate

for aircraft carriers by a discharge ratio. The discharge ratio is the total fleet discharge rate

divided by the total discharge from aircraft carriers. Use of this ratio to estimate fleet mass

loadings assumes sample data from CVN 74 (Table 10) is representative of all vessels of the

armed forces.

M(tph)CVN (pounds/year) = (VCVN (million gals/year)) (CCVN (mg/Liter)) (CF)

where: VCVN = Total bilgewater/OWS generation rate/year

 CCVN = TPH (SGT-HEM) concentration

 CF = conversion factor = 8.34 = (3.785 liters/gal) (1x106 gals/million gals)

 (454 grams/pound) (1,000 mg/gram)

MCVN = (4.9) (9.64) (8.34) = 394 pounds/year
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

8

2. Ratioing the total flow for the fleet (89.8 mgd) to the aircraft carrier class (CVN 68) flow for

(4.9 mgd) , and multiplying the aircraft carrier loading by the ratio.

4.2 Environmental Concentrations

Table 11 identifies bilgewater OWS effluent constituents in the aircraft carrier samples

whose log mean average concentrations (dissolved and/or total) were above Federal water quality

criteria, and/or the most stringent state water quality criteria. With regard to oil concentration

data, the samples were analyzed for HEM and SGT-HEM. The HEM values correspond to oil

and grease and the SGT-HEM values correspond to total petroleum hydrocarbon (TPH) which is

a subset of oil and grease.

4.3 Potential for Introducing Non-indigenous Species

There is a low potential for transporting non-indigenous species in this discharge. There

is only minor seawater access to bilge compartments, and bilgewater is generally processed

before it is transported over long distances.

5.0 CONCLUSIONS

Surface vessel bilgewater and OWS discharges have the potential to cause an adverse

environmental effect for the following reasons:

1) Bilgewater, if discharged without treatment, would contribute significant amounts of oil to the

environment at concentrations exceeding water quality criteria and discharge standards.

2) OWS effluent contributes significant amounts of oil to the environment at concentrations

exceeding water quality criteria and discharge standards.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process

information and assumptions were used to estimate the rate of discharge. Based on this estimate

and on the reported concentrations of oil and grease constituents, the concentrations of the oil

and grease constituents in the environment resulting from this discharge were then estimated.

MFLEET = (FFLEET / Fcvn ) (MCVN)

MFLEET = (89.8/4.9)(394)=7220 pounds/year
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

9

Table 12 shows the source of the data used to develop this NOD Report.

1. Bilgewater Characterization and Generation Surveys Aboard DD-963 Class Ships. April,

1981. David Taylor Naval Ship Research and Development Center. Report #:

DTNSRDC/SME-81/09.

2. In-Port Oily Wastewater Generation on USS ARLEIGH BURKE (DDG 51), NSWCCD-TR63-96/37. November 1996.

3. USS John C. Stennis (CVN 74) OWS log sheets obtained from CVN 74 by J. Jereb of DLS

Engineering Assoc. and submitted to Malcolm-Pirnie via facsimile on February 13, 1997.

4. Correspondence from Commander, Naval Surface Warfare Center, Carderock Division,

Philadelphia Site to Commander, Naval Sea Systems Command (Code 03L13), Uniform

National Discharge Standards (UNDS) Sampling Program Data, Ser 631/225, 1-6310-280,

dated June 19, 1997.

5. The Characterization of Bilgewater Aboard U.S. Navy Ships. October 1992. Naval Surface

Warfare Center Carderock Division. Tech. Report #: CDNSWC/SME-CR-10-91.

6. Weaver, George, An Analysis of Bilgewater. Undated, Analytical data for period from 1993

to 1995. Navy Public Works Center Environmental Department, Naval Station San Diego.

7. Wastewater Characterization Data from USS L Y Spear (AS 36) and USS Carney (DDG 64),

NSWCCD, 6330-270/KA, February 19, 1997, Enclosures (4) and (6).

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

10

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Navy Small Craft Bilge Generation and Characterization. March, 1987. David W. Taylor Naval

Ship Research and Development Center, Report No. DTNSRDC/SME-86/32.

Personal Communication between C. Geiling, Malcolm-Pirnie, and Brian Gordon, NAVSTA San

Diego, Week of February 17, 1997, Topic of discussion: bilgewater characterization.

Environmental and Natural Resources Program Manual, OPNAVINST 5090.1B, Department of

the Navy, November 1, 1994.

Department of Defense (DoD) Directive 6050.15 of 14 June 1985, Prevention of Oil Pollution

from Ships Owned or Operated by the DoD (NOTAL).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.

UNDS Equipment Expert Meeting Minutes. “Surface Vessel Bilgewater and Oily Waste”. July

29, 1996.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

11

Pentagon Ship Movement Data for Years 1991-95, March 4, 1997.

UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

UNDS Ship Database, August 1, 1997.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

12

Figure 1. U.S. Navy Oil Water Separator (OWS) Process Flow Diagram (Typical)
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

13

Table 1. Vessels Equipped With Oil/Water Separator Systems

SHIP CLASSIFICATION INFORMATION TRANSIT

INFORMATION

CLASS ARMED CLASS NO. OF PROPULSION TRAN- DAYS IN

ID NO. SERVICE NAME SHIP TYPE SHIPS SYSTEM SITS PORT

AE 26 MSC Kilauea Ammunition Ship 8 Steam 4 26

AFS 1 MSC Mars Combat Store Ship (ROS) 8 Steam 7 148

AG 194 MSC Vanguard Navigation Research Ship 2 Steam 10 151

AGF 3 NAVY Austin (Converted) Miscellaneous Command Ship 1 Steam NA NA

AGF 11 NAVY Austin (Converted) Miscellaneous Command Ship 1 Steam NA NA

AGM 22 MSC Converted Haskell Missile Range Instrumentation Ship 1 Steam 4 133

AGOS 1 MSC Stalwart Ocean Surveillance Ship 5 Diesel 4 70

AGOS 19 MSC Victorious Ocean Surveillance Ship 4 Diesel 5 107

AGS 26 MSC Silas Bent and Wilkes Surveying Ship 2 Diesel 6 44

AGS 45 MSC Waters Surveying Ship 1 Diesel 1 7

AGS 51 MSC John McDonnell Surveying Ship 2 Diesel 6 96

AGS 60 MSC Pathfinder Surveying Ship 4 Diesel NA NA

AH 19 MSC Mercy Hospital Ship (ROS) 2 Steam 2 184

AKR 287 MSC Algol Vehicle Cargo Ship (ROS) 8 Steam 3 109

AKR 295 MSC NA Vehicle Cargo Ship (ROS) 3 Diesel NA NA

AO 177 NAVY Jumboised Cimarron Oiler 5 Steam 10 188

AO 187 MSC Henry J. Kaiser Oiler 12 Diesel 6 78

AOE 1 NAVY Sacramento Fast Combat Support Ship 4 Steam 11 183

AOE 6 NAVY Supply Fast Combat Support Ship 3 Gas 6 114

AR NAVY Vulcan Repair Ship 6 Steam 8 131

ARC 7 MSC Zeus Cable Ship 1 Diesel 2 8

ARS 50 NAVY Safeguard Salvage Ships 4 Diesel 22 208

AS 33 NAVY Simon Lake Submarine Tender 1 Steam 6 229

AS 39 NAVY Emory S Land Submarine Tender 3 Steam 6 293

ATF 166 MSC Powhatan Fleet Ocean Tug 7 Diesel 16 127

BD ARMY 264B Barge Derrick(Floating Cranes) 12 Diesel NA NA

BO USCG NA Buoy Boat 5 Diesel NA NA

BOSL USCG NA Stern Loading Buoy Boat 14 Diesel NA NA

CG 47 NAVY Ticonderoga Guided Missile Cruiser 27 Gas 12 166

CGN 36 NAVY California Guided Missile Cruiser 2 Nuclear 11 143

CGN 38 NAVY Virginia Guided Missile Cruiser 1 Nuclear 11 161

CV 63 NAVY Kitty Hawk Aircraft Carrier 3 Steam 7 137

CVN 65 NAVY Enterprise Aircraft Carrier 1 Nuclear 6 76

CVN 68 NAVY Nimitz Aircraft Carrier 7 Nuclear 7 147

DD 963 NAVY Spruance Destroyer (Typical) 31 Gas 12 178

DDG 51 NAVY Arleigh Burke Guided Missile Destroyer 18 Gas 11 101

DDG 993 NAVY Kidd Guided Missile Destroyer 4 Gas 12 175

FFG 7 NAVY Oliver Hazard Perry Guided Missile Frigate 43 Gas 13 167

LCC 19 NAVY Blue Ridge Amphibious Command Ship 2 Steam 8 179

LCU ARMY 2000 Utility Landing Craft 48 Diesel NA NA

LHA 1 NAVY Tarawa Amphibious Assault Ship 5 Steam 9 173

LHD 1 NAVY Wasp Amphibious Assault Ship 4 Steam 13 185
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

14

Table 1. Vessels Equipped With Oil/Water Separator Systems (cont'd)

SHIP CLASSIFICATION INFORMATION TRANSIT

INFORMATION

CLASS ARMED CLASS NO. OF PROPULSION TRAN- DAYS IN

ID NO. SERVICE NAME SHIP TYPE SHIPS SYSTEM SITS PORT

LPD 4 NAVY Austin Amphibious Transport Dock 3 Steam 11 178

LPD 7 NAVY Austin Amphibious Transport Dock 3 Steam 12 188

LPD 14 NAVY Austin Amphibious Transport Dock 2 Steam 11 192

LPH 2 NAVY Iwo Jima Amphibious Assault Helicopter

Carrier

2 Steam 11 186

LSD 36 NAVY Anchorage Dock Landing Ship 5 Steam 13 215

LSD 41 NAVY Whidbey Island Dock Landing Ship 8 Diesel 13 170

LSD 49 NAVY Harpers Ferry Dock Landing Ship 3 Diesel NA NA

LST 1179 NAVY Newport Tank Landing Ship 3 Diesel 13 191

LSV ARMY Frank S Besson Vehicle Landing Ship 6 Diesel NA NA

LT ARMY 100 / 130 Large Tug 25 Diesel NA NA

MCM 1 NAVY Avenger Mine Countermeasure Vessel 14 Diesel 28 232

MHC 51 NAVY Osprey Minehunters Coastal 12 Diesel NA NA

WAGB 290 USCG Mackinaw Icebreaker 1 Diesel NA NA

WAGB 399 USCG Polar Icebreaker 2 Diesel 4 139

WHEC 378 USCG Hamilton/Hero Class High Endurance Cutter 12 Diesel 13 151

WIX 295 USCG Eagle Sail Training Cutter 1 Diesel 7 188

WLB 180A USCG Balsam Seagoing Tender 8 Diesel 18 190

WLB 180B USCG Balsam Seagoing Tender 2 Diesel 5 120

WLB 180C USCG Balsam Seagoing Tender 13 Diesel 16 123

WLB 225 USCG Juniper Seagoing Tender 2 Diesel NA NA

WLI 65303 USCG Blackberry Buoy Tender, Inland 2 Diesel NA NA

WLI 65400 USCG Bayberry Buoy Tender, Inland 2 Diesel NA NA

WLI 100A USCG Blue Bell Buoy Tender, Inland 1 Diesel NA NA

WLI 100C USCG Blue Bell Buoy Tender, Inland 1 Diesel NA NA

WLIC 75A USCG Anvil/Clamp Construction Tenders, Inland 2 Diesel NA NA

WLIC 75B USCG Anvil/Clamp Construction Tenders, Inland 3 Diesel NA NA

WLIC 75D USCG Anvil/Clamp Construction Tenders, Inland 2 Diesel NA NA

WLIC 100 USCG Cosmos Construction Tenders, Inland 3 Diesel NA NA

WLIC 115 USCG ? Construction Tenders, Inland 1 Diesel NA NA

WLIC 160 USCG Pamlico Construction Tenders, Inland 4 Diesel NA NA

WLM 157 USCG Red Buoy Tender, Coastal 9 Diesel NA NA

WLM 551 USCG Keeper Buoy Tender, Coastal 2 Diesel NA NA

WLR 65 USCG Ouachita Buoy Tender, River 6 Diesel NA NA

WLR 75 USCG F/Gasconade Buoy Tender, River 13 Diesel NA NA

WLR 115 USCG Sumac Buoy Tender, River 1 Diesel NA NA

WMEC 210A USCG Reliance Medium Endurance Class 5 Diesel 13 235

WMEC 210B USCG Reliance Medium Endurance Class 11 Diesel 9 149
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

15

Table 1. Vessels Equipped With Oil/Water Separator Systems (cont'd)

SHIP CLASSIFICATION INFORMATION TRANSIT

INFORMATION

CLASS ARMED CLASS NO. OF PROPULSION TRAN- DAYS IN

ID NO. SERVICE NAME SHIP TYPE SHIPS SYSTEM SITS PORT

WMEC 213 USCG Diver Medium Endurance Class 1 Diesel 9 98

WMEC 230 USCG Storis Medium Endurance Class 1 Diesel 11 167

WMEC 270A USCG Bear Medium Endurance Class 4 Diesel 6 137

WMEC 270B USCG Bear Medium Endurance Class 9 Diesel 7 164

WPB 82C USCG Point Patrol Craft 28 Diesel NA NA

WPB 82D USCG Point Patrol Craft 8 Diesel NA NA

WPB 110A USCG Island Patrol Craft 16 Diesel 2 72

WPB 110B USCG Island Patrol Craft 21 Diesel 7 137

WPB 110C USCG Island Patrol Craft 12 Diesel 5 157

WTGB 140 USCG Bay Icebreaking Tug 9 Diesel 1 8

WYTL 65A USCG NA Harbor Tug 3 Diesel NA NA

WYTL 65B USCG NA Harbor Tug 3 Diesel NA NA

WYTL 65C USCG NA Harbor Tug 3 Diesel NA NA

WYTL 65D USCG NA Harbor Tug 2 Diesel NA NA

TOTAL: 640 AVG: 9 145

Subtotals:

Navy 231 13 197

MSC 70 5 92

USCG 248 8 140

Army 91 NA NA

Notes:

1. NA = Information not available

2. One transit = travel from one port to another, or from one port to sea and returning back to same port.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

16

Table 2. In-Port Bilgewater Generation Rates1,2,3

Ship Class Gal/Day (Range) Avg Gal/Day

DD 963 1,000-3,000 2,000

DDG 51 N/A 335

CVN 68*5,000-25,000 3,000

* Values based on recording information over a 30 day period. All bilgewater was processed by

the OWS during six individual days, in volumes ranging from 5,000 to 25,000 gallons per

processing event. The total volume processed over 30 days was 91,000 gallons, yielding an

average daily processing rate of 3,000 gallons per day.

Table 3. In-Port Bilgewater/OWS Discharge Rates From U.S. Navy Ships

Average Daily Flow

per Ship (gals/day)

Annual Flow per Ship

 (gals/yr)

Total Annual Flow

(million gals/yr)

Ship Class Days in

Port

Total

Flow

No. of

Ships

Total

Flow

Aircraft Carriers 3,000 147 441,000 11 4.9

All Other Ships (Avg.) 2,000 178 356,000 220 84.9

Total: 89.8
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

17

Table 4. Ship Study Bilgewater Pollutant Summary5

Biddle

CG 34

Vincennes

CG 49

 with OWS

San Jacinto

CG 56

 with OWS

Roosevelt

CVN 71

C. DeGrasse

DD 974

H.W. Hill

DD 986

Belleau

Wood

LHA 3

Vancouver

LPD 2

 with OWS

Pensacola

LSD 38

 with OWS

Manitowoc

LST 1180

 with OWS

Louisville

SSN 724

TSS (mg/L) 1,440 38 19 519 233 548 1205 62 29 114 169

COD (mg/L) 5,600 530 760 5,400 18,000 11,000 66,000 780 470 1,600 1,100

TOC (mg/L) 644 129 34.6 116 264 4,620 19,040 34 31 224 247

BOD (mg/L) 583 NA 6,740 554 >14,000 842 13,000 <142 98 335 0

O&G (mg/L) 46 27 8 1,550 725 765 5,220 20 4 32 164

Phenols(μg/L) 600 110 30 <5,000 <10 40 2,600 10 10 20 310

Cu (μg/L) 6,400 540 430 1,050 5,320 1,180 1,720 790 300 360 1,450

Fe (μg/L) 46,000 810 260 2,560 28,000 18,900 14,600 1,130 1,620 2,600 1,030

Zn (μg/L) 4,300 810 190 1,900 6,560 1,390 16,200 1,590 410 2.5 2,720

Cd (μg/L) 67 10 5 21 156 44 280 <3 <5 14 82

Ag (μg/L) 10 <10 10 <50 <10 <10 80 10 <10 <10 <10

Ni (μg/L) 3,500 270 130 170 890 550 650 400 210 120 1,590

Mn (μg/L) 3,000 220 20 140 1,350 1,150 370 61 110 210 269

Pb (μg/L) 230 20 <20 <30 2,900 30 270 20 50 <50 60

As (μg/L) 3 6 6 3 7 <4 18 10 4 2 4

Ba (μg/L) 170 63 60 85 <100 60 122 16 40 50 57

Note: Values are not necessarily representative. Concentrations were determined from only one sample per ship class per constituent.

NA : Information not available

< : Less than
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

18

Table 5. Ship Study OWS Influent and Effluent Contaminant Concentration Data5

USS VINCENNES

(CG 49)

USS SAN JACINTO

(CG 56)

USS VANCOUVER

(LPD 2)

USS PENSACOLA

(LSD 38)

USS MANITOWOC

(LST 1180)

Parameter Units Influent Effluent Influent Effluent Influent Effluent Influent Effluent Influent Effluent

COD

BOD

TOC

TSS

O&G

Ammonia

Fecal Coliform

mg/L

mg/L

mg/L

mg/L

mg/L

mg/L

cts/100 ml

660

NA

145

34

37

2.2

NA

530

NA

129

38

27

1.1

NA

810

94

56.8

62

143

<0.10

49

760

6,740

34.6

19

8

<0.10

94

900

<142

42

123

47

0.18

NA

780

<142

34

62

20

0.29

NA

520

101

39

41

10

<0.10

110

470

98

31

29

4

<0.10

49

2,800

341

570

2,684

2,593

NA

2

1,600

335

224

114

32

NA

240

Total Phenols

Cyanide

mg/L

mg/L

130

<10

110

<10

10

<10

30

10

10

<30

10

<50

20

10

10

40

NA

<10

20

NA

Arsenic

Barium

Cadmium

Chromium

Copper

Iron

Lead

Manganese

Nickel

Selenium

Zinc

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

4

59

9

<10

830

770

50

230

290

3

800

6

63

10

<10

540

810

20

220

270

<2

810

6

20

<5

<10

490

280

<20

10

100

12

80

6

60

5

<10

430

260

<20

20

130

8

190

8

10

<3

<10

2,930

1,240

40

51

310

15

670

10

16

<3

<10

790

1,130

20

61

400

17

1,590

4

30

<5

<50

560

2,960

<50

80

250

2

380

4

40

<5

<50

300

1,620

<50

110

210

2

410

6

40

17

770

430

2,.900

50

250

120

40

3,000

2

50

14

590

360

2,600

<50

210

120

40

2,500

Bis(2-ethylhexyl) phthalate

4-Nitrophenol

Phenanthrene

1,2,4-Trichlorobenzene

1,1,1- Trichloroethane

μg/L

μg/L

μg/L

μg/L

μg/L

<200

<400

<200

<200

<5

<10

<20

23.7

28.3

<5

<200

<200

<200

<200

<50

<100

<100

<100

<100

<50

11.2

10

<10

<10

NA

61.8

<20

<10

<10

<5

<100

<100

<100

<100

<50

<100

<100

<100

<100

<500

<200

<200

<200

<200

45,000

<200

<200

<200

<200

6,000

Alpha-BHC

Beta- BHC

Gamma-BHC

Heptachlor

Heptachlor Epoxide

μg/L

μg/L

μg/L

μg/L

μg/L

0.047

<0.999

<0.02

0.460

0.379

0.077

<0.580

<0.02

0.209

0.274

<0.05

<0.5

16

<0.05

<0.05

<0.05

<0.5

60

<0.05

<0.05

0.02

4.45

<0.02

<0.02

<0.02

<0.02

<0.10

<0.02

<0.02

<0.02

<0.05

<12

<0.05

<0.05

<0.05

<0.05

<5

0.5

<0.05

<0.05

<0.25

<2.5

<0.25

<0.25

<0.25

<5

<50

<5

<5

<5

NA = Data not available

Note: Values are not necessarily representative. Concentrations were determined from only one sample per ship class per constituent.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

19

Table 6. Naval Station San Diego Bilgewater Characterization Data Summary6

(Calendar Years 1993 through 1995)

Values Above MDL (units in μg/L)

Parameter

No. of

Analyses

No. Of

Values

Min. Max. Median Std. Dev.

Oil & Grease

Phenols

45

83

45

12

5

15

12,900

901

146

116

2,234

0.309

Antimony

Arsenic

Cadmium

Chromium

Copper

Lead

Nickel

Selenium

Silver

Thallium

Zinc

(a)

(a)

84

85

85

85

85

1

84

(a)

82

(a)

(a)

33

31

84

52

83

0

14

(a)

80

(a)

(a)

10

20

10

39

20

NA

4

(a)

100

80

1

610

2,320

80,400

3,360

10,300

NA

1,440

277

97,000

(a)

(a)

20

70

420

100

150

NA

23

(a)

688

(a)

(a)

118

492

9,250

509

1,590

NA

398

(a)

14,500

Benzene

Chloroform

Ethyl Benzene

Methylene Chloride

Tetrachloroethane

Toluene

Xylene

82

81

81

68

82

80

17

29

1

38

18

7

52

12

0.5

47

6

5

7

5

28

179

47

1,360

4,220

74

2,220

9,440

30

47

50

16

18

77

16

42

NA

221

1,000

24

383

2,600

2,4-Dimethyl Phenol

Fluorene

Naphthalene

82

83

79

14

41

37

30

5

11

840

1,890

3,070

89

42

85

23

411

613

NOTES: (a) References contain summary tables and raw data laboratory logs that are incomplete.

 Summary tables indicate single peak results for antimony, arsenic and thallium in 1993.

 However, log sheets showing the corresponding data are not included. The above statistical

 analysis is based on log sheet data that was provided, except for the maximum values shown

 for the three metals, which were obtained from the PWC summary table for 1993.

 (b) NA = Information not available.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

20

Table 7. Navy Destroyer (DDG 64) OWS Effluent Discharge Data Summary7

May to September, 1996

Values Above MDL (μg/L)

Parameter No. of

Analyses

No. Of

Values

Min. Max. Median Std. Dev.

Oil in Water (Navy) 28 28 13 670 151 205

Arsenic

Barium

Cadmium

Chromium

Copper

Lead

Iron

Manganese

Mercury

Nickel

Selenium

Silver

Zinc

11

18

18

18

18

18

18

18

18

18

11

18

18

6

18

3

10

18

15

18

18

2

18

11

1

18

10

30

10

10

430

10

300

20

10

140

70

10

480

70

535

10

60

6,110

195

4,620

150

10

1,510

210

10

8,880

20

118

10

20

1,.410

40

1,280

48

10

320

100

10

2,190

23

124

NA

16

1,400

62

1,210

41

NA

317

40

NA

1,930

July 30, 1996 (μg/L)

Sample A Sample B Sample C

Parameter NRL LLI NRL LLI NRL LLI

Oil and Grease (EPA 418.1)

Petroleum Hydrocarbons

MBAS

---

---

---

29

38

0.13

---

---

---

70

73

0.11

---

---

---

66

70

0.16

Benzene

Ethylbenzene

Methylene Chloride

Toluene

Xylene (total)

79

71

<5

170

460

50

59

64

80

289

77

59

<5

170

450

49

54

63

78

266

70

64

<5

150

410

55

54

20

81

264

Diethyl Phthalate

2,4-Dimethylphenol

Dimethyl Phthalate

Fluorene

Naphthalene

Phenanthrene

Phenol

---

---

---

---

---

---

---

<10

110

11

12

63

16

46

---

---

---

---

---

---

---

 10

110

12

17

61

27

47

---

---

---

---

---

---

---

12

110

13

20

14

30

30

NOTES: (a) Volatile and semi-volatile analysis performed on random samples collected over two hour period.

Sample A during first hour. Samples B and C during second hour.

 (b) LLI = Lancaster Labs Inc. NRL = Naval Research Laboratory.

 (c) --- = Samples were not analyzed by LLI for the parameters shown.

 (d) NA = Information not available

 (e) < = less than
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

21

Table 8. Auxiliary Ship (AS 36) OWS Effluent Discharge Data Summary7

(May 2 through September 12, 1996)

Values Above MDL (μg/L)

Parameter Method

Detection Level

No. of

Analyses

No. of

Values

Min. Max. Median Std.

Dev.

Oil in Water

BOD

COD

TSS

NA

NA

NA

NA

44

8

14

10

44

8

14

10

0.5

1

26

1

93

34

260

57

5.4

3.5

61

12.5

20.1

10.1

79.5

16

Antimony

Arsenic

Beryllium

Cadmium

Chromium

Copper

Lead

Iron

Mercury

Nickel

Selenium

Silver

Thallium

Zinc

600

10

5

10

20

NA

100

NA

0.2

NA

10/5

30

10

NA

14

14

14

14

14

14

14

11

14

14

14

14

14

14

0

0

0

0

0

14

0

11

1

14

0

0

14

14

NA

NA

NA

NA

NA

44

NA

786

1.6

75

NA

NA

NA

164

NA

NA

NA

NA

NA

661

NA

2,200

1.6

471

NA

NA

NA

1,100

NA

NA

NA

NA

NA

257

NA

1,050

NA

117

NA

NA

NA

382

NA

NA

NA

NA

NA

166

NA

427

NA

103

NA

NA

NA

283

NOTE: NA = Information not available.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

22

Table 9. Aircraft Carrier (CVN 74)

Oil/Water Separator Influent/Effluent Raw Data4

CVN 74-OWSI-01 CVN 74-OWSI-02 CVN 74-OWSI-03 CVN 74-OWSI-04

Parameter Units Influent Effluent Influent Effluent Influent Effluent Influent Effluent

COD

BOD

TOC

TSS

O&G

TKN

Ammonia

Nitrate + Nitrite (As N)

Total Phosphorous

mg/L

mg/L

mg/L

mg/L

mg/L

mg/L

mg/L

mg/L

mg/L

132

31

28

38

50

1.6

0.14

054

3.2

179

5

9

64

22

1.7

<0.10

0.20

1.2

258

17

24

38

269

2.0

0.19

0.44

3.7

258

11

21

46

17

1.7

0.17

0.30

2.7

86

18

26

36

42

1.4

0.15

0.50

3.9

148

18

20

48

36

1.6

0.17

0.40

2.2

195

22

19

70

122

1.2

<0.10

0.62

3.1

148

10

11

23

27

1.0

<0.10

0.0

2.0

TDS

Chloride

Sulfate

Sulfide

Total Alkalinity

mg/L

mg/L

mg/L

mg/L

mg/L

7,360

4,126

498

5

36

16,620

9,742

1,290

2

64

5,570

3,616

411

10

40

9,720

7,359

643

8

46

5,920

3,531

446

10

40

10,260

8,125

780

8

48

8,970

3,956

643

10

48

13,320

8,040

958

5

58

Cyanide μg/L <10 <10 <10 <10 <10 <10 NA <10

Aluminum

Antimony

Arsenic

Barium

Beryllium

Cadmium

Chromium

Copper

Iron

Lead

Manganese

Nickel

Selenium

Silver

Thallium

Zinc

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

μg/L

69(B)

<20

<10

49

1(B)

6

<10

581

455

<46

34

304

<20

5(B)

<10

1,590

229

<2

33

32

<1

<5

<10

284

482

<46

29

98

<20

<5

<10

519

74(B)

<20

<1

50(B)

<1

5.7

<10

567

471

<46

34

318

<31.5

<5

<10

1,760

108(B)

2.6(B)

3(C)

43(B)

<1

<5

<10

426

442

<46

33

245

41(C)

5(B)

<10

1,330

83(B)

5.6(B)

<1

55(B)

<1

5.1

<10

554

560

<46

37

321

<20

<5

<10

1,840

104(B)

<20

33(B)

40(B)

<1

5.6

<10

363

432

<46

30

208

<20

<5

<10

1,110

143(B)

<20

<1

44(B)

<1

<5

<10

574

610

<46

35

277

26(C)

<5

<10

1,350

220

<10

<1

34(B)

<1

<5

<10

316

531

<46

31

162

<20

<5

<10

786

Bis(2-ethylhexyl) phthalate

N,N-Dimethylformamide

Toluene

Xylene (o+p)

μg/L

μg/L

μg/L

μg/L

<10

99

14

24

<10

33

<10

<10

30

124

12

20

<10

88

<10

13

22

102

13

19

<10

65

<10

<10

38

85

12

19

<10

58

<10

12

Note: (a) < = less than
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

23

Table 10. Summary of Detected Analytes: Oil/Water Separator Effluent Data

Constituent Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Mass

Loading

(lbs/yr)

Oil Water Separator Effluent

Classicals (mg/L)

ALKALINITY 53.51 4 of 4 46 64 40,013

AMMONIA AS NITROGEN 0.09 2 of 4 BDL 0.17 67

BIOCHEMICAL OXYGEN

DEMAND

8.78 3 of 4 BDL 18 6,565

CHEMICAL OXYGEN

DEMAND (COD)

178.34 4 of 4 148 258 133,356

CHLORIDE 8273.63 4 of 4 7360 9740 6,186,728

HEXANE EXTRACTABLE

MATERIAL

23.54 4 of 4 17.5 27 17,602

NITRATE/NITRITE 0.27 4 of 4 0.2 0.4 202

SGT-HEM 9.64 4 of 4 6 16 7,208

SULFATE 887.29 4 of 4 643 1290 663,484

TOTAL DISSOLVED SOLIDS 13238.57 4 of 4 9720 21600 9,899,334

TOTAL KJELDAHL NITROGEN 1.5 4 of 4 1.1 1.7 1,122

TOTAL ORGANIC CARBON

(TOC)

14.53 4 of 4 9.3 21 10,865

TOTAL PHOSPHOROUS 1.81 4 of 4 1.2 2.7 1,353

TOTAL RECOVERABLE OIL

AND GREASE

39.96 4 of 4 15.05 173 29,881

TOTAL SULFIDE

(IODOMETRIC)

5.03 4 of 4 2 8 3,761

TOTAL SUSPENDED SOLIDS 42.46 4 of 4 23 64 31,750

VOLATILE RESIDUE 13285.59 4 of 4 9770 21600 9,934,494

Hydrazine (mg/L)

HYDRAZINE 0.15 4 of 4 0.095 0.2 112

Mercury (ng/L)

MERCURY 51.8 4 of 4 32.05 79.8 0.04

Metals (μg/L)

ALUMINUM

Total 154.49 4 of 4 104 230.5 116

ANTIMONY

Total 6.15 1 of 4 BDL 2.6 5

ARSENIC

Total 6.09 2 of 4 BDL 33 5

BARIUM

Dissolved 34.98 4 of 4 27.8 41.8 26

Total 36.58 4 of 4 30.65 42.9 27

BORON

Dissolved 1562.43 4 of 4 1280 2030 1,168

Total 1505.6 4 of 4 1240 1945 1,126
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

24

CADMIUM

Total 3.06 1 of 4 BDL 5.6 2

CALCIUM

Dissolved 135123.39 4 of 4 105000 184000 101,040

Total 129848.08 4 of 4 104000 172500 97,096

COPPER

Dissolved 162.56 4 of 4 116 201 122

Total 341.25 4 of 4 277.5 426 255

IRON

Total 472.36 4 of 4 432 531 353

MAGNESIUM

Dissolved 392878.32 4 of 4 262000 486000 293,780

Total 423465.92 4 of 4 333000 593500 316,653

MANGANESE

Dissolved 26.21 4 of 4 22.2 31.1 20

Total 30.35 4 of 4 28.25 32.5 23

MOLYBDENUM

Dissolved 21.29 4 of 4 18.6 24.3 16

Total 9.29 2 of 4 BDL 28.1 7

NICKEL

Dissolved 176.4 4 of 4 109 247 132

Total 168.54 4 of 4 97.75 245 126

SODIUM

Dissolved 3606853.89 4 of 4 2680000 5200000 2,697,078

Total 3585080.31 4 of 4 2770000 5000000 2,680,796

TIN

Total 16.59 1 of 4 BDL 41.2 12

TITANIUM

Total 4.5 2 of 4 BDL 9.2 3

ZINC

Dissolved 855.7 4 of 4 511 1260 640

Total 878.8 4 of 4 514 1330 657

Organics (μg/L)

N,N-DIMETHYLFORMAMIDE 57.3 4 of 4 32.5 88 43

O+P XYLENE 7.9 2 of 4 BDL 13 6

Pesticides (μg/L)

2,4-DB 1.66 2 of 4 BDL 2.88 1

DICAMBA 0.29 3 of 4 BDL 0.48 0.2

MCPA 28.45 1 of 4 BDL 58.9 21

MCPP 113.25 4 of 4 41.3 167 85

PYRETHRIN I 183 1 of 1 183 183 137

Log normal means were calculated using measured analyte concentrations. When a sample set contained one or

more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations

equivalent to one-half of the detection levels were used to calculate the mean. For example, if a "non-detect" sample

was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log normal mean

calculation.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

25

Table 10 a. Estimated Annual Mass Loadings of Constituents

Constituent Log Normal

Mean

Frequency of

Detection

Minimum

Concentration

Maximum

Concentration

Mass Loading

(lbs/yr)

Classicals (mg/L)

AMMONIA AS NITROGEN 0.09 2 of 4 BDL 0.17 67

NITRATE/NIRITE 0.27 4 of 4 0.2 0.4 202

TOTAL KJELDAHL

NITROGEN

1.5 4 of 4 1.1 1.7 1,122

TOTAL NITROGENA1.77 1,304

TOTAL PHOSPHOROUS 1.81 4 of 4 1.2 2.7 1,353

SGT-HEM 9.64 4 of 4 6 16 7,208

Mercury (ng/L)

MERCURY 51.8 4 of 4 32.05 79.8 0.04

Metals (μg/L)

COPPER

 Dissolved 162.56 4 of 4 116 201 122

 Total 341.25 4 of 4 277.5 426 255

IRON

 Total 472.36 4 of 4 432 531 353

NICKEL

 Dissolved 176.4 4 of 4 109 247 132

 Total 168.54 4 of 4 97.75 245 126

ZINC

 Dissolved 855.7 4 of 4 511 1260 640

 Total 878.8 4 of 4 514 1330 657

Notes:

A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

26

Table 11. Mean Concentrations of Constituents that Exceed Water Quality Criteria

Constituent Log

Normal

Mean

Minimum

Concentration

Maximum

Concentration

Federal Acute Water Quality

Criteria

Most Stringent State

Acute Water Quality

Criteria

Classicals (mg/L)

AMMONIA AS

NITROGEN

0.09 BDL 0.17 None 0.006 (HI)A

NITRATE/NITRITE 0.27 0.2 0.4 None 0.008 (HI)A

TOTAL KJELDAHL

NITROGEN

1.5 1.1 1.7 None -

TOTAL

NITROGENB

1.77 None 0.2 (HI)A

TOTAL

PHOSPHOROUS

1.81 1.2 2.7 None 0.025 (HI)A

TPH (SGT-HEM) 9.64 6 16 visible sheena

 / 15b

5 (FL)

Mercury (ng/L)

MERCURY*51.8 32.05 79.8 1800 25 (FL, GA)

Metals (μg/L)

COPPER

 Dissolved 162.56 116 201 2.4 2.4 (CT, MS)

 Total 341.25 277.5 426 2.9 2.5 (WA)

IRON

 Total 472.36 432 531 None 300 (FL)

NICKEL

 Dissolved 176.4 109 247 74 74 (CA, CT)

 Total 168.54 97.75 245 74.6 8.3 (FL, GA)

ZINC

 Dissolved 855.7 511 1260 90 90 (CA, CT, MS)

 Total 878.8 514 1330 95.1 84.6 (WA)

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.

B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

* - Mercury was not found in excess of WQC; concentration is shown only because it is a bioaccumulator.

CA= California

CT = Connecticut

FL = Florida

GA = Georgia

HI = Hawaii

MS = Mississippi

WA = Washington

a Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen

on receiving waters.

b

International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as

implemented by the Act to Prevent Pollution from Ships (APPS)
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge

27

Table 12. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

Equipment

Literature

X

2.2 Releases to the Environment OPNAVINST

5090.1B

X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X X X

3.3 Constituents X X X

3.4 Concentrations X X

4.1 Mass Loading X X

4.2 Environmental Concentrations X X

4.3 Potential for Introducing NonIndigenous Species

X
Underwater Ship Husbandry

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second

phase will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects. 

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Underwater Ship Husbandry
Underwater Ship Husbandry

2

2.0 DISCHARGE DESCRIPTION

This section describes the underwater ship husbandry discharge and includes information

on: the equipment that is used and its operation (Section 2.1), the general description of the

constituents of the discharge (Section 2.2), and the vessels that produce this discharge (Section

2.3).

2.1 Equipment Description and Operation

For the purpose of this evaluation, underwater ship husbandry is defined as the

inspection, grooming, maintenance, and repair of hulls and hull appendages performed while a

vessel is waterborne. In the case of repairs, they may be classified as permanent (equivalent to

dry-dock repair); temporary (to be reworked at the next scheduled dry-docking); and emergency

(allowing the ship to transit to a facility for further repair). Underwater ship husbandry includes

the following operations:1,2

• hull cleaning,

• fiberglass repair,

• welding,

• sonar dome repair,

• non-destructive test/inspection,

• masker belt repairs, and

• paint operations, and

• SEAWOLF propulsor layup.

All of these activities are typically conducted while ships are pierside. Cleaning of

underwater hulls is the major activity within this category, and is performed on a routine basis.1

Layup of SEAWOLF propulsors occurs approximately 6 times per year.3 The remaining

operations are unplanned repair activities incidental to normal vessel operation.1

2.1.1 Underwater Hull Cleaning

Underwater hull cleaning is performed to remove fouling organisms which have adhered

to a vessel and its appendages.4 Biological growth is undesirable since it increases ship drag,

thereby increasing fuel consumption and decreasing speed. Hull cleanings can be either full

cleanings or interim cleanings. Full cleanings are those which include the entire painted

underwater hull surface, propellers, and propeller shafts. Interim cleanings include the cleaning

of propellers and shafts only.

Hull Coating Systems. Ablative hull coating systems are typically comprised of two

coats (layers) of epoxy anticorrosion (AC) paint applied to the bare hull and two coats of copper

antifouling (AF) paint applied over the AC coating. The function of the AC coat, in conjunction

with cathodic protection, is to prevent hull corrosion. The AC coat also provides bonding

between the hull and the AF topcoats. AF topcoats control biological growth by ablating and/or

leaching antifouling agents into the surrounding water (as described in the Hull Coating Leachate
Underwater Ship Husbandry

3

NOD report). The total design thickness of this system is 20 mils (1 mil = 0.001 inches), of

which 10 mils are the AF coating, although the actual application may be thicker.5

Most ships of the Navy, Military Sealift Command (MSC), and U.S. Coast Guard

(USCG) use AF paint qualified to MIL-PRF-24647 “Paint System, Anticorrosive and

Antifouling, Ship Hull.”6,7 While several types of AF topcoats conform to this specification, the

most common types are ablative, copper-based coatings.8

 An ablative coating thins as it erodes

or dissolves. Through this action, a fresh layer of antifouling agent (e.g. copper) is exposed,

maintaining the paint’s antifouling properties. Self-polishing AF paints are a type of ablative

coating which undergoes chemical hydrolysis when it comes into contact with the slightly

alkaline seawater. Any toxic agents which are chemically bound to the paint matrix will be

released at a rate dependent upon the rate of hydrolysis.

Other vessels of the Armed Forces use non-ablative paint systems which do not

appreciably diminish in thickness during service.7

 Non-ablative paints containing tributyltin

(TBT) are still found on some aluminum-hulled small craft because some copper-based paints are

incompatible with aluminum hulls.8

 However, TBT paints are no longer approved for any Navy

vessel, including aluminum-hulled craft, effective as of fiscal year (FY) 1998.5,9

Coating Service Life. Ablative copper AF coatings for naval vessels are designed to

meet five-, seven-, or ten-year dry-docking periods.9 Typically, ablative copper AF coatings

remain free of fouling for about three years after application before they require in-water hull

cleaning.10 After the first cleaning, they typically require an annual hull cleaning, which is

usually performed just prior to deployments, to optimize fuel consumption underway. This is

only a guideline, since the frequency of cleaning is also influenced by the ship’s schedule and

location.4

Inspection and Evaluation. Navy vessels are inspected quarterly and before

deployments, and are assigned a Fouling Rating (FR) on a scale of 0 to 100.1,4 This rating is

established by comparing photographs of the fouled hull with photographic standards

representing values on the FR scale. The criteria for performing hull cleaning is FR 40 or higher

(for ablative and self-polishing paint systems) over 20% of the ship’s hull; or the presence of FR

50 or higher (for non-ablative paint systems) over 10% of the ship’s hull.4

Underwater Hull Cleaning Process. Underwater hull cleaning can be accomplished

with hand-held rotary brush units, self-propelled multi-brush cleaning vehicles, water jets, and

hand-held scrapers.4

 Most often, it is conducted by divers using the Submerged Cleaning and

Maintenance Platform (SCAMP) or the similar SeaKlean multi-brush systems.1

 These

mechanical devices are held next to the hull from the thrust and suction generated by a large

impeller, which pumps seawater at approximately 13,500 gallons per minute (gpm). While the

brushes rotate and sweep biofouling off of the hull, the system moves forward at a maximum rate

of 1 foot per second (ft/sec), but typically at 0.75 ft/sec. A small percentage of the hull, gratings,

and struts; which are inaccessible to these multi-brush machines, must be cleaned using handheld single-brush cleaning units.10
Underwater Ship Husbandry

4

2.1.2 Other Underwater Repair, Maintenance, And Inspection Processes

Fiberglass Repair. Two activities comprise this class of ship husbandry: fiberglass hull

repairs and fiberglass propeller shaft coating repairs. Methods for performing underwater

fiberglass hull repairs are still under development, and therefore are not a standard operation. 

Shafts are coated with fiberglass to prevent corrosion. A confirmed or suspected failure in the

fiberglass coating may require an underwater repair, if dry-docking is not imminent.1

Fiberglass shaft repairs are performed by divers working in a dry underwater enclosure, or

“habitat,” having an opening in the underside for diver access.11 When coating shafts with

fiberglass, glass reinforced plastic (GRP) wrapping is applied in accordance with MIL-STD2199, “Glass Reinforced Plastic Coverings for Propeller Shafting.” In this procedure, the shaft is

first cleaned with a solvent, typically acetone, to remove grease and oil. Next, four wrappings of

fiberglass tape/cloth are made and fixed with a viscous epoxy or polyester resin which hardens

into an insoluble plastic. The cure time and working life of the resin vary with the individual

brand, temperature, and humidity. However, the total cure time is on the order of 24 hours. The

working life of the resin, after the addition of the hardener, is significantly less. The

specification states that resin systems may have a working life from 30 minutes to six hours at

73 °F and as short as 18 minutes at 90 °F. The specification recommends that a new resin pot be

prepared for each wrapping, because it may harden between wrapping passes.12

Welding. There are two types of underwater welding: dry habitat and wet welding. An

underwater enclosure is used for dry habitat welding, the use of which is required for slower

cooling of high strength steels. A high-flow air system filters and exhausts the welding fumes

and provides a safe atmosphere for the welder. In wet welding, operations are performed under

submerged conditions. Specially coated welding rods allow the flux to bond with the wet

surface. Before welding, the area is cleaned with scrapers, chipping hammers, or hand-held

brushes.11,13

Sonar Dome Repair. Minor repairs to the exterior of rubber sonar domes can be

accomplished by divers. The most common repair is patching the rubber window. A diver

removes loose rubber, prepares the edges to receive a patch, and affixes a rubber patch with an

amine polymer.11

Non-Destructive Test/Inspection. Underwater magnetic particle testing is used as a

non-destructive inspection method to detect or define surface or near-surface cracks in ferrous

metal structures prior to repair. It may also be used for welding quality assurance. An

electromagnet is used to magnetize a localized area on the hull surface. A slurry of fluorescent

iron flakes is then applied to the weld or crack with a squeeze bottle. These particles align with

the defective area, facilitating inspection.11,14

Masker Belt Repairs. Masker emitter belts are installed at the forward end of the ship’s

machinery spaces and run vertically down both sides of the external hull. The masker belt is a

continuous length of copper-nickel pipe that emits air bubbles through small holes to mask ship

noise. The pipe is epoxied into a fairing channel that is welded to the hull. The channel ensures
Underwater Ship Husbandry

5

that the hull shape remains “fair,” or smoothly curved, so the masker belt does not protrude and

increase drag. Waterborne repairs by divers consist of cutting away damaged belt sections and

installing replacement sections. An insert is used to join the replacement with existing sections. 

Finally, an epoxy sealer is applied to ensure a positive air seal.11

Paint Operations. Underwater touchup painting is required after welding, shaft

lamination repairs, and masker belt repairs. Touchup painting is also performed to repair paint

damage or deterioration on surfaces such as rudders, dielectric shielding for the cathodic

protection system, struts, and stern tubes. Epoxy paint is mixed on the surface (above water),

supplied to the diver, and applied to the affected area with a brush or roller.11

SEAWOLF Propulsor Layup. The newly commissioned SEAWOLF attack submarine

utilizes vinyl covers to prevent fouling of the propeller (also called propulsor) when it is in port

for extended periods. The covers, referred to as the Propulsor Protective Covering System

(PPCS), restrict sunlight and the supply of fresh nutrient-rich water into the propulsor. Reducing

the amount of fouling that occurs on the propulsor in port reduces the need for underwater

cleaning of the propulsor.2

2.2 Releases to the Environment

2.2.1 Underwater Hull Cleaning

Underwater hull cleaning is accomplished by divers operating hand-held rotary brush

units, self-propelled multi-brush cleaning vehicles, water jets, and hand-held scrapers.4 These

tools sweep or dislodge biofouling from the wetted surface of the hull and appendages.1 The

discharge from the cleaning process consists of seawater (from the impeller of the cleaning

vehicle), living and dead marine organisms, and antifouling paint.10 Variables affecting the

amount of this discharge include hull surface area, condition of the paint system, degree of

fouling, brush selection, conditions in the water, and the skill of the operators.

2.2.2 Other Underwater Repair, Maintenance, And Inspection Processes

Fiberglass Repair. A two component system consisting of an epoxy resin and a

hardener is mixed topside and transferred to the underwater habitat to accomplish the fiberglass

repairs.15 Due to the rapid curing time of the resin system, it is applied to the surface to be

repaired soon after mixing, and then covered with glass tape. Releases of fiberglass and resin can

occur when materials fall through the open bottom of the enclosure.11 Since the resin being

applied quickly solidifies, any releases from the enclosure will fall to the bottom of the harbor.

Welding. Small amounts of welding consumables can enter the marine environment

upon entry into or exit from the dry welding habitat, or by passing directly into the water during

wet welding.11 Slag, which is molten refuse material from the welding process, may fall from the

welding area into the water column. Some spent welding rods and welding gases may also be

released.
Underwater Ship Husbandry

6

Sonar Dome Repair. When the diver removes the loose rubber from the sonar dome

and affixes a rubber patch with adhesive, a discharge of solid rubber waste and/or adhesive may

result.11

Non-Destructive Test/Inspection. The slurry of iron flakes applied to the weld is

discharged directly into the water column.11

Masker Belt Repairs. Waterborne repairs consist of cutting away damaged belt sections

and installing replacement sections as described in Section 2.1.11 Portions of the damaged belt or

some of the epoxy sealer can be released during this operation.

Paint Operations. While a diver is performing underwater touchup painting with epoxy

coatings, some paint can be incidentally released into the water in the vicinity of the painting

operation.11 Neither the epoxy resin nor the amine compound of the primary products in use are

water-soluble.16

SEAWOLF Propulsor Layup. Use of the PPCS creates a relatively isolated volume of

water of approximately 21,000 gallons inside the propulsor. The chemistry of this volume of

water can change over time, primarily due to the generation of small amounts of chlorine from

the installed Impressed Current Cathodic Protection (ICCP) system and the decay of trapped

organic matter. (Descriptions of the purpose and function of ICCP systems can be found in the

Cathodic Protection NOD report). Releases to the environment resulting from the layup of the

propulsor include decaying organic matter, chlorine, and Chlorine Produced Oxidants (CPO). 

CPO is used to describe the combination of oxidant species that may, in this case, be formed by

the ICCP system in both primary and secondary reactions, and includes various chlorinated and

brominated species.17

2.3 Vessels Producing the Discharge

All Navy surface ships and submarines undergo periodic underwater ship husbandry.1

However, the predominant discharge is from underwater hull cleanings. Underwater cleanings

are performed on larger vessels between dry-docking periods. The Navy, with the greatest

number of large vessels, produces this discharge more frequently than the other Armed Forces. 

The U.S. Coast Guard (USCG), Military Sealift Command (MSC), Army, and Air Force drydock their vessels more frequently, at which time hull cleaning is performed.18, 19, 20 Small boats

and craft are typically removed from the water for maintenance and repairs.1 Layup of

SEAWOLF Propulsors is currently limited to the SEAWOLF Class of attack submarines. The

first of this class, SSN 21, was commissioned in the fall of 1997, with a total of 3 submarines

planned. The next attack submarine class, commonly referred to as the “New Attack

Submarine,” is also expected to use a PPCS type system.

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the
Underwater Ship Husbandry

7

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Underwater ship husbandry is conducted pierside.1

3.2 Rate

Because of the variability in vessel surface area and in the volume of these releases for

underwater ship husbandry, rates are discussed in terms of frequency of the event.

3.2.1 Underwater Hull Cleaning

On average, each Navy surface ship will receive five underwater hull cleanings every six

years.

1

 These statistics vary regionally depending on fouling rates, water temperatures, and the

coating service life. Vessels in Pearl Harbor, HI, for example, would have higher fouling rates,

and, therefore, a higher cleaning frequency than those in Norfolk, VA. An average of 136 full

cleanings (including the hull surface, propeller, and shaft) are performed annually fleetwide,

based on the following four years of data:21

1993: 131 vessels

1994: 131 vessels

1995: 135 vessels

1996: 148 vessels

An additional 170 interim cleanings (i.e., the cleaning of propellers and shafts only) are

estimated to occur each year.1

Although flow rates from the SCAMP have not been measured, based on impeller

characteristics, motor speed, and expected efficiency, the flow rate has been estimated to be

13,500 gallons per minute (gpm), or 51,100 liters per minute (L/min).10

3.2.2 Other Underwater Repair, Maintenance, and Inspection Processes

Table 1 lists the estimated releases from Navy underwater ship husbandry activities other

than hull cleaning.22 Coating shafts with fiberglass is performed on an infrequent basis. Sonar

dome repairs are necessary only on submarines and surface combatants equipped with sonar

equipment. The other listed activities apply to all vessels. Since the other services have fewer

large ships than the Navy, these activities are expected to be less frequent among vessels of the

other Armed Forces. For example, there have been three documented instances of underwater

weld repairs conducted on MSC vessels in the past five years, and no rubber dome or fiberglass

repairs.23
Underwater Ship Husbandry

8

Fiberglass Repair. On Navy vessels, fiberglass shaft coatings are estimated to be

applied 12 times per year. Based on operational experience, it is estimated that approximately

one quart of resin could possibly be released per fiberglass wrapping event. Given this amount, it

is estimated that 12 quarts (11.4 liters) of the resin system (i.e., resin mixed with hardener) could

possibly be released per year.22

Welding. Small amounts of welding consumables can enter the marine environment

through the dry habitat or directly when wet welding is performed.11 Slag and spent welding rods

may also be released. From operational experience, it is estimated that approximately five

pounds of slag or spent welding rod are discharged during each underwater welding operation,

and approximately 12 of these operations are performed fleet-wide each year on Navy ships.22

Metals from the welding operation will not be readily dissolved in the surrounding waters and

will fall to the harbor floor.

Sonar Dome Repair. A discharge of solid rubber waste and/or adhesive can result from

this operation. This is a site-specific operation, and this discharge is dependent on the size of the

patch being repaired. It is estimated that 19 Navy surface ships and submarines undergo sonar

dome repairs yearly.22 Rubber pieces from the sonar dome repair operations will not be

dissolved in the surrounding water and will settle on the harbor floor. 

Non-Destructive Test/Inspection. During magnetic particle inspection, a slurry of iron

flakes is discharged directly through the water column. It is estimated that 20 Navy vessels

undergo magnetic particle inspections yearly.22

Masker Belt Repairs. Waterborne repairs consist of cutting away damaged belt sections

and installing replacement sections. Based on operational experience, it is estimated that six

Navy vessels undergo masker belt repairs yearly.22 Releases can occur from the removal of the

damaged belt and the application of the epoxy sealer.11 Similar to the epoxy resin used in

propeller shaft repair, the epoxy sealant will quickly solidify into a hard, insoluble material.

Paint Operations. While a diver is performing in-water touchup painting with epoxy

coatings, some paint can be incidentally released into the water in the vicinity of the painting

operation. It is estimated that roughly 60 operations of this type are performed on Navy vessels

annually.24 The surface area involved may be as small as two square feet for a weld touchup, or

as large as 1,500 square feet when several areas of the ship require touchup painting. The

amount of paint released will vary with the size of the area painted and the skill of the operator.1

The release of material during these operations is accidental and highly variable.

SEAWOLF Propulsor Layup. Current operational procedures require the PPCS to be

installed with 12 hours after entering port when the in port time is expected to be greater than 72

hours.2 Exceptions to this requirement exist for maintenance and engine testing, during which

the PPCS will be removed, or perhaps not installed at all. This is similar to the requirement for

putting the main condensers of earlier submarine classes on a fresh water layup for which an

estimate of 6 times per year was developed.3
Underwater Ship Husbandry

9

3.3 Constituents

Materials associated with underwater ship husbandry activities and which may be

constituents of the various discharges are discussed in this section.

3.3.1 Underwater Hull Cleaning

The primary constituents found in the hull cleaning discharge are copper and zinc from

the antifouling paint. These constituents are priority pollutants; neither are bioaccumulators. 

TBT is not a constituent of concern since small craft with aluminum hulls are not typically

cleaned waterborne.1

3.3.2 Other Underwater Repair, Maintenance, And Inspection Processes

The primary constituents which may be found in the discharge from underwater repair,

maintenance, and inspection processes other than hull cleaning are listed in the following

paragraphs. Constituents which are classified as bioaccumulators or priority pollutants are

identified.

Fiberglass Repair. The primary constituents found in the discharge from fiberglass

repair activities are proprietary resins and fiberglass. The resin material is fluid for only a short

period of time; will not be dissolved in the surrounding water; and will fall to the harbor floor,

where it will complete its curing. The hardener can contain triethylenetetramine;

tetraethylenepentamine; 2,4,6-tris(dimethylaminomethyl)phenol; and amidoamine.25

Welding. The primary constituents found in the discharge from underwater welding are

metals in the slag associated with welding rods. These may contain chromium, iron, nickel,

beryllium, manganese, and trace quantities of other metals.11 Chromium, nickel, and beryllium

are priority pollutants.

Sonar Dome Repair. The primary constituents found in the sonar dome repair discharge

are rubber from the patches and the sealant. The sealant adhesive contains epoxy resin, amine

polymer, iron oxide, and silica.11

Non-Destructive Test/Inspection. The primary constituents found in the discharge from

crack or weld inspection are fluorescent iron powder or flakes, water conditioner, and a

surfactant mixture suspended in water.26 The particles used are required by specification to be

non-toxic, finely divided ferromagnetic material free from rust, grease, oil, paint, or other

materials which can interfere with their proper functioning.14

Masker Belt Repairs. The primary constituents found in the discharge from masker belt

repairs are portions of the damaged belt and adhesive. Sealant adhesive contains amine polymer,

iron oxide, and silica.11

Paint Operations. The primary constituents found in the discharge from touchup paint
Underwater Ship Husbandry

10

operations are epoxy paint which contains 4,4’-methylene dianiline, benzyl alcohol, and traces of

epichlorohydrin.11

SEAWOLF Propulsor Layup. Constituents from the layup of the SEAWOLF propulsor

will include decaying organic matter, and CPO that may build-up in the enclosed volume of the

propulsor. CPO is the primary constituent.

3.4 Concentrations

3.4.1 Underwater Hull Cleaning

The Navy studied the environmental effects of in-water hull cleaning on six ships during

the period from 1991-1993. Measurements of total copper were taken directly within the

SCAMP discharge plume for three of these ships.10 This data serves as the basis for the analysis

of copper concentrations in and loading from the SCAMP effluent.

Table 2 summarizes both dissolved (0.45 micron filtered) and total (unfiltered) copper

concentrations from the effluent of the SCAMP for the three ships.10 Samples were collected in

the plume created by the cleaning operation near the point of discharge, and thus are

representative of the highest anticipated levels in the marine environment attributable to

underwater hull cleaning. The mean for total copper in the samples ranged from 1,565

micrograms per liter (μg/L) to 2,619 μg/L. The dissolved fraction was 4 to 9 percent of the total

copper (66 μg/L to 146 μg/L). Zinc levels were not measured in this study, but can be roughly

estimated from the original ratio of constituents in the paint. Assuming a ratio of 2.5 parts

copper to 1 part zinc, it can be estimated that the total zinc concentration is 626 to 1,048 μg/L.27

3.4.2 SEAWOLF Propulsor Layup

The concentration of organic matter in the released volume of water will be related to the

amount of biological matter in the harbor water when the PPCS is installed. The concentration

of CPO will be proportional to the current output of the ICCP system and the length of time the

PPCS is installed, and inversely proportional to the oxidizable component of the harbor water at

the time of PPCS installation.

Typical in port ICCP system output for the SEAWOLF Propulsor is less than 1 ampere. 

An equation based on Faraday’s Law is used to determine the maximum CPO generation rate of

1.3 g Cl/hr.

Generation Rate of Chlorine Produced Oxidants (CPO)

= (1 amp) (1 coulomb/amp-sec) (3,600 sec/hr) (35.45 g chlorine/mole) (mole/96,484 coulomb)

= 1.323 g chlorine/hr ≈ 1.3 g/hr
Underwater Ship Husbandry

11

Since ICCP systems (i.e., anode materials and system operating voltage) are designed to

maximize cathodic protection provided to the hull, and generation of chlorine or CPO is a

secondary reaction, actual CPO generation rates are expected to be significantly lower.

This generation rate of CPO will be further offset by the consumption of CPO in the

harbor water. In the first stage of CPO decay, a portion of the CPO disappears within one

minute, consumed by the instantaneous oxidant demand. This first decay is assumed to be a 25%

reduction, based upon a range of values reported for studies performed in waters between 0oC

and 33oC.28, 29 Following this, decay is assumed to occur at a rate of 50% concentration

reduction per hour. While actual decay rates for CPO will vary significantly due to temperature,

flow, and amount of biological matter, these average decay rates can be used to determine an

estimate of the resultant CPO concentration and mass loading as shown in Calculation Sheet 1.30

 The resultant concentration and mass loading converge to steady-state values of 18 μg/L CPO

and 1.4 g CPO per event, respectively, in the enclosed volume of water after ten hours of system

operation.

One set of field was data obtained for this application, and in this, a CPO concentration of

less than 40 μg/L was measured in the enclosed water of the propulsor over a 52 day period.31,32

This testing was accomplished in the context of local environmental limits for CPO of 0.2 ppm

(200 μg/L), and test results only confirmed CPO concentrations within the lowest range of the

test apparatus (0.0 ppm to 0.04 ppm) rather than precise values.32 This is in agreement with the

18 μg/L estimated from the previous CPO decay calculation. The larger of the two estimates (40

μg/L) will be assumed for subsequent calculations.

3.4.3 Other Underwater Repair, Maintenance, and Inspection Processes

In accordance with the specifications, the concentration of magnetic particles in the slurry

used for underwater weld inspection is between 0.1% and 0.7% by volume.14 The remainder of

the suspension is water. The estimated release amounts from other underwater ship husbandry

activities are infrequent and in small quantities. In addition, these discharges are mostly

insoluble and are unlikely to remain suspended in the water column or be dissolved. Pollutant

concentrations resulting from fiberglass repair, welding, sonar dome repair, masker belt repair,

and painting were not estimated.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. The estimated mass

loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents

are compared with water quality criteria. In Section 4.3, the potential for the transfer of nonindigenous species is discussed.

4.1 Mass Loadings
Underwater Ship Husbandry

12

4.1.1 Underwater Hull Cleaning

Differences in ship assignments and deployments create different rates of hull fouling on

individual vessels. However, the decision to initiate hull cleaning operations is based on visual

inspection and by ship performance indicators as outlined in NSTM, Chapter 081.4 Based upon

this standard approach to assessing the need for cleaning, it is reasonable to assume that cleaning

operations are initiated under similar fouling conditions. Therefore, the SCAMP discharges

sampled are assumed to provide a reasonable basis for the approximation of SCAMP discharges

fleet-wide. The total volume of a release from an underwater hull cleaning operation is

proportional to the area of the hull cleaned. Therefore, the total volume of the discharge is

related to the class of ship, with larger releases generated from the cleaning of larger hull areas.

For the purposes of calculating mass loading from ships and the fleet, the mean

concentration of the copper in the SCAMP discharge from the three vessels studied was used. 

The total copper was measured to be 1,950 μg/L and the dissolved copper fraction averaged

approximately 107 μg/L, or approximately 5.5%.10

In order to calculate the mass loading, data are needed on the flow rate (F) from the

SCAMP impellers, and the rate (R), or area cleaned per unit time. The mass of copper released

(Cu) per unit area cleaned (A) can be calculated by the following formula:10

Cu/A = (Cu concentration) (F/R)

where Cu is in grams (g)

A is in square meters (m2)

Cu concentration is in grams per liter (g/L)

F is in liters per minute (L/min)

R is in square meters per minute (m2/min)

Using the following assumptions, a sample calculation of the mass of copper released per

unit area cleaned is provided below:

SCAMP flow rate is 51,100 L/min (equivalent to 13,500 gpm), (Section 3.2)

Cu concentration = 0.00195 g/L (mean concentration)

Flow rate (F) = 51,100 L/min

Cleaning rate (R) = 20.8 m2/min (225 ft2 /min)

(based on 45 ft/min travel speed, and a 5 ft wide cleaned path)

Cu/Area = (0.00195 g/L) (51,100 L/min) / (20.8 m2/min)

Copper release= 4.8 g Cu per m2 of surface cleaned

Assuming the entire hull area exposed to the water is cleaned, the wetted surface area of

the ships can be used for the area cleaned. The wetted surface area of the ships was taken
Underwater Ship Husbandry

13

directly from tables in NSTM Chapter 633, “Cathodic Protection,” or estimated by the following

formula presented in the same source:33

S = 1.7(L)(d) + (V/d)

where: S = wetted surface area (ft2)

L = length between perpendiculars (ft)

d = molded mean draft at full displacement (ft)

V = molded volume of displacement ft3

(for seawater, 35 ft3 of water per ton displacement)

As an example for an individual ship, from the NSTM the Spruance Class destroyer has a

wetted hull area of 35,745 ft2 (3,321 m2).33 Therefore, the mass loading is estimated to be 15.9

kilograms (kg), or 35 pounds (lbs) total copper released during a full hull cleaning.

Fleetwide Hull Cleanings. A list of Navy vessels which received full hull cleanings

during the period from 1993-1996 was used to determine a weighted average mean hull surface

area cleaned annually.21 This weighted average was estimated to be 2,973 m2. The estimated

copper release rate and the mean hull wetted surface area can be applied to all Navy ships to

derive a total mass release fleet-wide. Dissolved copper releases are based on the average ratio

(5.5%) of dissolved to total copper measured.10

Mean wetted hull area (all vessels) = 2,973 m2

Approximate number of Navy vessels cleaned annually = 136

Total area cleaned annually = 404,328 m2 (assuming full hull cleanings)

Total copper release = (4.8 g/m2) (404,328 m2) = 1,941 kg/yr; or 4,279 lbs/yr

Dissolved copper release = (1,941 kg/yr) (5.5%) = 108 kg/yr; or 238 lbs/yr

Since zinc was not measured in the Navy studies, it was assumed that releases from hull

cleaning contain the same copper to zinc ratio (2.5:1) as is found in AF paint prior to its

application.27 The annual mass loading for zinc was estimated.

Total zinc release = (1,941 kg Cu/yr) / (2.5 (Cu/Zn ratio)) = 776 kg/yr; or 1,712 lbs/yr

4.1.2 SEAWOLF Propulsor Layup

Based on information previously provided, the annual mass loading of CPO due to the

layup of the SEAWOLF propulsor is estimated to be a maximum of 19 g of chlorine.
Underwater Ship Husbandry

14

Annual mass loading = (concentration)(volume per discharge)(number of discharges)

Maximum concentration = 40 μg/L (see Section 3.4.2)

Volume per discharge = 21,000 gal (3.785 L/gal) = 79,500 L

Number of discharges per year = 6

Mass loading per event = 3.2 g CPO

Maximum annual mass loading = 1.9 x 107μg, or 19 g CPO

4.1.3 Other Underwater Repair, Maintenance, And Inspection Processes

Based on the information presented in Section 3.2 and Table 1, the total discharges

associated with underwater ship husbandry operations outside of underwater hull cleaning are as

follows:

• 12 quarts of fiberglass resin released annually from shaft coatings over the course

of 12 events

• Approximately 60 pounds of welding consumables released annually, including

spent welding rods and slag over 12 events

The estimated release amounts from other underwater ship husbandry activities are

infrequent and in small quantities. In addition, these discharges are mostly insoluble and are

unlikely to remain suspended in the water column or be dissolved.

4.2 Environmental Concentrations

Total copper has been measured in the effluent stream near hull cleaning operations at

levels of approximately 1,600 to 2,600 μg/L.10 These measured copper concentrations exceed

water quality criteria (WQC) by three orders of magnitude. Dissolved copper in those same tests

ranged from 66 to 146 μg/L, which is 28 to 61 times the Federal criterion for copper.

Using the compositional ratio of copper to zinc in antifouling paint, zinc concentrations

in the release from underwater hull cleaning are estimated to be approximately 780 μg/L. This

value exceeds WQC by one order of magnitude.

Table 3 shows Federal and most stringent state WQC relevant to the underwater ship

husbandry discharge in comparison with the measured copper concentrations and estimated zinc

concentrations from the SCAMP discharge.

For the SEAWOLF propulsor lay-up, most states have ambient WQC for CPO of 7.5 - 13

μg/L. The sole measured concentration available reported the concentration as being between 0

and 40 μg/L.
Underwater Ship Husbandry

15

4.3 Potential for Introducing Non-Indigenous Species

Transport of non-indigenous species on the hulls of commercial vessels has been

documented.34 Although the cleaning practices, frequency of transits, and operating locations

differ for the Armed Forces, there is the potential for non-indigenous species to be transferred. 

Fouling and the presence of marine organisms is most serious around intakes, grates, and sea

chests.

5.0 CONCLUSIONS

Underwater ship husbandry has the potential to cause an adverse environmental effect

because measured concentrations of copper and estimated concentrations of zinc from

underwater hull scrubbing exceed ambient water quality criteria and these constituents are

discharged in significant amounts. The potential also exists for introducing non-indigenous

species during hull cleaning.

Discharges from the other ship husbandry operations are infrequent, and are small in

terms of volume or mass loading. Therefore, these discharges have a low potential for

environmental effect.

6.0 REFERENCES

To characterize this discharge, information from various sources was obtained, reviewed,

and analyzed. Process information, engineering studies, and engineering analyses were used to

estimate the rates of discharge and the concentrations of copper and zinc released to the

environment. Table 4 shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Underwater Hull Husbandry, 22 October

1996.

2. Wendel, A., Naval Sea Systems Command (SEA 03Z52), UNDS Equipment Expert

Meeting Structured Questions, “Chlorine Produced from SEAWOLF Propulsor,” 8

December 1997.

3. McFarland, L., SUBLANT. Freshwater Layup, Submarine Main Steam Condensers. 

Personal Communication. Miller, R.B., M. Rosenblatt & Son, Inc., 7 January 1997.

4. Naval Ships’ Technical Manual (NSTM) Chapter 081, Waterborne Underwater Hull

Cleaning of Navy Ships. 4 August, 1997.

5. NAVSEA Standard Work Item (SWI 009-32) FY-98, Cleaning and Painting

Requirements.
Underwater Ship Husbandry

16

6. Qualified Products List of Qualified Products Under Military Specification MIL-PRF24647 Paint System, Anticorrosive and Antifouling, Ships Hull. QPL-24647-3, 2 April

1996.

7. Military Specification, MIL-PRF-24647B, “Paint System, Anticorrosive and Antifouling,

Ship Hull,” August 1994.

8. UNDS Equipment Expert Meeting Minutes - Hull Coating Leachate Discharge, M.

Rosenblatt & Son, Inc., 20 August 1996,

9. Naval Ships’ Technical Manual (NSTM) Chapter 631, Preservation of Ships in Service,

Volume 3, Section 8. 1 November 1992.

10. The Naval Command, Control, and Ocean Surveillance Center, RDT&E Division, Marine

Environmental Support Office, San Diego, California. “UNDS Underwater Hull

Husbandry Evaluation: In-Water Hull Cleaning.” 13 February 1997.

11. Naval Sea Systems Command Code 00C, Underwater Ship Husbandry: Compilation of

Summary Sheets and Material Safety Data Sheets for the UNDS Program, 1997.

12. Military Standard for “Glass Reinforced Plastic Coverings for Propeller Shafting,” MILSTD-2199, 11 May 1990.

13. Naval Ships’ Technical Manual (NSTM) Chapter 074, Volume 1, Section 6.1-6.9.4.3,

Welding and Allied Processes, 15 June 1995.

14. Military Standard for “Requirements for Non-Destructive Testing Methods”, MIL-STD271F(SH), 27 June 1986.

15. Rosner, LCDR J., Naval Sea Systems Command, Code SEA 00C. Information on

Fiberglass Repair Processes, Personal communication, K. Thomas, M. Rosenblatt and

Son, Inc., 19 February 1998.

16. Material Safety Data Sheets for U.S. Technologies Limited Hycote 461 Epoxy Resin

Fairing Compound, Hycote 461 Curing Agent, Hycote 151 Epoxy Resin (November

1990), and Hycote 151 Curing Agent (December 1991).

17. White, G.C. The Handbook of Chlorination and Alternative Disinfectants. New York,

Van Nostrand Reinhold, 1992, p.1308.

18. Aivalotis, J., USCG, Use of TBT on USCG Ships, L. Panek, Versar, Inc., 28 May 1997.

19. Welling, J., Army. “Hull Cleaning Practices of the Army,” Personal communication, M.

DiValentin, Naval Sea Systems Command, SEA 03L, 2 June 1997.

20. UNDS Ship Database, August 1, 1997.
Underwater Ship Husbandry

17

21. Naval Sea Systems Command, SEA 00C. Computer Assisted Information Retrieval

System (CAIRS) Underwater Ship Husbandry Database Retrieval, September 1997.

22. Dean, M., Naval Sea Systems Command, SEA 00C. Memorandum to M. Wenzel,

NSWCCD Code 632, 10 April 1996.

23. Weersing, P., Military Sealift Command. Underwater Ship Husbandry Activities of the

MSC, Personal communication to UNDS file. 16 April 1997.

24. Naval Sea Systems Command, SEA 00C. Underwater Ship Husbandry Paint Operations

Data from May 1996 through August 1997.

25. Material Safety Data Sheet for ITW Philadelphia Resins, PHILLYCLAD 1775/620TS

Resin, 7 October 1996.

26. Material Safety Data Sheet for Circle Systems, Inc. Mi-Glow Underwater 1, May 1995.

27. Material Safety Data Sheet for Courtaulds BRA 640 Interviron Red Antifouling Paint,

March 1996.

28. Davis, M.H. and J. Coughlan. “A Model for Predicting Chlorine Concentrations within

Marine Cooling Circuits and its Dissipation at Outfalls,” in Water Chlorination: 

Environmental Impact and Health Effects, Vol. 4, Book 1, Eds. Jolley, R.L. et al., Ann

Arbor Science, 1983.

29. Naval Sea Systems Command, SEA 03L. Chlorination Report, Malcolm Pirnie, Inc., 14

July 1997.

30. Thomann, R. V. and J. A. Mueller. Principles of Surface Water Quality Modeling and

Control. Harper Collins Publishers, New York, NY. 1987. pp. 180-185.

31. Electric Boat Corporation, Supplemental Information Relative to SEAWOLF Propulsor

NOD, Alan Wendel, Naval Sea Systems Command, 16 December 1997.

32. Electric Boat Corporation, “SEAWOLF PPCS/ICCP System Compatibility” Draft

Engineering Report, 10 June 1998.

33. Naval Ships’ Technical Manual (NSTM) Chapter 633, Section 4.3.1 and Table 633-5. 

Cathodic Protection. 1 August 1992.

34. Ruiz, Greg. Non-Indigenous Species Presentation - Notes by Dan G. Mosher, Malcolm

Pirnie, Inc. 18 September 1996.

General References
Underwater Ship Husbandry

18

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR

22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the

House of Representatives, Table 1.
Underwater Ship Husbandry

19

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, pg. 15366. March 23, 1995.
Underwater Ship Husbandry

20

Table 1 - Releases Associated with Underwater Ship Husbandry on Navy Vessels

(Exclusive of Hull Cleaning)

22

Operation Material Released Quantity Released

per Event

Events per Year

Underwater Fiberglass

Repair

fiberglass resin 1 quart 12

Underwater Welding epoxy paint, welding

consumable, slag

5 lbs. (welding

consumables)

12

Rubber Sonar Dome or

Sub Tile Repair

rubber sealant, epoxy minimal 16 (surface ships)

3 (submarines)

Non-Destructive Testing iron flakes, dye,

surfactant

minimal 20

Masker Belt Repairs epoxy paint and filler;

rubber sealant

minimal 6

Paint Operations

Underwater/Waterline

epoxy paint minimal 60

Propulsor Protective

Covering System (PPCS)

chlorine produced

oxidants (CPO)

3.2 g 6

Table 2 - Total And Dissolved Copper Concentrations From In-Water Hull Cleaning

Effluent Generated By SCAMP10

Vessel Name Cu, μg/L

(Filtered)

% Dissolved Cu, μg/L

(Unfiltered)

USS Fort Fisher (LSD 40) 66 4 1,668

USS Tuscaloosa (LST 1187) 141 1,475

146 1,520

137 1,600

125 1,597

135 1,633

mean: 136.8 8.7 1,565

standard deviation: +/- 7.0 +/- 58.3

USS Ranger (CV 61) 106 2,499

116 2,503

118 3,287

120 2,441

124 2,362

mean: 116.8 4.5 2,619

standard deviation: +/- 6.0 +/- 338

 Grand Mean: 106.5 5.5 1950

standard deviation: 29.8 474
Underwater Ship Husbandry

21

Table 3. Comparison of Constituent Concentrations with Water Quality Criteria (μg/L)

Constituent Concentration Federal Acute WQC Most Stringent State Acute WQC

Copper (total) 1950 2.9 2.5 (WA)

Copper

 (dissolved)

107 2.4 2.4 (CT, MS)

Zinc (total) 780 95.1 84.6 (WA)

CPO 0 - 40 - 10 (FL)

Notes:

Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,

1992 and 60 FR 22230; May 4, 1995)

CT = Connecticut

FL = Florida

MS = Mississippi

WA = Washington

Table 4. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents MSDS X

3.4 Concentrations X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous Species

X
Underwater Ship Husbandry

22

Chlorine Produced Oxidants (CPO) generation rate (R) = 1.3 g/hr

PPCS volume (V) = 21,000 gal (3.785 L/gal) = 79,485 L

C0 = concentration after first minute (considered “time zero” due to first stage decay)

 = [(1.3 g/hr) (0.75) (106 μg/g)] / (79,485 L) = 12.3 μg/L

Ct = concentration at a given time (t)

Ct = C0 e (-kt), where k = decay constant

ln (Ct/C0) = ln (e (-kt)) = -kt

For t = 1 hr and C0 = 12.3 μg/L, Ct = (12.3μg/L) (50%) = 6.15 μg/L

ln (Ct/C0) = ln (12.3/6.15) = ln (0.5) = -0.693 = -kt

k = - (-0.693) / (1 hr) = 0.693 / hr

Ct = C0 e (-kt) = (12.3 μg/L) e (0.693t)

However, since CPO is generated simultaneously with the decay of previously

introduced CPO, a steady state concentration will be reached when the decay rate

equals the generation rate, which can be expressed as:30

k(CssV) = 0.75R

k = decay constant (hr

-1)

CssV = (steady state CPO concentration) (volume) = mass (g)

R = generation rate (g/hr)

Css = 0.75R / (kV)

Css = 17.7 μg/L

Mass = 1.4 g CPO/event or 8.4 g CPO/yr

Calculation Sheet 1. CPO Concentration and Mass from SEAWOLF Propulsor Layup
Underwater Ship Husbandry MPCD Analysis

1

UNDERWATER SHIP HUSBANDRY

MARINE POLLUTION CONTROL DEVICE (MPCD) ANALYSIS

Several alternatives were investigated to determine if any reasonable and practicable

MPCDs exist or could be developed for controlling discharges from underwater ship husbandry

activities. An MPCD is defined as any equipment or management practice, for installation or use

onboard a vessel, designed to receive, retain, treat, control, or eliminate a discharge incidental to

the normal operation of a vessel. Phase I of UNDS requires several factors to be considered

when determining which discharges should be controlled by MPCDs. These include the

practicability, operational impact, and cost of an MPCD. During Phase I of UNDS, an MPCD

option was deemed reasonable and practicable even if the analysis showed it was reasonable and

practicable only for a limited number of vessels or vessel classes, or only on new construction

vessels. Therefore, every possible MPCD alternative was not evaluated. A more detailed

evaluation of MPCD alternatives will be conducted during Phase II of UNDS when determining

the performance requirements for MPCDs. This Phase II analysis will not be limited to the

MPCDs described below and may consider additional MPCD options.

MPCD Options

Underwater ship husbandry activities include inspecting, grooming, maintaining, and

repairing hulls and hull appendages while a vessel is waterborne.1 Underwater hull cleaning is, by

far, the most common underwater ship husbandry process and has the highest potential for

environmental impact. Underwater hull cleaning is performed for numerous reasons including fuel

savings, extending service life of hull coatings, and extending the interval between dry dockings

and associated coating replacement. To determine the practicability of mitigating the potentially

adverse environmental effects of these activities, three potential MPCD options were investigated.

The purpose of these MPCDs would be to reduce or eliminate the release of antifouling agents,

specifically copper and zinc, into surrounding waters during underwater hull cleaning operations.

The MPCD options were selected based on initial screenings of alternate materials, equipment,

pollution prevention options, and management practices. They are listed below with brief

descriptions of each:

Option 1: Vary hull cleaning brush type and brush pressure - The goal of this

option would be to more closely match brush stiffness and pressure to the degree

of fouling to minimize antifouling coating removal. More brush types would be

developed, and several different brush types may be used and interchanged during

the cleaning of any one vessel. By properly selecting brushes, effective cleaning

can be conducted with a minimal release of antifouling agents and associated

discharges.
Underwater Ship Husbandry MPCD Analysis

2

Option 2: Mandate the maximum allowable frequency of underwater hull

cleaning - This option would reduce the number of hull cleanings permissible

within a given time period or at any one location to limit the amount of discharge

within each harbor.

Option 3: Collect water discharged from the multi-brush cleaning vehicle -

This option would provide a means to collect the discharge from the underwater

hull cleaning vehicles to prevent water that contains antifouling agents from

entering the surrounding environment.

MPCD Analysis Results

Table 1 shows the findings of the investigation of the selected MPCD options. It

contains information on the elements of practicability, effect on operational and

warfighting capabilities, cost, environmental effectiveness, and a final determination for

each option. Based on these findings, Option 1 -- varying hull cleaning brush type and

brush pressure -- offers the best combination of these elements and is considered to

represent a reasonable and practicable MPCD.
Underwater Ship Husbandry MPCD Analysis

3

Table 1. MPCD Option Analysis and Determination

MPCD Option Practicability Effect on Operational &

Warfighting Capabilities

Cost Environmental

Effectiveness

Determination

Option 1. Vary Hull

Cleaning Brush Type &

Brush Pressure

New brush types would

have to be developed so

they could more closely

match the hull fouling

condition. Monitoring and

controlling brush pressure

and aggressiveness would

further enhance cleaning

procedures.

Using different cleaning

brushes should not reduce

vessel capabilities as hulls

would still be required to

be cleaned to current

standards. However,

interchanging brush types

will potentially increase

cleaning time, thereby

slightly decreasing vessel

availability.

Cleaning costs will likely

increase if the brushes

have to be switched more

frequently or if the

discharge has to be

monitored. Additional

costs associated with

development of new

brushes would be

incurred.2

Varying brush type and

pressure will reduce copper

and zinc mass loading due

to a reduction in brush

aggressiveness by an

estimated 10% to 20%

depending on the age and

type of antifouling coating

system.1

Developing and

manufacturing new

brushes: 1) can be

implemented, 2) is cost

effective, and 3) will

reduce mass loading.

Therefore, this MPCD

option warrants further

consideration.

Option 2. Mandate the

maximum allowable

frequency of underwater

hull cleaning

Pre-cleaning inspections

are currently performed

and compared to hull

cleaning criteria to prevent

unwarranted hull

cleanings. Any further

prohibitions on cleaning

frequency could potentially

negate the benefits of hull

cleaning.3

Reducing the frequency of

hull cleanings would

increase hull fouling

causing increased fuel

consumption, decreased

maximum vessel speed,

and increased acoustic

signature, and, therefore,

adversely affect vessel

mobility and readiness.

Reducing cleaning

frequency will increase

annual fuel costs by up to

$75,000 for a typical

cruiser.4,5

Although reducing the

number of cleaning events

may reduce total load, the

increased aggressiveness

required to clean a more

heavily fouled hull could

result in equal or greater

total discharge. This

option may necessitate

more frequent paintings.

Newly applied coatings

have been shown to have

much higher copper

release rates than old

coatings, so the more ships

with newer coatings could

increase loadings.

This option results in a

performance penalty and

increased fuel costs with

questionable

environmental benefit.

Option 3. Collect Water

Discharged From the

Multi-Brush Cleaning

Vehicle

Installing discharge hoses

on existing cleaning units

does not seem to be

possible due to the

Collecting effluent during

cleaning operations will

increase cleaning time,

resulting in reduced vessel

If this option is proven to

be feasible, there would be

higher costs associated

with: 1) technology

A new hull cleaning

device has the potential to

reduce mass loading of

copper and zinc by 100% if

Although this option would

eliminate the discharge, if

the new hull cleaning

device proves to be
Underwater Ship Husbandry MPCD Analysis

4

MPCD Option Practicability Effect on Operational &

Warfighting Capabilities

Cost Environmental

Effectiveness

Determination

diameter of the hose

required, the expected flow

rate, and the head required

to discharge to the pier.

Operating such a device

could compromise diver

mobility and safety.

Alternatively, a new hull

cleaning device that would

collect cleaning effluent is

in early stages of

development and the

practicability of this device

has yet to be determined.

This effort is several years

away from completion.

availability. If cleaning

effectiveness is reduced,

this would adversely affect

acoustic signature, fuel

consumption, vessel speed,

and vessel mobility.

development, 2) increased

cleaning time, and 3) waste

treatment and disposal.

no discharge escapes

collection during cleaning

operations.

successful, this may

become a viable

alternative. Adapting a

collection system to the

current diver-based

technology is not feasible.
Underwater Ship Husbandry MPCD Analysis

5

REFERENCES

1 Equipment Expert Meeting Minutes, Underwater Hull Husbandry, 22 October 1996.

2 McCue, T. (NAVSEA Code 00C). Personal communication with K. Thomas. Estimate of

Cleaning Brush Costs based on previous R&D of same. 1997

3 Naval Ships’ Technical Manual S9086-CQ-STM-010 R3 Chapter 081, Waterborne Underwater

Hull Cleaning of Navy Ships. 4 August 1997.

4 Hundley, L. L. and Tate, C. W., Sr. (David W. Taylor Naval Ship Research and Development

Center). “Hull Studies and Ship Powering Trial Results of Seven FF 1052 Class Ships,”

DTNSRDC-80/027. March 1980.

5 Naval Petroleum Office Instruction. July 1997.
Welldeck Discharges

1

NATURE OF DISCHARGE REPORT

1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal

Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the

Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)

develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,

...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase (which this

report supports), will determine which discharges will be required to be controlled by marine

pollution control devices (MPCDs)—either equipment or management practices. The second phase

will develop MPCD performance standards. The final phase will determine the design,

construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has

been identified as a candidate for regulation under UNDS. The NOD reports were developed

based on information obtained from the technical community within the Navy and other branches

of the Armed Forces with vessels potentially subject to UNDS, from information available in

existing technical reports and documentation, and, when required, from data obtained from

discharge samples that were collected under the UNDS program.

The purpose of the NOD report is to describe the discharge in detail, including the system

that produces the discharge, the equipment involved, the constituents released to the

environment, and the current practice, if any, to prevent or minimize environmental effects.

Where existing process information is insufficient to characterize the discharge, the NOD report

provides the results of additional sampling or other data gathered on the discharge. Based on the

above information, the NOD report describes how the estimated constituent concentrations and

mass loading to the environment were determined. Finally, the NOD report assesses the

potential for environmental effect. The NOD report contains sections on: Discharge

Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data

Sources and References.

Welldeck Discharges
Welldeck Discharges

2

2.0 DISCHARGE DESCRIPTION

This section describes the welldeck discharges and includes information on the

equipment that is used and its operation (Section 2.1), general description of the constituents of

the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Several Navy ship classes have a welldeck in the aft section of the ship for embarking,

storing, and disembarking landing craft. These welldecks range from 50 to 78 feet in width, 168

to 440 feet in length, and 20 to 30 feet in height.1 During an amphibious operation or beach

assault, the ship can be positioned anywhere within proximity of land. However, the operations

are more likely to occur near the 12 nautical mile (n.m.) limit so the ship is less susceptible to

enemy gunfire from shore. The landing craft carried onboard the ship serve to ferry U. S. Marine

Corps (USMC) personnel, vehicles, and equipment to and from shore. Depending on the type of

landing craft used, the ship might fill ballast tanks with seawater to lower the ship so that the

welldeck floods with water (see Figure 1).

The types of craft that typically operate from these ships are utility landing craft (LCUs),

air-cushion landing craft (LCACs), and assault amphibian vehicles (AAVs). LCUs have diesel

engines to power the propellers. LCACs are gas-turbine-driven hovercraft. AAVs propel

themselves through the water with waterjets, but use tracked running gear on land. Although

AAVs can enter and exit the welldeck independently, they are also carried onboard LCUs and

LCACs. Mechanized landing craft (LCM), once common to amphibious operations, are no

longer carried by amphibious ships.1,2

Vehicles and equipment are stored in the vehicle storage areas forward of the welldeck.

These areas are located on two levels and are connected by ramps. Vehicles and equipment are

also stored onboard the LCUs and LCACs in the welldeck but not in the welldeck itself due to

space constraints. Similarly, containers and products are not stored in the welldeck but rather in

the vehicle storage areas or elsewhere on the ship. Examples of the vehicles carried onboard

include light armored vehicles (LAVs), AAVs, tanks, jeeps, trucks, high mobility multipurpose

wheeled vehicles (HMMWVs), and motorcycles. Examples of equipment carried onboard

include howitzers and trailers.2

The floors of the welldeck are lined with pressure treated lumber. The walls are lined

with either pressure treated lumber or synthetic batter boards except near the stern gate where the

walls are lined with rubber panels.

Vehicle and equipment maintenance is performed where the vehicles and equipment are

stored, which can include on the deck of a host LCU or LCAC. Waste products and spills

produced during vehicle maintenance are collected and held in accordance with shipboard

procedures for spill containment. Oily patches on the decks are cleaned with a detergent.2

There are five primary overboard discharges from a welldeck: (1) washout from the
Welldeck Discharges

3

welldeck when the ship ballasts to embark or disembark landing craft; (2) water or detergent and

water mixture used for LCAC gas turbine engine washes; (3) graywater and condensate that can

be discharged from the LCUs; (4) freshwater wash to remove salt and dirt from vehicles,

equipment, and landing craft; and (5) U.S. Department of Agriculture (USDA) washes of the

welldeck, vehicle storage areas, and all vehicles, equipment, and landing craft. These discharges

can occur almost anywhere within 12 n.m., except for the USDA work which occurs pierside.

2.1.1 Welldeck Washout

Washout occurs when the welldeck is flooded to allow landing craft to enter or exit the

ship. However, LCACs and AAVs do not need the welldeck to be flooded to enter or exit,

although some water will naturally enter. Therefore, this discussion is primarily applicable to

LCU operations. The ship submerges the welldeck by flooding clean ballast tanks with

seawater.3 See Figure 1. When the welldeck is submerged, any debris or fluid in the welldeck is

mixed with the seawater and will eventually flow to the open sea.

2.1.2 LCAC Engine Washes

The LCAC engine washes are performed on the four gas turbine engines provided for

propulsion and the two auxiliary power units (APUs) provided to supply electrical power. There

are two types of LCAC engine washes: thorough preventive-maintenance washes that uses a

detergent to remove engine deposits and those performed daily with only distilled water to

remove salt deposits. During winter conditions, methanol may be added to the mixture to

prevent the wash water from freezing.4

Preventive-maintenance washes are scheduled every 25 operating hours for the gas

turbines and quarterly for the APUs. Because the purpose of these washes is to prevent engine

degradation, any noticeable reduction in engine performance will usually result in a wash. There

are currently two separate methods used to perform these washes but both involve flushing

distilled water and detergent through the engine while it is being rotated on the starter. One

method uses an automated cleaning system, if installed, and a detergent called ZOK-27. The

other, a more manual procedure, uses a detergent called B&B 3100 (MIL-C-85704). Following

the detergent wash, a separate distilled water wash is performed to flush out the engine. APUs

are washed in a similar way except that the detergent is Stoddard Solvent, FedSpec P-D-680,

type III.2,3

Daily washes are performed when the LCACs have been operating, but not if preventive

maintenance washes are scheduled for the same day. This wash consists of a rinse of distilled

water through the propulsion gas turbines, but not the APUs. However, if a cleaning system is

installed it may also be used for the daily wash as it is for the preventive maintenance wash.

2.1.3 Landing Craft Discharges

LCU crews live aboard their craft in the welldeck. As such, they generate graywater (i.e.,

water from drains, sinks, and showers) as well as condensate from air conditioning systems. The
Welldeck Discharges

4

graywater and condensate produced is drained to the welldeck. LCUs do not create blackwater

(sewage) because the crew uses the ship’s sanitary facilities.3 LCACs do not have living spaces,

do not produce graywater, and do not discharge condensate into the welldeck.2 For more

information on graywater, see the Graywater NOD Report.

2.1.4 Vehicle, Equipment, and Landing Craft Washes

Dirty vehicles and equipment returning to the ship are washed ashore, if possible. They

also will receive a freshwater wash on the ramp leading from the welldeck to the vehicle storage

area. The engine compartments are not washed.2 The wash water flows into the welldeck and is

drained overboard or pumped overboard by an eductor. The motive water for the eductors in the

welldeck and vehicle storage areas is provided by the firemain.

The aluminum structure of an LCAC is unpainted and susceptible to the corrosive effects

of seawater. To prevent this corrosion, the exterior is washed with fresh water at the conclusion

of daily operations. If the LCACs are not being used, a biweekly wash is required.5 No cleaners

or detergents are used for these washes. LCUs and AAVs are not washed in the welldeck.

2.1.5 USDA Washes and Inspections

The USDA requires that vehicles, equipment, craft, and internal shipboard areas that have

contacted foreign soil be thoroughly washed and inspected to prevent the importation of nonindigenous species. These washes and inspections are performed prior to returning to, or upon

return to, the U.S. These washes and inspections fall into three categories; those done on the

welldeck and vehicle storage areas, those done on the vehicles and equipment, and those done on

the landing craft. These three operations normally occur in foreign ports, but can occur in the

U.S. or U.S. territories. 2

The welldeck and vehicle storage areas are washed when all of the vehicles, equipment,

and landing craft that can be off-loaded are removed. Those that remain are too large to fit down

the exit ramp on the side of the ship. Their normal path is through the stern gate. One example

is the M-9 armored combat earthmover (ACE) which is 10.5 feet wide and 8.75 feet high.

During the washes all surfaces (decks, bulkheads, and overheads) are cleaned. The process for

the welldeck begins with a seawater wash of all surfaces followed by a freshwater wash. Unlike

the welldeck, the vehicle storage areas are only washed with fresh water. Following the washes,

the USDA inspects to ensure that no foreign species, soil, or plants are in those areas. All of the

water effluent drains overboard or is pumped overboard by an eductor.2

The vehicles and equipment are washed pierside, except for those discussed above that

cannot be off-loaded. They will be washed and inspected in the welldeck. The process begins

with the vehicles and equipment being parked in a designated contaminated area. Each, in turn,

is then moved to an area to have the interior cleaned. They are then moved to the wash racks and

thoroughly washed (including the engine compartments) with fresh water. The wash racks are

long wheel ramps that allow the undersides of the vehicles to be washed and inspected.

Following the wash, each vehicle or piece of equipment is inspected by the USDA for foreign
Welldeck Discharges

5

organisms, plants, and soil, and then moved to a designated clean area to await reloading on the

ship. The effluent from the vehicles and equipment washed in the welldeck drains overboard or

is pumped overboard by an eductor.2

The landing craft are also washed and inspected. LCACs, however, are not usually given

a special wash because enough sea spray is created in their operation that all the exterior surfaces

are flushed free of foreign organisms, plants, and soil before the LCAC boards the ship at sea and

is inspected. LCUs are washed with fresh water in the welldeck or pierside and then inspected.2

2.2 Releases to the Environment

Effluent is discharged to the environment by washout or surge when landing craft are

operating in the welldeck. Effluent from the various washes performed in the welldeck are

discharged as it drains overboard from the welldeck or is pumped overboard by an eductor.

Welldeck washout and the effluent from the washes can contain fresh water, distilled

water, firemain water, graywater, air-conditioning condensate, sea-salt residues, paint chips,

wood splinters, dirt, sand, organic debris, oil, grease, fuel, detergents, combustion by-products,

and lumber treatment chemicals.

2.3 Vessels Producing the Discharge

Only the Navy has ships with welldecks. Ship classes with welldecks include general

purpose amphibious assault ships (LHAs), multipurpose amphibious assault ships (LHDs),

amphibious transport docks (LPDs), and dock landing ships (LSDs). While there are differences

among welldeck designs, the primary process variance is due to the type and number of landing

craft onboard. Applicable data is listed below.1

Ship No. of Welldeck Landing Craft

Class Ships Dimensions Loading Schemes

LHA 1 5 268’ x 78’ 4 LCU, 1 LCAC, or 45 AAV

LHD 1 4 267’ x 50’ 3 LCAC or 2 LCU

LPD 4 8 168’ x 50’ 1 LCU or 28 AAV

LSD 36 5 430’ x 50’ 4 LCAC, 3 LCU, or 52 AAV

LSD 41 8 440’ x 50’ 4 LCAC, 3 LCU, or 64 AAV

LSD 49 3 265’ x 50’ 2 LCAC or 1 LCU

3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

discharge. Section 3.1 describes where the discharge occurs with respect to harbors and nearshore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in

the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
Welldeck Discharges

6

3.1 Locality

Welldeck discharges can occur both within and beyond 12 n.m.

3.2 Rate

3.2.1 Welldeck Washouts

The flow from a welldeck washout can be estimated based on the welldeck dimensions

listed in Section 2.3. The washout volume was estimated by multiplying the dimensions of the

welldeck (length and width in feet) by the approximate height of water needed by an LCU (5’

2

 The numbers shown in parenthesis are estimated values for the

amount of water entering the welldeck during LCAC operations (using an assumed depth of 4

inches of water spread uniformly across the welldeck). The water in the welldeck during LCAC

operations is the result of the surge created when the LCACs enter the ship and is not the result

of ballasting.

Ship Class Estimated Gallons Per Washout (or Surge)

LHA 1 1,100,000 (52,000)

LHD 1 700,000 (33,000)

LPD 4 440,000 (0, no LCACs)

LSD 36 1,130,000 (54,000)

LSD 41 1,150,000 (55,000)

LSD 49 700,000 (33,000)

On average, an amphibious ship will have one six-month deployment every two years.

During such a deployment, ballasting/deballasting will take place approximately 40 times (unless

LCACs are deployed in which case the seawater surge will enter the welldeck 40 times).2 It is

variable how many times the ballasting/surge will take place within U.S. waters or how many

local exercises will take place during that two year period. This is because the amount of time

that a ship spends in U.S. waters varies from ship to ship.

3.2.2 LCAC Gas Turbine Engine Washes

Approximately 12 gallons of distilled water is used for a propulsion gas turbine daily

wash. The flow from a detergent wash would be 12.5 gallons of distilled water/detergent mix

followed by 12 gallons of distilled water rinse for a total of 24.5 gallons. For each APU, the flow

from a detergent wash would be 0.375 gallon of distilled-water-detergent mix followed by a 0.25

gallon distilled water rinse for a total of 0.625 gallon. Thus, each LCAC is capable of producing

48 gallons of effluent from the daily washes of the four propulsion gas turbines and 99.25 gallons

of effluent if all of the engines (four propulsion and two APUs) are washed with a waterdetergent mix.2,6
Welldeck Discharges

7

3.2.3 Graywater and Air Conditioning Condensate

LCUs discharge graywater into the welldeck because they do not have the capability to

collect and hold graywater. Air-conditioning condensate is also not collected.

During the transit of an amphibious ship from port to 12 n.m., the LCU would have 4

hours to generate graywater. The rate of graywater generation for Navy personnel is given as 30

gallons per person per day. Thus, an LCU with a typical load of six crew members could

generate 180 gallons of graywater per day or 30 gallons of graywater during the 4-hour transit

period. However, little or no graywater is produced and discharged within 12 n.m. because the

crew of the LCU is occupied with preparations for, or stand down from, welldeck operations.

The generation of graywater on an LCU while the host ship is operating within 12 n.m.

has not been estimated since the time that a host ship will be operating within 12 n.m. varies.

LCU air-conditioning capacity varies from 5 to 8 tons which, under severe heat and humidity

conditions, can produce 30 to 48 gallons of condensate per day.

3.2.4 Vehicle, Equipment, and Landing Craft Washes

When returning to the ship, vehicles and equipment receive a freshwater wash on the

ramp leading from the welldeck to the vehicle storage area. This freshwater wash uses a 1.5-inch

firehose at a rate of about 95 gallons per minute (gpm).2 The wash typically takes 30 seconds, so

it is estimated that 48 gallons of fresh water is used per wash. A typical ship contains about 100

to 125 vehicles and pieces of equipment, so approximately 4,800 to 6,000 gallons could be

discharged if all of the vehicles and equipment are returned to the ship and washed consecutively.

The exterior wash of the LCACs is performed at the end of daily operations. This wash

also uses a 1.5-inch firehose at a rate of 95 gpm and lasts for about 10 minutes. Estimates from

LCAC personnel indicate that about 1,000 gallons of water are used per LCAC, which is

consistent with a 10 minute wash at 95 gpm.2 Since the number of LCACs carried onboard a

ship can vary as shown in Section 2.3, 1,000 to 4,000 gallons of water could be released by these

washes. However, if the LCACs are not being used, only a biweekly wash is required.5

3.2.5 USDA Washes and Inspections

The welldeck and vehicle storage areas are washed differently. The welldeck is first

washed with seawater via the firemain, and then washed with fresh water. The vehicle storage

areas are only washed with fresh water. Each wash takes about 45 minutes. The seawater wash

of the welldeck uses a 1.5-inch firehose at a rate of about 95 gpm of seawater. Based on the

estimated time of 45 minutes, about 4,275 gallons are used. The freshwater wash of the welldeck

also uses a 1.5-inch firehose at a rate of about 95 gpm. Again, based on the estimated time of 45

minutes, about 4,275 gallons are used. The upper and lower vehicle storage areas are washed

separately with fresh water, each taking about 45 minutes, and using a 1.5-inch firehose at a rate

of about 95 gpm. To summarize these estimates, 4,275 gallons of firemain water and 4,275

gallons of fresh water are used to wash the welldeck and 8,550 gallons of fresh water are used to
Welldeck Discharges

8

wash both vehicle storage areas.

The vehicles and equipment are washed with a 1.5-inch firehose at a rate of about 95 gpm

of fresh water. Each vehicle or piece of equipment takes about 5 minutes to wash. Therefore,

about 475 gallons of water are used. If five to ten vehicles or pieces of equipment were unable to

be off-loaded, 2,375 to 4,750 gallons of water could be used.

The duration of the landing craft washes for calculation purposes will be estimated at 15

minutes using a 1.5-inch firehose at rate of about 95 gpm of fresh water. Therefore, about 1,425

gallons could be used for each landing craft. The washing of the LCACs in this manner is

unlikely however, so the loading of one to four LCUs (from Section 2.3) is used to yield a range

of effluent produced which is 1,425 to 5,700 gallons.

3.3 Constituents

The potential constituents of this discharge include:2,3

• air-conditioning condensate

• automotive grease

• B&B 3100 detergent (MIL-C-85704)

• bromine (from the wash water)

• chlorine (from the wash water)

• detergent

• gas turbine fuel, JP-5 (MIL-F-5624E)

• graywater

• lumber-treatment chemicals

• methanol

• motor oils

• naval distillate fuel, F-76 (MIL-F-16884)

• nickel, copper, zinc, and other metals

• solvent P-D-680 type III (petroleum distillate)

• vehicle diesel fuel, F-34 (MIL-T-83133)

• ZOK-27 water-soluble detergent

ZOK-27 contains ethanol and 2-butoxyethanol, while B&B 3100 contains solvent-refined

heavy naphthenic distillate and petroleum solvents. Marine diesel fuel (F-76) contains petroleum

mid-distillates, antisetting agents, and flow improvers.

It is possible that lube oils, greases, and fuel oils can be spilled on welldeck surfaces.

However, spills will be quickly wiped up in accordance with shipboard practices, so any oils or

greases found on welldeck surfaces will exist as surface films. Such surface films may contain

benzene, toluene, ethylbenzene, and xylenes which are the common constituents of lighter

petroleum products. These chemicals are also priority pollutants, as are various metals (e.g.,

copper and nickel) which are in firemain water and could be present in greases, oils, and fuels.7
Welldeck Discharges

9

There are no constituents present in welldeck discharges that are bioaccumulators.8

3.4 Concentrations

The constituent concentrations have not been estimated. The concentration of metals in

the firemain water is discussed in the Firemain Systems NOD Report.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the

discharge and its potential impact on the environment can be evaluated. A discussion on the

mass loadings is presented in Section 4.1. In Section 4.2, the concentrations of discharge

constituents after release to the environment are discussed along with the water quality standards.

In Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Since numbers that quantify the constituents of the various components of this discharge

are unknown and variable, mass loading calculations cannot be performed with any accuracy.

However, generalized statements regarding the mass loadings can be made based upon the

physical features of the discharge.

4.1.1 Welldeck Washouts

Spills from vehicle and equipment maintenance within the welldeck could potentially

result in the discharge of substances such as oil. These spills can leave a residue on the deck.

However, spills are controlled by shipboard procedures for spill containment and clean-up. Oily

patches on the decks are cleaned with a detergent.2 The small amounts of constituents remaining

as surface films in the welldeck do not support the production of significant mass loadings.

4.1.2 LCAC Engine Washes

The degree to which engine contaminants are removed by the wash water is unknown and

the amounts of engine washes within 12 n.m. are unknown. Since there are many LCACs and

not all of them are operating each day or are not within U.S. waters, it will be assumed that 1

LCAC is operating each day in U.S waters and requires an engine wash. Since the gas turbine

engines are relatively clean, it is assumed that, at most, a few tablespoons of hydrocarbon

constituents will be removed by each wash. Using these numbers, only 3-5 gallons of

hydrocarbon constituents would be released by the engine washes, per year, in U.S. waters.

4.1.3 Graywater and Air Conditioning Condensate

As discussed in section 3.2.3 above, it is estimated that 30 gallons of graywater can be

discharged from an LCU while the host ship is transiting to 12 n.m. LCUs are not normally
Welldeck Discharges

10

carried onboard amphibious ships since LCACs are favored. Assuming 10 LCUs are carried

onboard ships during a year, and assuming that each ship transits the 12 n.m. zone 6 times per

year, it is estimated that, at most, 1800 gallons of graywater will be released per year during

transit. These assumptions overestimate the amounts of graywater produced because it is

unlikely that each LCU on a host ship is discharging graywater at the maximum design rate

during the entire 12 n.m. transit. Graywater production is likely to be much lower during transit

because the LCU crew is occupied with preparations for, or stand down from, welldeck

operations. In port, mass loadings of graywater can equal the design rate so each LCU could

produce 180 gallons per day (32,760 gallons per year assuming 6 months in port).

Based on the discussions in the Refrigeration/AC Condensate NOD Report, the

condensate discharge contains little or no constituents and insignificant mass loadings are

expected.

4.1.4 Vehicle, Equipment, and Landing Craft Washes

These washes are directed at the external surfaces of vehicles, equipment, and landing

craft. The engine compartments are not washed. Any hydrocarbon constituents would be present

as films on exterior surfaces. Assuming that a tablespoon (29.6 mL) of oil was present and

washed off per vehicle, landing craft, etc., and that 1000 are washed in U.S. waters per year, only

about 4 gallons of oil would be released per year. However, it is felt that a tablespoon is an

overestimate of the amount of oil that could be removed by such washes.

4.1.5 USDA Washes and Inspections

Although somewhat similar to 4.1.3 discussed above, the vehicle portion of these washes

are substantially longer and include a high-pressure wash of the engine compartments external to

the vehicles. However since these washes are almost entirely performed shoreside, only the

effluent from those vehicles washed in the welldeck has the potential to enter the water.

Assuming 20 vehicles per year are given this wash while in U.S. waters, and half a pint (473 mL)

of oil is removed from each, only 1.25 gallons of oil would be released per year. However, these

assumptions will tend to overestimate of the amount of oil that could be removed by such

washes.

The other portion of this discharge, the washing of the welldeck and vehicle storage areas,

will only occur several times a year, at most, since the USDA washes and inspections are

normally conducted while the ship is still overseas. Furthermore, the hydrocarbon constituents

present will be in the form of surface films so significant mass loadings are not expected.

4.2 Environmental Concentrations

Since numbers that quantify the volumes and constituents of the various components of

this discharge are unknown and variable, concentrations cannot be performed with any accuracy.

However, generalized calculations and statements regarding the mass loadings can be made

based upon the known physical features of the discharge.
Welldeck Discharges

11

4.2.1 Welldeck Washout

Spills from vehicle and equipment maintenance within the welldeck could potentially

result in the discharge of substances such as oil. The spills can coat the deck with a residue.

However, the spills are controlled by shipboard procedures for spill containment and clean-up.

Oily patches on the decks are cleaned with a detergent.2 The small amounts of constituents

remaining as surface films in the welldeck do not support the production of significant mass

loadings. The large water volumes involved (see 3.2.1) and the small volumes contained in the

surface films do not appear to support the production of significant contaminant concentrations

in the washouts and it is not expected that they will exceed federal or state water quality criteria.

The visual criteria for oily discharges is that the discharge does not cause a sheen while the Act

to Prevent Pollution from Ships limits the oil content of the discharge to 15 parts per million

(approximately 15 mg/L). Florida has set a criterion of 5,000 micrograms per liter (μg/L) with

no visible sheen.

4.2.2 LCAC Engine Washes

Since this discharge comprises a low volume of water which passes through an engine

and is in contact with hydrocarbons, it is believed that water quality criteria can be exceeded. A

rough estimate of contaminant concentrations can be performed to check the validity of assuming

that hydrocarbon concentrations in the discharge can exceed water quality criteria. It does not

seem unreasonable to assume that one teaspoon (4.9 mL) of hydrocarbon constituents could be

deposited within the gas turbine engine and washed away in the discharge. The 4.9 mL placed in

12 gallons (45.42 L) of water (daily wash) will yield a hydrocarbon concentration of about

108,000 ppb of oil which exceeds the Florida water quality criterion of 5,000 ppb of oil. This

rough calculation supports the assumption that water quality criteria can be exceeded. There is

also the possibility that trace amounts of metals could be present that exceed federal and state

water quality criteria. Furthermore, the nature of the detergent wash will liberate more

hydrocarbon constituents and it is still assumed that water quality criteria can be exceeded, even

though twice as much water is used.

4.2.3 Graywater and Air Conditioning Condensate

As discussed in section 3.2.3 above, it is estimated that 30 gallons of graywater can be

discharged from an LCU while the host ship is transiting the 12 n.m. zone, or 180 gallons per day

in port. LCU graywater has not been sampled, but it is possible that graywater sampling data for

surface ships can be applied to the LCUs. According the Graywater NOD Report, the measured

concentrations of several metals in the discharge exceed ambient water quality criteria and the

estimated loadings of nutrients, solids, and oxygen-demanding substances are high.

As discussed in section 3.2.3 above, it is estimated that 30 to 48 gallons of airconditioning condensate can be produced each day. Based on the Refrigeration/AC Condensate

NOD Report, this discharge contains little or no constituents and has a low probability of

producing an environmental effect.
Welldeck Discharges

12

4.2.4 Vehicle, Equipment, and Landing Craft Washes

Although concentrations have not been calculated, the low volumes of water that are

mixed with small amounts of hydrocarbon constituents, are not considered to exceed federal or

state water quality criteria or to have an environmental effect.

4.2.5 USDA Washes and Inspections

The discharge from the USDA washes of the welldeck and vehicle storage areas will

contain dirt, debris, detergents, and hydrocarbons in concentrations that could possibly exceed

federal discharge standards or state water quality criteria. The washes of the welldeck will also

contain metals from the ship’s firemain.

4.3 Potential for Introducing Non-Indigenous Species

Although washes and inspections are required by the USDA for the vehicles, equipment,

landing craft, welldeck, and vehicle storage areas, the potential for introducing non-indigenous

species exists when the washes occur in U.S. ports. The wash water effluent could potentially

carry non-indigenous species from the ship into the water. It should be noted that the USDA

washdowns are intended to prevent transfer of non-indigenous species to land and the viability of

any waterborne species introduced is questionable since they generally would have been exposed

to air for extended periods of time prior to their introduction into U.S. coastal waters (i.e., for the

most part, these species would have been removed from vehicles and deck surfaces and thus it

would not be a water-to-water transfer, in contrast to species transfers from ballast water

systems).

5.0 CONCLUSIONS

If uncontrolled, discharges from the well deck could possibly have the potential to cause

an adverse environmental effect because oil drippings spilled during vehicle and equipment

maintenance would leave an oil film on the deck surface. When the welldeck is flooded, the oil

film can be washed from the deck by the incoming water. An oil sheen could possibly be

discharged when water within the welldeck is discharged. However, current management

practices provide for the clean-up of oil and other substances spilled during routine maintenance.

These practices reduce the possibility of discharging an oil sheen.

6.0 DATA SOURCES AND REFERENCES

To characterize the discharge, information from various sources was obtained. Process

information and assumptions were used to estimate the rate of discharge. Information to

determine the concentrations and loadings of constituents is not available. Table 1 shows the

sources of data used to develop this NOD report.
Welldeck Discharges

13

Specific References

1. Sharpe, Richard. Jane's Fighting Ships. Jane's Information Group, Ltd., 1996. 790-792.

2. Report on the Ship Check of USS Kearsarge (LHD 3) by M. Rosenblatt & Son, Inc.

(MR&S) dated October 1, 1997.

3. UNDS Equipment Expert Meeting Minutes - Welldeck Washout, October 3, 1996.

4. Welldeck/LCAC Questionnaire completed by Assault Craft Unit 4, June 1997.

5. Operating Instructions for LCAC/Welldeck Operations, SEAOPS Manual for LCAC,

Volume III, Revisions 1 and 2. September 30, 1995.

6. Eaton, Tim, CAPT USMC, USS Kearsarge. Gas Turbine Water Washes, 10 October

1997, David Eaton, MR&S, Inc.

7. Committee Print Number 95-30 of the Committee on Public Works and Transportation of

the House of Representatives, Table 1.

8. The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal

Register, p. 15366. March 23, 1995.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section

303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for

Priority Toxic Pollutants; States’ Compliance – Revision of Metals Criteria. 60 FR 22230.

May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants. 57 FR 60848. December 22, 1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic

Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal

Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

62-302. Effective December 26, 1996.
Welldeck Discharges

14

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi

Department of Environmental Quality, Office of Pollution Control. Adopted November

16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC

25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

173-201A, Washington Administrative Code (WAC).
Welldeck Discharges

15

Figure 1. Basic View of an Amphibious Ship Ballasted and Deballasted
Welldeck Discharges

16

Table 1. Data Sources

Data Source

NOD Section Reported Sampling Estimated Equipment Expert

2.1 Equipment Description and

Operation

X

2.2 Releases to the Environment X

2.3 Vessels Producing the Discharge UNDS Database X

3.1 Locality X

3.2 Rate X

3.3 Constituents MSDS X

3.4 Concentrations X X

4.1 Mass Loadings X

4.2 Environmental Concentrations X

4.3 Potential for Introducing NonIndigenous SpeciesX
B-1

Appendix B

Matrix of Navy Vessels and Discharges
Appendix B

Navy Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

AC X X X X

AFDB 4 X X X X X

AFDB 8 X X X X X

AFDL 1 X X X X X X

AFDM 3 X X X X X X

AFDM 14 X X X X X X

AGER 2 X X X X X X X X

AGF 3 X X X X X X X X X X X X X X

AGF 11 X X X X X X X X X X X X X X

AGOR 21 X X X X X X X X X X X X

AGOR 23 X X X X X X X X X X X X

AGSS 555 X X X X X X X X X X X

AO 177 X X X X X X X X X X X X X

AOE 1 X X X X X X X X X X X X X X X

AOE 6 X X X X X X X X X X X X X X X

AP X X X X X

APL X X X X

AR X X X X X X

ARD 2 X X X X X X X

ARDM X X X X X X X

ARS 50 X X X X X X X X X X X X

AS 33 X X X X X X X X X X X X X X

AS 39 X X X X X X X X X X X X X X

ASDV X X X X X X X

AT X X X X X X

B-2
Appendix B

Navy Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

ATC X X X X X X X

BH X X X X

BT X X X

BW X X X X

CA X X X X

CC X X X X

CG 47 X X X X X X X X X X X X X X X X X

CGN 36 X X X X X X X X X X X X X X X

CGN 38 X X X X X X X X X X X X X X X

CM X X X X X

CT X X X X X

CU X X X X X

CV 59 X X X X X X X X X X X X X X X

CV 63 X X X X X X X X X X X X X X X X

CVN 65 X X X X X X X X X X X X X X X

CVN 68 X X X X X X X X X X X X X X X X

DB X X X X

DD 963 X X X X X X X X X X X X X X X X X

DDG 51 X X X X X X X X X X X X X X X X X

DDG 993 X X X X X X X X X X X X X X X X X

DSRV-1 X X X X X X X

DSV 1 X X X X X X X

DT X X X X

DW X X X X

FFG 7 X X X X X X X X X X X X X X X X X

B-3
Appendix B

Navy Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

HH X X X X

HL X X X X

HS X X X X

IX X X X X X

IX 35 X X X X X

IX 501 X X X X X

IX 308 X X X X X X

LA X X X X

LCAC 1 X X X X X X

LCC 19 X X X X X X X X X X X X

LCM(3) X X X X X X X

LCM(6) X X X X X X X

LCM(8) X X X X X X X

LCPL X X X X X X

LCU 1610 X X X X X X X

LCVP X X X X X X

LH X X X X

LHA 1 X X X X X X X X X X X X X X X X

LHD 1 X X X X X X X X X X X X X X X

LPD 4 X X X X X X X X X X X X X X X X

LPD 7 X X X X X X X X X X X X X X X X

LPD 14 X X X X X X X X X X X X X X X X

LPH 2 X X X X X X X X X X X X X

LSD 36 X X X X X X X X X X X X X X X

LSD 41 X X X X X X X X X X X X X X X X

B-4
Appendix B

Navy Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

LSD 49 X X X X X X X X X X X X X X X X

LST 1179 X X X X X X X X X X X X X

MC X X X X

MCM 1 X X X X X X X X X X X X X

MHC 51 X X X X X X X X X X X X

ML X X X X

MM X X X X

MW X X X X

NM X X X X

NS X X X X X X X X

PB X X X X X X X

PBR X X X X X X X

PC 1 X X X X X X X X X X X

PE X X X X

PF X X X X

PG X X X X

PK X X X X

PL X X X X X X

PR X X X X

PT X X X X

RB X X X X X X

RX X X X X X X

SB X X X

SC X X X X

SES 200 X X X X X X

B-5
Appendix B

Navy Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

SLWT X X X X X X

SS X X X X

SSBN 726 X X X X X X X X X X X X

SSN 637 X X X X X X X X X X X X

SSN 640 X X X X X X X X X X X X

SSN 671 X X X X X X X X X X X X

SSN 688 X X X X X X X X X X X X

ST X X X X

TC X X X X

TD X X X X

TR X X X X X X X

UB X X X X X X

VP X X X X

WB X X X X

WH X X X X

WT X X X X

YC X X X

YCF X X X

YCV X X X

YD X X X

YDT X X X

YFB X N X X X

YFN X X X

YFNB X X X

YFND X X X

B-6
Appendix B

Navy Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

YFNX X X X X X X

YFP X X X X

YFRN X X X X

YFRT X X X X X

YFU 83 X X X X X X

YFU 91 X X X X X X

YGN 80 X X X X X

YL X X X X

YLC X X X X

YM X X X X

YMN X X X

YNG X X X

YO 65 X X X X X X X

YOG 5 X X X X X X X

YOGN X X X X X

YON X X X X

YOS X X X X

YP 654 X X X X X X X

YP 676 X X X X X X X

YPD X X X

YR X X X

YRB X X X

YRBM X X X

YRDH X X X

YRR X X X

B-7
Appendix B

Navy Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

YRST X X X

YSD 11 X X X X X X X

YSR X X X

YTB 752 X X X X X X X

YTB 756 X X X X X X X

YTB 760 X X X X X X X

YTL 422 X X X X X X X

YTM X X X X X

YTT 9 X X X X X X X X

YWN X X X X

B-8
Appendix B

Navy Vessel Discharges Not to be Regulated 

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

AC

AFDB 4 X X

AFDB 8 X X

AFDL 1 X X

AFDM 3 X X

AFDM 14 X X

AGER 2 X X X X

AGF 3 X X X X X X X X

AGF 11 X X X X X X X X

AGOR 21 X X X X X

AGOR 23 X X X X X

AGSS 555 X X X X

AO 177 X X X X X X X

AOE 1 X X X X X X X X

AOE 6 X X X X X X X X

AP X

APL X X X

AR X

ARD 2 X X X

ARDM X X X

ARS 50 X X X X X X X

AS 33 X X X X X X X

AS 39 X X X X X X X

ASDV X

AT X X

B-9
Appendix B

Navy Vessel Discharges Not to be Regulated 

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

ATC X X X

BH

BT

BW

CA

CC

CG 47 X X X X X X X

CGN 36 X X X X X X X

CGN 38 X X X X X X X

CM X

CT

CU X

CV 59 X X X X X X X X

CV 63 X X X X X X X X

CVN 65 X X X X X X X X X

CVN 68 X X X X X X X X X

DB

DD 963 X X X X

DDG 51 X X X X

DDG 993 X X X X

DSRV-1 X

DSV 1 X

DT

DW

FFG 7 X X X X X

B-10
Appendix B

Navy Vessel Discharges Not to be Regulated 

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

HH

HL

HS

IX

IX 35

IX 501 X

IX 308 X

LA

LCAC 1

LCC 19 X X X X X X X

LCM(3) X X

LCM(6) X X

LCM(8) X X

LCPL X

LCU 1610 X X X X

LCVP X

LH

LHA 1 X X X X X X X X

LHD 1 X X X X X X X X

LPD 4 X X X X X X X X

LPD 7 X X X X X X X X

LPD 14 X X X X X X X X

LPH 2 X X X X X X X X

LSD 36 X X X X X X X X

LSD 41 X X X X X X X X

B-11
Appendix B

Navy Vessel Discharges Not to be Regulated 

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

LSD 49 X X X X X X X X

LST 1179 X X X X X X X X

MC

MCM 1 X X X X X X X

MHC 51 X X X X X X X

ML

MM

MW

NM

NS X

PB X X

PBR X X

PC 1 X X X X X

PE

PF

PG

PK

PL X

PR

PT

RB X

RX X

SB

SC

SES 200 X

B-12
Appendix B

Navy Vessel Discharges Not to be Regulated 

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

SLWT X

SS

SSBN 726 X X X X X X X X X

SSN 637 X X X X X X X X X

SSN 640 X X X X X X X X X

SSN 671 X X X X X X X X X

SSN 688 X X X X X X X X X

ST

TC

TD

TR X X

UB X

VP

WB

WH

WT

YC

YCF

YCV

YD

YDT

YFB X X

YFN X X

YFNB

YFND X X

B-13
Appendix B

Navy Vessel Discharges Not to be Regulated 

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

YFNX X X X X

YFP X X

YFRN

YFRT

YFU 83 X

YFU 91 X

YGN 80 X

YL

YLC

YM

YMN

YNG

YO 65 X

YOG 5 X

YOGN

YON

YOS

YP 654 X

YP 676 X

YPD

YR

YRB

YRBM X X

YRDH X X

YRR

B-14
Appendix B

Navy Vessel Discharges Not to be Regulated 

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

YRST

YSD 11 X

YSR

YTB 752 X

YTB 756 X

YTB 760 X

YTL 422 X

YTM

YTT 9 X

YWN

B-15
C-1

Appendix C

Matrix of MSC Vessels and Discharges
Appendix C 

MSC Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

AE 26 X X X X X X X X X X X

AFS 1 X X X X X X X X X X X X

AG 194 X X X X X X X X X X

AGM 22 X X X X X X X X X X X

AGOS 1 X X X X X X X X X X X X

AGOS 19 X X X X X X X X X X X X

AGS 26 X X X X X X X X X X X X X

AGS 45 X X X X X X X X X X X X X

AGS 51 X X X X X X X X X X X X X

AGS 60 X X X X X X X X X X X X X

AH 19 X X X X X X X X X X X X X

AO 187 X X X X X X X X X X X X X

ARC 7 X X X X X X X X X X X

ATF 166 X X X X X X X X X X X X X

C-2
Appendix C

MSC Vessel Discharges Not to be Regulated

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

AE 26 X X X X X X X

AFS 1 X X X X X X X

AG 194 X X X X X X X

AGM 22 X X X X X X X

AGOS 1 X X X X X

AGOS 19 X X X X X

AGS 26 X X X X X X

AGS 45 X X X X X

AGS 51 X X X X X

AGS 60 X X X X X

AH 19 X X X X X X X

AO 187 X X X X X X

ARC 7 X X X X X X X

ATF 166 X X X X X

C-3
D-1

Appendix D

Matrix of Coast Guard Vessels and Discharges
Appendix D

Coast Guard Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

ANB X X X X

ANB(X) X X X X

ATB X X X X

BU X X X X

BUSL X X X X

FR X X X X

LC X X X X

MCB X X X X

MLB X X X X

MSB X X X X

PSB X X X X

PWB X X X X

RHIB X X X X

RHIL X X X X

RHIM X X X X

SKI X X X X

SPC X X X X

SRB X X X X

TANB X X X X

UTB X X X X

UTL X X X X

W/P X X X X

WAGB 290 X X X X X X X X X X X X X X X

WAGB 399 X X X X X X X X X X X X X X X

WHEC 378 X X X X X X X X X X X X X X X

D-2
Appendix D

Coast Guard Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

WIX 295 X X X X X X X X X X X X X X

WLB 180A X X X X X X X X X

WLB 180B X X X X X X X X X

WLB 180C X X X X X X X X X

WLB 225 X X X X X X X X X

WLI 100A X X X X X X X

WLI 100C X X X X X X X

WLI 65303 X X X X X X X

WLI 65400 X X X X X X X

WLIC 100 X X X X X X X

WLIC 160 X X X X X X X

WLIC 75A X X X X X X X

WLIC 75B X X X X X X X

WLIC 75D X X X X X X X

WLM 157 X X X X X X X

WLM 551 X X X X X X X

WLR 115 X X X X X X

WLR 65 X X X X X X

WLR 75 X X X X X X X

WMEC 210A X X X X X X X X X X X X X

WMEC 210B X X X X X X X X X X X X X

WMEC 213 X X X X X X X X X X X X X

WMEC 230 X X X X X X X X X X X X X

D-3
Appendix D

Coast Guard Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

WMEC 270A X X X X X X X X X X X X X

WMEC 270B X X X X X X X X X X X X X

WP X X X X X X

WPB 110A X X X X X X X X

WPB 110B X X X X X X X X

WPB 110C X X X X X X X X

WPB 82C X X X X X X X X

WPB 82D X X X X X X X X

WTGB 140 X X X X X X X

WYTL 65A X X X X X X X

WYTL 65B X X X X X X X

WYTL 65C X X X X X X X

WYTL 65D X X X X X X X

D-4
Appendix D

Coast Guard Vessel Discharges Not to be Regulated

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

ANB

ANB(X)

ATB

BU

BUSL

FR

LC

MCB

MLB

MSB

PSB

PWB

RHIB

RHIL

RHIM

SKI

SPC

SRB

TANB

UTB

UTL

W/P

WAGB 290 X X X X X X

WAGB 399 X X X X X X

D-5
Appendix D

Coast Guard Vessel Discharges Not to be Regulated

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

WHEC 378 X X X X X X

WIX 295 X X X X X

WLB 180A X X X X X

WLB 180B X X X X X

WLB 180C X X X X X

WLB 225 X X X X X

WLI 100A X X X X

WLI 100C X X X X

WLI 65303 X X X X

WLI 65400 X X X X

WLIC 100 X X X X

WLIC 160 X X X X

WLIC 75A X X X X

WLIC 75B X X X X

WLIC 75D X X X X

WLM 157 X X X X

WLM 551 X X X X

WLR 115 X X X X

WLR 65 X X X X

WLR 75 X X X X

WMEC 210A X X X X X X

WMEC 210B X X X X X X

WMEC 213 X X X X X X

WMEC 230 X X X X X X

D-6
Appendix D

Coast Guard Vessel Discharges Not to be Regulated

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

WMEC 270A X X X X X X

WMEC 270B X X X X X X

WP X X X X

WPB 110A X X X X

WPB 110B X X X X

WPB 110C X X X X

WPB 82C X X X X

WPB 82D X X X X

WTGB 140 X X X X

WYTL 65A X X X X

WYTL 65B X X X X

WYTL 65C X X X X

WYTL 65D X X X X

D-7
E-1

Appendix E

Matrix of Army Vessels and Discharges
Appendix E

Army Vessel Discharges to be Regulated 

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

BC X X

BD X X X X X X

BG X X X

BK X X

CF X X X X X

CHI X X X X X

FB X X X X

HF X X X X X

J-BOAT X X X X X

LCM-8 MOD 0 X X X X X

LCM-8 MOD 1 X X X X X

LCU-1600 X X X X X X X

LCU-2000 X X X X X X X X X

LSV X X X X X X X X

LT-100 X X X X X X X

LT-128 X X X X X X X X

PB X X X

Q-BOAT X X X X X

ST-45 X X X X X X X

ST-65 X X X X X X X

SLWT X X X X X

T-BOAT X X X X X

WORKBOATS X

E-2
Appendix E

Army Vessel Discharges Not to be Regulated

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

BC X

BD X X X

BG X

BK X

CF X X

CHI X X

FB X X

HF X X

J-BOAT X X

LCM-8 MOD 0 X X

LCM-8 MOD 1 X X

LCU-1600 X X X

LCU-2000 X X X X X

LSV X X X X

LT-100 X X X X X

LT-128 X X X X X

PB X

Q-BOAT X X

ST-45 X X

ST-65 X X

SLWT X X

T-BOAT X X

WORKBOATS

E-3
F-1

Appendix F

Matrix of Marine Corps Vessels and Discharges
Appendix F

Marine Corps Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-LaunchChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

CRRC X X X

RRC X X X

F-2
Appendix F

Marine Corps Vessel Discharges Not to be Regulated

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSubmarine Emergency Diesel Engine Wet ExhaustSub Outboard Equip. Grease & External Hydraulics

CRRC

RRC

F-3
G-1

Appendix G

Matrix of Air Force Vessels and Discharges
Appendix G

Air Force Vessel Discharges to be Regulated

Ship Class

Aqueous Film Forming FoamCatapult Water-Brake Tank & Post-Launch Retraction ExhaustChain Locker EffluentClean BallastCompensated Fuel BallastCPP Hydraulic FluidDeck RunoffDirty BallastDistillation & Reverse Osmosis BrineElevator Pit EffluentFiremain SystemsGas Turbine Water WashGraywaterHull Coating LeachateMOGAS Compensated Overboard DischargesNon-Oily Machinery WastewaterPhoto Lab DrainsSeawater Cooling Overboard DischargeSeawater Piping Biofouling PreventionSmall Boat Engine Wet ExhaustSonar Dome DischargeSubmarine BilgewaterSurface Vessel Bilgewater/OWS DischargeUnderwater Ship HusbandryWelldeck Discharges

MR X X X X X X X X

P X X X X

TR X X X X

U X X X X

G-2
Appendix G

Air Force Vessel Discharges Not to be Regulated

Ship Class

Boiler BlowdownCatapult Wet Accumulator DischargeCathodic ProtectionFreshwater Lay-upMine Countermeasures Equipment LubricationPortable Damage Control Drain Pump DischargesPortable Damage Control Drain Pump Wet ExhaustRefrigeration/AC CondensateRudder Bearing LubricationSteam CondensateStern Tube Seals & Underwater Bearing LubricationSubmarine Acoustic Countermeasures Launcher DischargeSub Emergency Diesel Engine Wet ExhaustSub Outboard Equipment Grease & External Hydraulics

MR X X X

P

TR

U

G-3