REVISED DRAFT REPORT

Technical Support for EPA Development of a Permitting Framework to 

Address the Vacatur of the NPDES Vessel Exclusion

Prepared for:

Oceans and Coastal Protection Division

U.S. Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, D.C. 20460

Prepared by:

BATTELLE

397 Washington St.

Duxbury, MA 02332

EPA Contract No. 68-C-03-041

Work Assignment No. 4-50

Project No. G921350
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CONTENTS

ACRONYMS AND ABBREVIATIONS.................................................................................................vii

1.0 INTRODUCTION...........................................................................................................................9

1.1 The Clean Water Act.............................................................................................................9

1.2 Northwest Environmental Advocates, et al. v. EPA..............................................................9

1.3 Scope of the Vessel Vacatur................................................................................................10

1.3.1 Exemptions to the Vessel Vacatur ........................................................................................10

2.0 DATA GATHERING AND ANALYSIS.....................................................................................11

2.1 Recreational Vessel Data.....................................................................................................11

2.1.1 National Marine Manufacturers Association (NMMA) 2006 Boating Statistics Report ......11

2.2 Commercial Vessel Data .....................................................................................................11

2.2.1 Merchant Vessels of the United States (VESDOC)..............................................................11

2.2.2 Waterborne Transportation Lines of the United States (WTLUS)........................................12

2.3 Foreign Vessel Data ............................................................................................................12

2.3.1 U.S. Customs Entrances/Clearances Records .......................................................................12

2.4 Port Data..............................................................................................................................12

2.4.1 MARAD Vessel Calls...........................................................................................................12

2.4.2 U.S. Customs Entrances/Clearances Records .......................................................................12

2.4.3 National Ballast Information Clearinghouse.........................................................................12

2.4.4 EPA National Total Maximum Daily Load (TMDL) Database ............................................13

2.4.5 National Estuary Program 2007 Coastal Condition Report ..................................................13

2.5 Discharge Data ....................................................................................................................14

2.5.1 Uniform National Discharge Standards Reports...................................................................14

2.6 Pollution Control Technologies/Best Management Practices Data.....................................15

2.6.1 Uniform National Discharge Standards Reports...................................................................15

2.6.2 Lloyd’s Register Ballast Water Treatment Technology Report............................................15

2.6.3 Miscellaneous Literature, Reports, and Phone Conversations..............................................15

3.0 VESSEL POPULATION STATISTICS .....................................................................................15

3.1 Recreational Vessels............................................................................................................15

3.1.1 Recreational Vessel Numbers...............................................................................................16

3.1.2 Recreational Vessel Propulsion and Size Data......................................................................17

3.2 Commercial Vessels............................................................................................................19

3.2.1 Domestic Commercial Vessel Numbers and Types..............................................................19

3.2.2 Domestic Commercial Fishing Vessel Numbers...................................................................24

3.2.3 Foreign Commercial Vessel Numbers ..................................................................................26

4.0 PORT FINDINGS.........................................................................................................................27

4.1 Calls to U.S. Ports ...............................................................................................................27

4.2 Receiving Water Characteristics .........................................................................................33

4.2.1 Houston, Texas .....................................................................................................................33

4.2.2 New York City, NY ..............................................................................................................34

4.2.3 Port Everglades, Florida........................................................................................................34

4.2.4 Miami, Florida ......................................................................................................................34

4.2.5 Los Angeles/Long Beach, CA...............................................................................................34

4.2.6 San Juan, Puerto Rico ...........................................................................................................35

4.2.7 Savannah, GA .......................................................................................................................35

4.2.8 St. Thomas, Virgin Islands....................................................................................................35

4.2.9 Seattle, WA...........................................................................................................................35

4.2.10 New Orleans, LA ..................................................................................................................36
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4.2.11 Charleston, SC ......................................................................................................................36

4.2.12 Baltimore, MD ......................................................................................................................36

4.2.13 Elizabeth River, VA..............................................................................................................36

4.2.14 Oakland, CA .........................................................................................................................36

4.2.15 Bayou Lafourche, LA ...........................................................................................................37

4.2.16 Galveston, TX.......................................................................................................................37

4.2.17 Tacoma, WA.........................................................................................................................37

4.2.18 Jacksonville, FL ....................................................................................................................38

4.2.19 South Louisiana, LA .............................................................................................................38

5.0 DISCHARGE FINDINGS............................................................................................................38

5.1 Discharges Incidental to the Normal Operation of a Vessel................................................38

5.1.1 Aqueous Film Forming Foam (AFFF)..................................................................................41

5.1.2 Boiler Blowdown ..................................................................................................................42

5.1.3 Cathodic Protection...............................................................................................................43

5.1.4 Chain Locker Effluent...........................................................................................................44

5.1.5 Clean Ballast .........................................................................................................................45

5.1.6 Compensated Fuel Ballast.....................................................................................................46

5.1.7 Controllable Pitch Propeller Hydraulic Fluid........................................................................47

5.1.8 Deck Runoff..........................................................................................................................48

5.1.9 Dirty Ballast..........................................................................................................................49

5.1.10 Distillation and Reverse Osmosis Brine................................................................................49

5.1.11 Elevator Pit Effluent..............................................................................................................50

5.1.12 Firemain Systems..................................................................................................................51

5.1.13 Freshwater Layup..................................................................................................................52

5.1.14 Gas Turbine Water Wash......................................................................................................53

5.1.15 Grey Water............................................................................................................................53

5.1.16 Hull Coating Leachate ..........................................................................................................55

5.1.17 Motor Gasoline Compensating Discharge ............................................................................56

5.1.18 Non-Oily Machinery Wastewater .........................................................................................56

5.1.19 Photographic Laboratory Drains...........................................................................................57

5.1.20 Refrigeration/Air Conditioning Condensate Discharge ........................................................58

5.1.21 Rudder Bearing Lubrication Discharge.................................................................................58

5.1.22 Seawater Cooling Overboard Discharge ...............................................................................59

5.1.23 Seawater Piping Biofouling Prevention ................................................................................60

5.1.24 Small Boat Engine Wet Exhaust...........................................................................................60

5.1.25 Sonar Dome Discharge .........................................................................................................61

5.1.26 Steam Condensate .................................................................................................................62

5.1.27 Stern Tube Seals and Underwater Bearing Lubrication ........................................................62

5.1.28 Submarine Bilge Water.........................................................................................................63

5.1.29 Surface Vessel Bilge Water/Oil-Water Separator (OWS) Discharge ...................................64

5.1.30 Underwater Ship Husbandry.................................................................................................64

5.1.31 Welldeck Discharges.............................................................................................................66

6.0 Pollution Control Technologies and Best Management Practices............................................66

6.1 Aqueous Film Forming Foam .............................................................................................66

6.2 Chain Locker Effluent.........................................................................................................66

6.3 Clean Ballast........................................................................................................................67

6.4 Compensated Fuel Ballast ...................................................................................................70

6.5 Controllable Pitch Propeller Hydraulic Fluid......................................................................70

6.6 Deck Runoff ........................................................................................................................71

6.7 Dirty Ballast ........................................................................................................................71

6.8 Distillation and Reverse Osmosis Brine..............................................................................71

6.9 Elevator Pit Effluent............................................................................................................72
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6.10 Firemain Systems................................................................................................................72

6.11 Freshwater Layup ................................................................................................................72

6.12 Gas Turbine Water Wash ....................................................................................................72

6.13 Grey Water ..........................................................................................................................72

6.14 Hull Coating Leachate.........................................................................................................74

6.15 Motor Gasoline Compensating Discharge...........................................................................75

6.16 Photographic Laboratory Drains .........................................................................................76

6.17 Small Boat Engine Wet Exhaust .........................................................................................76

6.18 Sonar Dome Discharge........................................................................................................76

6.19 Surface Vessel Bilge Water/Oil-Water Separator Discharge ..............................................76

6.20 Underwater Ship Husbandry ...............................................................................................78

7.0 Laws, Regulations, and Conventions...........................................................................................81

7.1 International and National Laws and Regulations...............................................................81

7.1.1 International Standards .........................................................................................................81

7.1.2 National Law.........................................................................................................................81

7.1.3 State Law ..............................................................................................................................82

8.0 CONCLUSIONS ...........................................................................................................................83

9.0 REFERENCES.............................................................................................................................. 84

LIST OF TABLES

Table 3-1. Top 20 U.S. States for Total Registered Recreational Vessels, with General Type of Vessel 

Indicated..................................................................................................................................17

Table 3-2. Type of Propulsion for All Registered Mechanically-Propelled Recreational Vessels............18

Table 3-3. Lengths of All Registered Mechanically-Propelled Recreational Vessels. ..............................18

Table 3-4. Summary of the U.S.-Flag Cargo or Passenger Vessels Operating in U.S. Waters by Region.

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

Table 3-5. Top Twenty U.S. TSO Companies Operating Cargo or Passenger Vessels in U.S. Waters by 

Number of Vessels Operated...................................................................................................22

Table 3-6. Total Number of U.S. Documented Vessels by Service Type...................................................23

Table 3-7. Top 20 Most Frequently Recorded Flags Entering U.S. Ports or Waterways in 2005..............26

Table 4-1. 2005 Vessel Calls at All U.S. Coastal Ports Organized by Geographic Region ......................28

Table 4-2. Top 20 U.S. Ports by Number of Vessel Calls in 2005. ............................................................31

Table 4-3. 2005 Domestic and Foreign Vessel Calls at Top 20 U.S. Ports. ...............................................32

Table 5-1. Phase I UNDS Armed Forces Vessel Discharges Requiring an MPCD...................................39

Table 6-1. Characteristics of Example Ballast Water Treatment Systems .................................................68

Table 6-2. Ballast Water Treatment System Standards. .............................................................................70

Table 6-3. Grey Water Treatment Technology Costs.................................................................................74

Table 6-4. Bilge Water Treatment Technology Costs ................................................................................78

Table 6-5. Global BMPs for Preventing Vessel Hulls from being Invasive Species Vectors. ..................79

Table 7-1. Current or Pending State Permitting Systems Pertaining to Vessel Discharges Covered in this 

Report......................................................................................................................................82

Table 8-1. Summary of Statistical Findings for Vessels and Ports............................................................83
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LIST OF FIGURES

Figure 3-1. 2006 U.S. Regional Recreational Vessel Registration.............................................................16

Figure 3-2. Summary of U.S. Flag Cargo and Passenger Vessels Operating in U.S. Waters by Region. ..21

Figure 3-3. Documented Commercial Fishing Vessels by Owner’s Contact State. ..................................25

Figure 4-1. 2005 Vessel Calls to U.S. Coastal Ports by Geographic Region..............................................27

Figure 6-1. Types of Processes Utilized by Ballast Water Treatment Technologies..................................68

Figure 6-2. Grey Water Treatment System.................................................................................................73

LIST OF ATTACHMENTS

ATTACHMENT A: Table 1–State-by-state Recreational Vessel Registration Information
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ACRONYMS AND ABBREVIATIONS

AFFF aqueous film-forming foam

ANPRM advanced notice of proposed rulemaking

APPS Act to Prevent Pollution from Ships

AWO American Waterways Operators

BMP best management practice

CBP U.S. Customs and Border Protection

CERCLA Comprehensive Environmental Response and Community Right-to-Know Act

CFR Code of Federal Regulations

CLIA Cruise Lines International Association

CMC Crowley Maritime Corporation

CPO chlorine-produced oxidant

CPP controllable pitch propeller

CSLC California State Lands Commission

CWA Clean Water Act

DA Discharge Assessment

DB deck barge

DCB dry cargo barge

DDT dichloro-diphenyl-trichloroethane

DEC Department of Environmental Conservation (Alaska)

DHTB double-hull tanker barge

DIN dissolved inorganic nitrogen

DIP dissolved inorganic phosphorus

DO dissolved oxygen

DOB dry open barge

DoD Department of Defense

EEZ exclusive economic zone

EPA United States Environmental Protection Agency

gph gallons per hour

gpm gallons per minute

HEM hexane extractable material

HEP Harbor Estuary Program (New York/New Jersey)

IMO International Maritime Organization

LMC Liberty Maritime Corporation

LSB lash/seabee barge

MARAD Maritime Administration

MARPOL 73/78 International Convention for the Prevention of Pollution from Ships, 

1973, as modified by the Protocol of 1978 relating thereto
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MOGAS motor gasoline

MPCD marine pollution control device

NAISA National Aquatic Invasive Species Act

NAS National Academy of Sciences

NBIC National Ballast Information Clearinghouse

NDC Navigation Data Center

NEA Northwest Environmental Advocates

NEP National Estuary Program

NISA National Invasive Species Act

nmi nautical mile

NMMA National Marine Manufacturers Association

NOD Nature of Discharge

NPDES National Pollutant Discharge Elimination System

NVDC National Vessel Documentation Center

OPA Oil Pollution Act

OTB other tank barge

OWS oil/water separator

PAHs polycyclic aromatic hydrocarbons

PCBs polychlorinated biphenyls

PCT pollution control technology

PSPA Pacific Seafood Processors Association

RO reverse osmosis

SBT segregated ballast tanks

SERC Smithsonian Environmental Research Center

TBT tributyltins

TMDL total maximum daily load

TMP topside management plan

TOC total organic carbon

TPH total petroleum hydrocarbons

TSO Transportation Series Operator

UNDS Uniform National Discharge Standards

USACE United States Army Corps of Engineers

USCG United States Coast Guard

USDA United States Department of Agriculture

USHMP underwater ship husbandry management plan

UV ultraviolet

VESDOC Merchant Vessels of the United States

WCSC Waterborne Commerce Statistics Center

WSC World Shipping Council

WTLUS Waterborne Transportation Lines of the United States
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1.0 INTRODUCTION

1.1 The Clean Water Act 

Originally enacted in 1972, the Clean Water Act (CWA) is the primary federal law governing water 

pollution in the United States (U.S.). Among other authorities, it allows the U.S. Environmental 

Protection Agency (EPA) to regulate discharges to the nation’s waterways through the National Pollutant 

Discharge Elimination System (NPDES). The NPDES program “requires permits for the discharge of 

pollutants from any point source into the waters of the United States” (40 CFR 122.1(b)), with the 

definition of point source including, among other things, “vessel or other floating craft” (40 CFR 122.2). 

The term pollutant includes the following list of potential contaminants:

dredged spoil, solid waste, incinerator residue, filter backwash, sewage, garbage, 

sewage sludge, munitions, chemical wastes, biological materials, radioactive 

materials..., heat, wrecked or discarded equipment, rock, sand, cellar dirt and 

industrial, municipal, and agricultural waste. (40 CFR 122.2)

However, section 122.3(a) of the CWA regulations (40 CFR 122.3(a)) exempts some vessel discharges 

from requiring a NPDES permit, stating:

The following discharges do not require NPDES permits:

(a) Any discharge of sewage from vessels, effluent from properly functioning marine 

engines, laundry, shower, and galley sink wastes, or any other discharge incidental to 

the normal operation of a vessel. (40 CFR 122.3(a))

Although the CWA regulations do not specifically define “discharges incidental to the normal operation 

of a vessel”, this term is broadly described in “Phase I: Uniform National Discharge Standards (UNDS) 

for Vessels of the Armed Forces”, a 1999 technical document developed by the EPA and the Department 

of Defense (DoD) under Section 312 of the CWA. This UNDS document further breaks down incidental 

discharges of Armed Forces vessels to 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” (EPA, 1999a). During the development of the UNDS document, the authors consulted with 

Armed Forces technical experts and developed a list of 39 different discharges considered to be incidental 

to the normal operation of an Armed Forces vessel. While some of these 39 incidental discharges would

not apply to civilian vessels (e.g., catapult wet accumulator discharge, which can be found on aircraft 

carriers), and some of the standards set for others would not apply to civilian vessels, some of the studies 

developed for the UNDS rule may be instructive for this effort. Discharge reports were also developed for 

each of the discharges, with some of the more critical ones receiving a more in-depth examination

(Section 2.5.1). 

1.2 Northwest Environmental Advocates, et al. v. EPA 

In January 1999, several environmental groups, including Northwest Environmental Advocates (NEA) 

(hereafter referred to as NEA et al.), collectively petitioned the EPA to repeal 40 CFR 122.3(a) (hereafter

referred to as the ‘vessel exclusion clause’). As explained in their petition, the primary concern of NEA 

et al. was for the discharge of ballast water and any potentially invasive or harmful organisms contained 

therein from vessels into United States waters. Referring to the CWA definition of pollutant (40 CFR 

122.2) and the inclusion of ‘biological materials’ in that definition, NEA et al. stated that the vessel 

exclusion clause was illegal because it ran counter to the CWA and case law (e.g., Natural Resources 
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Defense Council v. Costle (1977)). The petition asked that the EPA repeal this exclusion “to help prevent 

the further degradation of aquatic resources from” invasive species (Johnston, 1999).

EPA denied the petition in September 2003, stating that other federal statutes (e.g., the Act to Prevent 

Pollution from Ships [APPS], the National Invasive Species Act [NISA]) and federal-sponsored activities 

(e.g., workshops, research and development funding, and participation in the International Maritime 

Organization’s (IMO) invasive species control efforts) are sufficient to address the invasive species issue 

in U.S. waters. 

In response to the petition denial, NEA et al. filed a lawsuit (C 03-05760 SI) in the U.S. District Court for 

the Northern District of California in December 2003 seeking to compel the EPA to repeal the vessel 

exclusion clause. While the court found for the plaintiffs (NEA et al.) in March 2005 and ordered the 

EPA to repeal 40 CFR 122.3(a), the EPA returned to the court to request that the repeal apply solely to 

ballast water and not to all “discharges incidental to the normal operation of a vessel”. This request was 

denied in a September 2006 injunction in which the court directed the EPA to vacate “the blanket 

exemption for discharges incidental to the normal operation of a vessel, contained in 40 CFR 122.3(a)” by 

September 30, 2008 (NEA et al. v. EPA, 2006). Hereafter, the vacating of the vessel exclusion clause 

shall be referred to as the ‘vessel vacatur’.

1.3 Scope of the Vessel Vacatur

As a result of the court-ordered vessel vacatur, the EPA must develop a feasible permitting system that 

will cover millions of formerly-exempt vessel discharges under the NPDES program. This permitting 

system must be conceived, developed, and implemented by September 30, 2008 or the EPA risks legal 

challenges. Prior to determining the type and manner of permitting system to implement, EPA must fully 

understand the scope of the issue, including the number and types of vessels that must be covered and the 

nature and type of discharges incidental to their normal operation. In addition, the EPA will need 

information on U.S. ports and waterways, current national and international regulations that apply to 

vessel discharges, and the current state of shipboard and land-based pollution control technologies (PCTs) 

and best management practices (BMPs).

1.3.1 Exemptions to the Vessel Vacatur

Under the pending NPDES permitting framework for the vessel vacatur, some discharges incidental to the 

normal operation of a vessel will not be affected due to their coverage or exemption under other federal 

regulations. As stated in the court’s injunction (NEA et al. v. EPA, 2006), NEA et al. sought to only 

vacate the first sentence of 40 CFR 122.3(a). The manner in which the following discharge types are 

regulated will not be affected by the vessel vacatur.

· In CWA §312(a)(12)(B)(i), the discharge of rubbish, trash, and garbage is specifically excluded 

as being ‘incidental to the normal operation of a vessel’. Rubbish, trash, and garbage discharge is 

regulated under APPS, which is the U.S. implementation of the International Convention for the 

Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto 

(MARPOL 73/78).

· Discharges originating from a vessel when it is operating in a capacity other than a means of 

transportation, as specifically exempted in the second sentence of 40 CFR 122.3(a), which is not 

being vacated. 

· Discharges from a vessel or other floating craft outside the U.S. three mile territorial sea limit do 

not constitute “the discharge of a pollutant” under CWA §502(12)(A) and thus are not subject to 

NPDES permitting.
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· Sewage discharge from a vessel is specifically excluded from CWA’s definition of pollutant

(CWA §502(6)(A)) and thus is not subject to NPDES permitting.

· Discharges incidental to the normal operation of a vessel of the U.S. Armed Forces are excluded 

from NPDES permitting requirements under the CWA’s definition of pollutant (CWA 

§502(6)(A)) and thus are not subject to NPDES permitting.

This report summarizes the findings of a search of available literature and databases and aims to provide 

EPA with the scope of existing conditions (as available) in four major categories: vessels, ports, 

discharges, and PCTs/BMPs. Because the field of information is constantly developing, particularly with 

regards to treatment technologies, and data on vessels and ports are updated at least annually, this report 

will be a living document to be added to and amended based on the state of the most current knowledge.

2.0 DATA GATHERING AND ANALYSIS

2.1 Recreational Vessel Data

2.1.1 National Marine Manufacturers Association (NMMA) 2006 Boating Statistics 

Report

Data on recreational vessels operating in U.S. waters were obtained primarily from the 2006 National 

Marine Manufacturers Association’s (NMMA) Recreational Boat Registration Statistics report (NMMA, 

2007) which compiles data from the registration agencies in each state and territory, among other sources. 

At the time of publication of this document, the 2006 version of the NMMA report was the latest 

available. However, the overall state-by-state vessel registration numbers had not been re-compiled for 

the 2006 version of the report; therefore, while the report contains some data that are updated for 2006, 

much of the data with which this report is concerned were from 2005.

2.2 Commercial Vessel Data

2.2.1 Merchant Vessels of the United States (VESDOC)

Vessel data were obtained from the United States Coast Guard (USCG) in the form of the Merchant 

Vessels of the United States (VESDOC) data file, which contained updated data through May 5, 2007

(USCG, 2007a). These data were sent from the USCG’s National Vessel Documentation Center (NVDC)

on CD-ROM to Battelle on May 14, 2007. The CD-ROM contained data in both tab-delimited and fixedlength formats as well as a metadata document. There were a total of 328,234 records in the file. These 

data were loaded into a table within the Battelle database on May 23, 2007.

VESDOC contains information on domestic merchant and recreational vessels with a valid Certificate of 

Documentation, which is a form of registration used to track U.S.-owned vessels involved in certain trade 

activities. Any vessel involved in fishing activities, passenger/merchandise transportation, towing, or 

dredging within U.S. navigable waters or the Exclusive Economic Zone (EEZ) and that measures five net 

tons or greater must be documented. A Certificate of Documentation can allow a vessel to be ‘endorsed’ 

for a specific trade, such as fishing or recreation, although a vessel that is only documented for recreation 

cannot be used for any other purpose. Some states do not require a documented recreational vessel to also 

register with the relevant state agency, a fact that has implications for the statistics gathered from the 

NMMA report (Section 2.1.1)

VESDOC data presented some difficulties when database queries were developed. For example, the 

VESDOC field ‘hailing port’ provides the state and/or city displayed on the vessel stern and is a good 

indicator of the vessel’s geographic area of operation. However, the data entered for this field varied 

from city only to state only to a city/state combination and the syntax used was inconsistent (e.g., commas 
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were not always used to separate city from state, some state abbreviations had periods, etc.). These 

variations in data entry style made some of the VESDOC querying difficult because the field could not 

efficiently be parsed out. 

2.2.2 Waterborne Transportation Lines of the United States (WTLUS)

The Waterborne Transportation Lines of the United States (WTLUS) is an annual three-volume product 

provided by the U.S. Army Corps of Engineers’ (USACE) Navigation Data Center’s (NDC) Waterborne 

Commerce Statistics Center (WCSC) (USACE 2005a, 2005b, 2005c). At the time of publication, the 

2005 version of WTLUS was the latest available. Battelle downloaded 2005 WTLUS data in Microsoft 

Excel format directly from the NDC website1on April 25, 2007. These data were loaded into a table in 

the Battelle database. 

WTLUS contains summary information on vessel companies and their U.S.-flagged vessels available for 

operation as of December 31, 2005 (for vessels capable of carrying passengers or freight, the information 

is updated through August 1, 2006). The three volumes contain summary statistics, characteristics of the 

vessels available (e.g., net tonnage, length, type, year built, etc.), and information on the companies that 

own the vessels (e.g., contact information, number of vessels owned by the company, etc.). 

2.3 Foreign Vessel Data

2.3.1 U.S. Customs Entrances/Clearances Records

Data on the comings and goings (entrances and clearances) of vessels at U.S. ports were collected by U.S. 

Customs and Border Protection (CBP). The CBP gathers these data during the normal processing of 

imports and exports. Available information included the vessel name, the U.S. port that it was 

entering/clearing, the type of vessel, the vessel’s flag of registry, and the last port (domestic or foreign) 

that the vessel had visited. The CBP entrances and clearances data were used as an indicator of the 

numbers and types of non-U.S. flag vessels coming to U.S. ports. Therefore, only the data on entrances 

have been described in this report. Battelle downloaded the most recently available (2005) entrances data 

from USACE’s NDC website on May 10, 2007. 

2.4 Port Data

2.4.1 MARAD Vessel Calls

The U.S. Maritime Administration (MARAD) collects annual data on calls by oceangoing vessels of 

10,000 deadweight tons or greater at U.S. coastal ports. These data are published in a report entitled 

Vessel Calls at U.S. Ports (the most recently available report contained 2005 data [MARAD, 2006a]) as 

well as in Excel spreadsheets. Battelle downloaded the most recently available (2005) data from the 

MARAD website2as an Excel spreadsheet on April 18, 2007. The MARAD data downloaded by Battelle 

contained information on the number of vessel calls at U.S. coastal ports, separated by vessel type. 

2.4.2 U.S. Customs Entrances/Clearances Records

See Section 2.3.1.

2.4.3 National Ballast Information Clearinghouse

The Smithsonian Environmental Research Center (SERC) and the USCG maintain the National Ballast 

Information Clearinghouse (NBIC), which maintains a database of the ballast water management 

1

http://www.ndc.iwr.usace.army.mil/data/datavess.htm

2

http://www.marad.dot.gov/MARAD_statistics/index.html
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practices and activities of commercial ships operating in U.S. waters and seeks to keep track of the 

amount and origins of discharged ballast water. This database (NBIC, 2004) stores information from 

ballast water reports, which must be submitted to the USCG by all ballast tank-equipped vessels entering 

U.S. waters, as required under the National Aquatic Invasive Species Act (NAISA) (33 CFR 151.2045). 

The information provided by the NBIC database includes state, port, vessel name, arrival date, the last 

port/country the vessel called at, vessel type, and data on the ballast water management (e.g., volume 

discharged [if any] and treatment method). The NBIC currently has data available from 1999 through 

2004, although in this report, only the most recent year of data were provided. 

Similar to the problems encountered with the VESDOC data, the NBIC database proved to be difficult to 

work with. The NBIC website allows users to download data by text file, which can then be exported into 

Excel. However, when the data were imported into Excel, the fields were not consistent and the rows did 

not necessarily line up with the correct column headers. For example, a column that was supposed to 

contain locations may have contained some dates because the rows had been shifted or were misaligned. 

These errors were inherent in the text files and were not caused by incorrect importing. Additional 

problems were encountered when the data were downloaded in XML format: the arrival dates for the 

vessels were not included in the output and, therefore, could not be imported into Excel (despite the fact 

that the arrival dates were included in the text file and HTML output types, which were unusable in their 

own right). Some of the states with the busiest ports (i.e., the most amount of available data) contained 

unallowable characters somewhere embedded in their files, preventing the files from being imported into 

Excel at all. After several attempts were made to correct the data output through NBIC, Battelle 

determined that, given these errors in the data and the inability to correct them in a timely manner, the 

data available through NBIC were unusable for the stated purposes.

2.4.4 EPA National Total Maximum Daily Load (TMDL) Database

To describe the current conditions of the major U.S. ports, information on pollutants that exceed water 

quality standards was gathered from EPA’s collection of water bodies listed under §303(d) of the CWA

(EPA, 2007a)3. Based on sampling activities, water bodies that do not meet state water quality standards 

for particular pollutants are placed on a list mandated by CWA §303(d). The water bodies placed on this 

list must have an evaluative report created for them, in which the pollutant sources are assessed and future 

loading rates for the listed pollutant(s) are set. Current CWA §303(d) lists were available from the EPA 

National TMDL database, which contains information on what pollutants were exceeding state water 

quality standards in each port, at the time of the most recent assessment (typically 2002 or 2004).

2.4.5 National Estuary Program 2007 Coastal Condition Report

The National Estuary Program’s (NEP) Coastal Condition report (EPA, 2007b)4evaluates the 28 NEPs 

based on water quality, sediment quality, benthic condition, and fish tissue contamination. Five 

parameters are measured as indicators of overall water quality of an NEP: dissolved inorganic nitrogen

(DIN), dissolved inorganic phosphorus (DIP), chlorophyll a, water clarity, and dissolved oxygen (DO). 

For each water quality indicator, EPA has assigned a range of values that, depending on the sampling 

data, allows the water quality station in question to be rated as ‘good’, fair’, or ‘poor’. For example, if 

DO concentrations are measured as >5 mg/L, then the station is rated as having ‘good’ DO levels. If the 

measured concentrations are 2-5 mg/L or <2 mg/L, the station DO level is rated as ‘fair’ or ‘poor’, 

respectively. Once a station’s condition has been assessed for each of the five indicators, the station’s 

health as a whole can be rated as ‘good’, ‘fair’, or ‘poor’, depending on the combination of indicator 

ratings. Finally, once several stations in an estuary have been evaluated in this manner, the estuary itself 

can be rated for overall water quality using the same scale. Because the NEP water bodies listed below 

3

http://www.epa.gov/owow/tmdl/index.html

4

http://www.epa.gov/owow/oceans/nepccr/index.html
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are described based on their overall estuarine rating, the following guide can help put the estuarine 

conditions in context. 

Good: Less than 10% of the NEP estuarine area is in poor condition, and more than 50% of the 

NEP estuarine area is in good condition.

Fair: 10% to 20% of the NEP estuarine area is in poor condition, or more than 50% of the NEP 

estuarine area is in combined poor and fair condition.

Poor: More than 20% of the NEP estuarine area is in poor condition.

The same fundamental rating methodologies apply to the sediment quality, benthic condition, and fish 

tissue contamination indices. 

2.5 Discharge Data

2.5.1 Uniform National Discharge Standards Reports

The vast majority of information on discharges originating from vessels came from the UNDS reports. A 

few other sources were helpful, but the UNDS reports are the greatest single source of information on 

vessel discharges. Although these reports focus on Armed Forces vessels, some of the discharge studies 

may be instructive for the evaluation of discharges from civilian vessels. 

The team of federal agencies that is tasked with setting UNDS includes EPA and the DoD. Their 

activities are grouped into phases, with Phase I consisting of “determining for which Armed Forces vessel 

discharges it is reasonable and practicable to require control with a marine pollution control device 

(MPCD)” (EPA, 1999a). Phase II includes setting performance standards for any MPCD that would be 

required based on Phase I determinations. Finally, Phase III consists of setting requirements for the 

designing, constructing, installing, and operating the MPCDs identified in Phase II. 

One of the results of Phase I was a technical development document entitled “Phase I Uniform National 

Discharge Standards for Vessels of the Armed Forces” (EPA, 1999a) which included as appendices 

separate “Nature of Discharge” (NOD) reports for each of the 39 discharges incidental to the normal 

operation of an Armed Forces vessel identified during Phase I. Each NOD report included a description 

of the discharge and discussion on the discharge characteristics (e.g., constituents, rates, concentrations, 

etc.), as applicable to vessels of the Armed Forces. Some of the information presented in the NOD 

reports was gathered from primary research, while some of it was taken from existing literature, expert 

opinion, and expert workshop results. During Phase I, EPA and DoD determined that 14 of the 39 

discharges would not require a MPCD when discharged from an Armed Forces vessel and, therefore, 

would not be examined in more detail beyond the NOD report. Therefore, only 25 discharges were

chosen to undergo more extensive assessment for UNDS purposes.

For Phase II, EPA and DoD split up the 25 remaining discharges into batches and developed “Discharge 

Assessment” (DA) reports for the first batch of seven. For four of the seven discharges, EPA and DoD 

also developed reports on the environmental effects, feasibility impact analysis, and a characterization 

analysis. Therefore, each of the 39 discharges has a NOD report, seven of them have a DA report, and 

four of them currently have more in-depth analytical studies. Phase II is currently ongoing and more 

reports from EPA and DoD are expected in the future.
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2.6 Pollution Control Technologies/Best Management Practices Data

2.6.1 Uniform National Discharge Standards Reports 

While the UNDS NOD reports primarily cover the discharge characteristics and constituents, the DA 

reports focus partially on some of the PCTs or BMPs that were investigated by EPA and DoD for their 

feasibility in treating discharges from Armed Forces vessels. Although the DA reports are slightly dated

(which matters more for technological advances than it does for the discharge characteristics discussed in 

the NOD reports), many of the fundamental technologies and management practices are still applicable 

today. The DA reports were primarily used for PCT and BMP information on chain locker effluent, deck 

runoff, elevator pit effluent, firemain systems, and small boat engine wet exhaust. In addition, the Phase I 

report (EPA, 1999a) included short separate MPCD reports for four of the discharges: distillation and 

reverse osmosis brine, hull coating leachate, small boat engine wet exhaust, and underwater ship 

husbandry. These four MPCD reports contained more detailed cost-benefit/feasibility analyses than the 

DA reports and the results are described in the appropriate sections of this report.

2.6.2 Lloyd’s Register Ballast Water Treatment Technology Report

In June 2007, a report was published by Lloyd’s Register that summarized the current status of ballast 

water treatment technology. This document was very useful for identifying the technologies that are 

currently available or soon to be approved as well as the costs of the technologies. 

2.6.3 Miscellaneous Literature, Reports, and Phone Conversations

Much of what was learned about current PCTs and BMPs for operational vessel discharges was gained 

through contacting equipment manufacturers, conducting literature searches, and searching the endless 

available information found on the internet. For example, California Sea Grant and California State 

Lands Commission had a wealth of information on vessel hulls as vectors for invasive species 

introductions that helped to inform the sections on hull coating leachate and underwater ship husbandry.

Contacts were made with numerous representatives of various PCTs, especially bilge water and grey 

water, which helped to establish the estimated costs for some technologies. Finally, state government 

websites provided information on BMPs for some of the more common discharges that may be found in a 

marina.

3.0 VESSEL POPULATION STATISTICS

To help EPA fully comprehend the universe of vessels that may need to be covered by the NPDES 

permitting program (Section 1.3), Battelle has compiled the most recently available data on the vessel 

population that operates in U.S. waters. The following sections present current data on recreational 

vessels (Section 3.1) and commercial vessels (Section 3.2), and includes (to the extent that the 

information was available) data on numbers and types of vessels. Section 2.0 describes the data sources 

consulted for this section. 

3.1 Recreational Vessels

Battelle assumed that the vast majority of recreational vessels using U.S. waters are registered in one of 

the fifty United States or in one of the U.S. territories. Some recreational traffic may come to U.S. waters 

from Mexico or Canada, but, of the total population, these numbers are expected to be minimal. 

Each of the states has different registration requirements for recreational vessels (see Table A-1 in the 

attachments), so the numbers provided in the NMMA report may not accurately represent the entire 

picture of recreational vessels in any given state. NMMA’s report (NMMA, 2007) provides total and 

state-by-state numbers, in addition to information on vessel type and size. However, as indicated in 

Section 2.2.1, in some states recreational vessels that are documented in VESDOC are not required to 
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register with the relevant state agency. The NMMA report (NMMA, 2007) identifies those states that do 

not require the registration of documented vessels and provides the numbers of documented vessels in 

those states at the time of publication. Those states are noted with an asterisk in Tables 3-1 and A-1 and 

the state totals in Table 3-1 include both registered and documented recreational vessels.

Specific ownership information for recreational vessels as well as data on the port or harbor in which a 

recreational vessel is primarily used are not available through NMMA. However, Table A-1 includes the 

most current contact information for the registration agency in each state. These states can be contacted 

individually for answers to specific questions.

3.1.1 Recreational Vessel Numbers

According to NMMA’s 2006 data (NMMA, 2007), the U.S. population of registered recreational vessels 

numbers 12,942,414. Figure 3-1 illustrates the NMMA’s 2006 data on recreational vessel registration 

separated by U.S. region. Although it only encompasses five states, the Great Lakes region boasts the 

greatest number of registered recreational vessels, almost 44% more vessels than the next highest region, 

Inland. 

3,444,761

1,396,358

2,398,894

854,691

1,224,050

2,071,618

68,422

1,483,620

Great Lakes Gulf Coast

Inland Mid Atlantic

North Atlantic Pacific

South Atlantic U.S.Territories

Great Lakes: IL, IN, MI, OH, and WI

Gulf Coast: AL, LA, MS, and TX

Inland: IA, KS, MS, NE, ND, SD, AR, OK, AZ, CO, ID, MT, NV, 

NM, UT, WY, VT, WV, KY, and TN

Mid Atlantic: DE, DC, MD, PA, and VA

North Atlantic: CT, ME, MA, NH, RI, NJ, and NY

Pacific: AK, CA, HI, OR, and WA

South Atlantic: FL, GA, NC, and SC

U.S. Territories: PR, VI, GU, Northern Mariana Islands

Figure 3-1. 2006 U.S. Regional Recreational Vessel Registration.

Source: NMMA, 2007.

On a state-by-state basis, California had the greatest number of registered recreational vessels in 2005, 

with Florida and Michigan rounding out the top three. Table 3-1 lists the top twenty states for numbers of 

registered recreational vessels and also indicates that the vast majority of registered vessels in the top 

twenty states were mechanically-propelled. However, as shown in Table A-1, not all states require nonmechanically propelled vessels to be registered, and in those states that do require such registration, some 

vessel owners either may not be aware of the requirement or may ignore it. Because the registration of 

mechanically-propelled vessels is likely
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Table 3-1. Top 20 U.S. States for Total Registered Recreational Vessels, with General Type of 

Vessel Indicated.

State

Total Registered 

Recreational 

Vessels

MechanicallyPropelledaNon-MechanicallyPropelledb

California* 989,021 892,722 71,036

Florida 973,859 932,673 41,186

Michigan 944,138 891,937 52,201

Minnesota* 856,411 640,862 212,627

Wisconsin 639,198 635,862 3,336

Texas* 623,868 604,929 9,687

New York 508,536 499,136 9,400

South Carolina* 419,841 393,341 23,422

Ohio 412,375 325,632 86,743

Illinois 380,865 308,875 71,990

North Carolina 362,784 357,253 5,531

Pennsylvania* 355,300 308,851 40,308

Missouri 326,749 277,433 49,316

Georgia 318,212 317,315 897

Louisiana* 310,772 308,104 0

Washington 267,793 267,793 0

Tennessee 267,567 265,966 1,601

Alabama 265,172 262,295 2,877

Virginia* 255,948 240,097 4,976

Iowa 243,924 115,044 128,880

Total 9,722,333 8,846,120 816,014

Source: NMMA, 2007.

* Indicates those states that do not require a documented recreational vessel to be registered with the state. Totals 

for these states include both registered and documented recreational vessel numbers. Information on propulsion 

type is for registered vessels only; no data on propulsion type for recreational documented vessels were

available.

a Mechanically-propelled includes power inboard, power outboard, power sterndrive (or inboard/ 

outboard), personal watercraft (PWC), auxiliary sail inboard, and auxiliary sail outboard.

b Non-mechanically propelled includes rowboats, sailboats, kayaks/canoes, and other.

to be more strictly enforced and monitored (by the state agencies and entities charged with enforcing 

vessel registration) than the registration of non-mechanically-propelled vessels, it is assumed that the 

NMMA numbers fully or nearly fully capture the national population of recreational mechanicallypropelled vessels.

3.1.2 Recreational Vessel Propulsion and Size Data

The particular type of engine used on a mechanically-propelled vessel may have implications for the 

types of discharges it emits (Section 5.0). For example, some engine types take up ambient water to act 

as a cooling mechanism before discharging it back into receiving waters. As shown in Table 3-2, 

NMMA’s data indicates that almost 66% of all registered mechanically-propelled recreational vessels are 

powered by outboard engines.
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Table 3-2. Type of Propulsion for All Registered Mechanically-Propelled Recreational Vessels.

Propulsion Type Number of Boats

Outboard 7,911,509

Inboard/PWC 2,269,542

Sterndrive 1,680,045

Auxiliary Sail Inboard 67,742

Auxiliary Sail Outboard 69,890

TOTAL 11,998,728

Source: NMMA, 2007.

Along with the propulsion type of a recreational vessel, the size is also important when considering 

potential discharges. Smaller vessels are more likely than larger vessels to be removed from the water for 

repairs and maintenance. Larger vessels are more likely to have greater deck surface area, may generate 

grey water from an onboard galley or bathroom, and have bilge water tanks with greater capacities. 

The NMMA data indicate that over 95% of all registered mechanically-propelled recreational vessels in 

the U.S. are less than 26 feet in length (NMMA, 2007). No data are available for sizes of nonmechanically-propelled vessels. Table 3-3 presents the number of vessels less than 26 feet in length and 

the number of vessels 26 feet and over in length for each state, organized by the percent of the total 

registered mechanically-propelled recreational vessels that are less than 26 feet in length.

Table 3-3. Lengths of All Registered Mechanically-Propelled Recreational Vessels.

Number of Recreational 

Mechanically-Propelled Vessels State Less than 26 

feet in length

26 feet and over 

in length

Percent of total 

less than 26 feet 

Nebraska* 78,499 483 99.39%

North Dakota* 43,431 297 99.32%

South Dakota* 48,013 514 98.94%

Kansas* 92,385 1019 98.91%

Arkansas* 185,139 2,162 98.85%

Montana* 69,020 911 98.70%

Minnesota* 631,838 9,024 98.59%

West Virginia* 43,674 630 98.58%

Wyoming* 25,110 400 98.43%

Georgia 312,222 5,093 98.39%

Louisiana* 302,857 5,247 98.30%

Wisconsin 623,542 12,320 98.06%

New Mexico 36,430 766 97.94%

Pennsylvania* 302,432 6,419 97.92%

Colorado* 92,248 1,958 97.92%

Iowa 112,651 2,393 97.92%

Mississippi* 198,807 4,413 97.83%

South Carolina* 383,366 9,975 97.46%

Maine* 108,402 2,911 97.38%

Oklahoma 211,034 5,879 97.29%

Idaho* 79,756 2,279 97.22%

Alabama 254,566 7,729 97.05%
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Table 3–3. Lengths of All Registered Mechanically-Propelled Recreational Vessels, 

continued.

Number of Recreational 

Mechanically-Propelled Vessels State Less than 26 

feet in length

26 feet and over 

in length

Percent of total 

less than 26 feet 

Missouri 268,975 8,458 96.95%

North Carolina 345,986 11,267 96.85%

Texas* 585,715 19,214 96.82%

Indiana 197,760 6,765 96.69%

Kentucky* 157,855 5,579 96.59%

Oregon 178,295 6,348 96.56%

Virginia* 231,629 8,468 96.47%

Vermont 31,120 1,266 96.09%

Utah 71,423 3,001 95.97%

Tennessee 254,708 11,258 95.77%

Michigan 850,848 41,089 95.39%

Illinois 294,328 14,547 95.29%

New Hampshire 93,501 4,669 95.24%

Massachusetts* 134,498 6,892 95.13%

California* 848,098 44,624 95.00%

Nevada* 53,436 3,150 94.43%

Arizona* 133,708 8,019 94.34%

Ohio 305,363 20,269 93.78%

Alaska* 40,379 3,027 93.03%

Connecticut 98,378 9,625 91.09%

Florida 847,626 85,047 90.88%

Washington 242,777 25,016 90.66%

New York 451,654 47,482 90.49%

New Jersey 171,450 20,463 89.34%

Hawaii* 12,461 1,851 87.07%

Delaware* 44,218 7,111 86.15%

Maryland 165,018 31,677 83.90%

Rhode Island 35,930 7,726 82.30%

District of 

Columbia 1228 784 61.03%

TOTAL 11,383,787 547,514 95.41%

Source: NMMA, 2007.

* Documented recreational vessel numbers are not included in this table for those states that do not require a 

documented vessel to also be registered with the state.

3.2 Commercial Vessels

As described in Section 2.0, data on commercial vessels operating in U.S. waters were obtained primarily 

from the USCG (VESDOC) and USACE (WTLUS). 

3.2.1 Domestic Commercial Vessel Numbers and Types

USACE’s most recent WTLUS volumes (USACE, 2005a, 2005b, 2005c) contain substantial and wellorganized data on U.S.-flagged passenger and cargo vessels operating in U.S. waters. Table 3-4 presents 
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the summary findings by propulsion type (self-propelled or non-self-propelled); the subtypes contained 

within these general categories are provided in the table footnote. Figure 3-2 illustrates that the vast 

majority (78%) of cargo and passenger vessels operating in U.S. waters can be found in the Mississippi 

River System or the Gulf Intracoastal Waterway.

Table 3-4. Summary of the U.S.-Flag Cargo or Passenger Vessels Operating in U.S. Waters by 

Region.

Type of Vessel Total Number 

of Vessels

Atlantic, Gulf, and 

Pacific Coasts

Mississippi River 

System and the Gulf 

Intracoastal 

Waterway

Great Lakes 

System

SELF-PROPELLED

Dry Cargo and/or 

Passenger, Offshore 

Support

2,967 1,638 1,162 167

Vehicular Ferries and 

Railroad Cars 619 472 82 65

Tankers 100 90 6 4

Towboats 5,290 1,864 3,303 123

TOTAL SELFPROPELLED 8,976 4,064 4,553 359

TOTAL CARGO 

CAPACITYa(short tons) 12,342,485 9,175,249 894,749 2,272,487

TOTAL PASSENGER 

CAPACITYb(persons) 451,723 330,271 85,072 36,380

NON-SELF-PROPELLED

Barges, Dry Cargo 27,876 3,961 23,739 176

Barges, Tanker 4,151 618 3,525 8

Railroad Car Barge 25 24 1 0

TOTAL NON-SELFPROPELLED 32,052 4,603 27,265 184

TOTAL CARGO 

CAPACITYc(short tons) 57,035,748 11,398,711 45,259,164 377,873

TOTAL PASSENGER 

CAPACITYd(persons) 553 167 386 0

GRAND TOTAL SELFAND NON-SELFPROPELLED

41,028 8,667 31,818 543

Source: USACE, 2005a.

a

Includes cargo capacity of dry cargo vessels and tankers.

b

Includes passenger capacity of passenger vessels and vehicular ferries

c Includes cargo capacity of dry cargo barges, tanker barges, and railroad car floats

d

Includes passenger capacity of dry cargo barges

Self-Propelled, Dry Cargo: Crewboat / Supply / Utility Vessel; Vehicle Carrier; General Cargo Freighter; Passenger Carrier; Break Bulk / RORO Carrier; Combination Passenger and Cargo; RO-RO Vessel; Ferry; Bulk Carrier; Railroad Car Ferry; Containership; Lash Vessel; Partial 

Containership; Excursion / Sightseeing Vessel; Container / Vehicle / Trailer (RO-RO) Carrier

Self-Propelled, Tanker: Petroleum / Chemical Carrier; Liquid Gas Carrier; Chemical Carrier; Other Tanker; Liquid Bulk Tanker

Towboat: Pushboat; Tugboat

Non-Self-Propelled, Tanker: Liquid Cargo Barge (Single Hull); Liquid Cargo Barge (Double Bottom Only); Liquid Cargo Barge (Double Hull); 

Other Liquid Cargo Barge, Not; Liquid Cargo Barge (Double Sided Only) Elsewhere Included

Non-Self-Propelled, Dry Cargo: Open Hopper Barge; Covered Dry Cargo Barge; Covered Hopper Barge; RO-RO Barge; Carfloat (Railroad 

Car Barge); Container Barge; Flat / Deck Barge; Lash / Seabee Barge; Pontoon Barge; Convertible Barge; Open Dry Cargo Barge; Other
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21%

78%

1%

Atlantic, Gulf, and Pacific Coasts

Mississippi River System and the Gulf Intracoastal Waterway

Great Lakes System

Figure 3-2. Summary of U.S. Flag Cargo and Passenger Vessels Operating in U.S. Waters by 

Region.

Source: USACE, 2005a

As described in Section 2.2.3, WTLUS also provides information on the Transportation Series Operator 

(TSO) company that operates these 41,028 passenger or cargo vessels (Volume 2) as well as the relevant 

characteristics of the vessels themselves (Volume 3). There are 2,732 TSO companies that own the 

41,028 vessels (USACE, 2005b). Table 3-5 lists the top twenty U.S. TSO companies according to the 

number of vessels operated and includes the principal types of vessels operated as well as a list of the 

major commodities carried. More detailed information on all 2,732 TSO companies with specific contact 

information can be found in USACE (2005b). USACE (2005c) also provides more detail on each vessel, 

including in which specific subtype (in list above) the vessel is categorized, the vessel’s registered 

length/depth/breadth, and horsepower.

As described in Section 2.2.1, VESDOC is another source for data on commercial vessels operating in 

U.S. waters. All U.S.-owned commercial vessels involved in passenger or merchandise transportation as 

well as towing or dredging must be documented with the USCG. One of the ways VESDOC data are 

organized is by “Vessel Service Type”, which indicates the primary service for which the vessel was 

documented. The VESDOC metadata (USCG, 2007b), however, caution that the vessel service type may 

not be the most reliable indicator of the specific use of a vessel. Rather, USCG (2007b) recommends 

using the vessel numbers provided in the ‘trade indicator’ fields, as described in Section 2.2.1, for a more 

complete picture. However, the vessel service type field is broken into more categories than the trade 

indicator field; in addition, the trade indicator field appeared to be focused more on where the vessel 

could be operated and less on the general use of the vessel. Table 3-6 provides the VESDOC statistics for 

the various vessel service types. 
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Table 3-5. Top Twenty U.S. TSO Companies Operating Cargo or Passenger Vessels in U.S. Waters 

by Number of Vessels Operated.

TSO Name

City/State 

Location of 

the TSO

Total 

Number of 

Vessels 

Operated 

by TSO

Principal Types of 

Vessels Operated 

by TSOa

List of Principal Commodities 

Carried by TSO’s Vessels

Ingram Barge 

Co. Nashville, TN 4,256 DCB, DOB, DHTB

Towing, petroleum products, 

bulk freight, coal, coke, grain 

and aggregates

American 

Commercial 

Lines, LLC

Jeffersonville, 

IN 3,249 DCB, DOB, DHTB

Towing, steel, petroleum 

products, coal, coke, sulphur, 

sugar, creosote, grain, scrap iron, 

chemicals, salt and general 

commodities

American River 

Transportation 

Co.

Ama, LA 2,221 DCB, DHTB, DB Grain and grain products, coal, 

fertilizer, salt and scrap

AEP Memco, 

LLC

Chesterfield, 

MO 1,620 DOB, DCB, PUSH

Towing, coal, grain, grain 

products, cement, chemicals, 

salt, steel, lime, coke, slag, and 

aggregates

Kirby Inland 

Marine, LP Houston, TX 1,013 DHTB, PUSH, OTB

Chemical and petroleum 

products

Crounse 

Corporation Paducah, KY 939 DOB, PUSH Towing, bulk freight and coal

Cargill Marine 

and Terminal, 

Inc.

Minneapolis, 

MN 673 DCB Coal, grain, vegetable oil, salt and miscellaneous commodities

McDonough 

Marine Service 

(Div. of 

Marmac 

Corporation)

Metarie, LA 672 DB, DOB, DHTB Miscellaneous freight

Teco Barge 

Line Metropolis, IL 612 DOB, DCB Coal, phosphate sulphur and bulk commodities

Canal Barge 

Company, Inc.

New Orleans, 

LA 608 DOB, DHTB, DB

Towing, bulk petroleum, molten 

sulphur, chemicals, coal, grain, 

fertilizer and general cargo

SCF Marine, 

Inc. St. Louis, MO 581 DCB, DOB, DB

Grain, industrial commodities, 

rice, meals, salt, coal and dry 

bulk commodities

Campbell 

Transportation 

Co.

Charleroi, PA 404 DOB Coal, sand & gravel

American 

Commercial 

Barge Line, 

LLC

Jeffersonville, 

IN 383 DCB

Towing, liquid chemicals, 

petroleum, crude oil and refined 

oil products

Central Gulf 

Lines, Inc.

New Orleans, 

LA 378 LSB

Steel, paper products and 

miscellaneous cargo - rubber, 

timber, flour and rice

Forest Lines, 

LLC

New Orleans, 

LA 332 LSB Paper products
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Table 3–5. Top Twenty U.S. TSO Companies Operating Cargo or Passenger Vessels in U.S. Waters 

by Number of Vessels Operated, continued.

TSO Name

City/State 

Location of 

the TSO

Total 

Number of 

Vessels 

Operated 

by TSO

Principal Types of 

Vessels Operated 

by TSOa

List of Principal Commodities 

Carried by TSO’s Vessels

Alter Barge 

Line, Inc. Bettendorf, IA 327 DCB, DB

Coal, steel, scrap, grain, 

containers and general 

commodities; bulk products -

regulated and exempt

Consolidation 

Coal Company 

(River Division)

Elizabeth, PA 297 DOB Coal

Marquette 

Transportation 

Company

Paducah, KY 285 DCB, DB, PUSH Grain, coal, salt, fertilizer and 

rock

Pine Bluff Sand 

and Gravel 

Company

Pine Bluff, AR 253 DB, DOB, PUSH Construction equipment and 

materials, sand and gravel

Luhr Bros., Inc. Columbia, IL 245 DB, DOB, PUSH

Crushed limestone products, riprap and heavy construction 

equipment

Source: USACE, 2005b.

a Vessel type abbreviations: DCB = dry covered barge; DOB = dry open barge; DB = deck barge; DHTB = double hull tank 

barge; PUSH = pushboat; LSB = lash/seabee barge; OTB = other tank barge

Table 3-6. Total Number of U.S. Documented Vessels by Service Type.

VESDOC Vessel Service Type Total Number of Vessels 

Documented

Commercial Fishing Vessel 28,972

Fish Processing Vessel 35

Freight Barge 23,153

Freight Ship 651

Industrial Vessel (e.g., cable layer, dredge, crane barge) 823

Mobile Offshore Drilling Unit 118

Offshore Supply Vessel 1,114

Oil Recovery 372

Passenger (Inspected) 9,539

Passenger (Uninspected) 2,311

Passenger Barge (Inspected) 109

Passenger Barge (Uninspected) 127

Public Freight 6

Public Tankship/Barge 2

Public Vessel, Unclassified 24

Research Vessel 234

School Ship 38

Tank Barge 4,134

Tank Ship 129

Towing Vessel 6,898

Unclassified/Unknown/Unspecified 5,357

Source: VESDOC, 2007
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3.2.2 Domestic Commercial Fishing Vessel Numbers

Because the USCG differentiates between commercial vessels and commercial fishing vessels (see 

Section 3.2), these two categories of vessels are dealt with separately in this report. As described in 

Section 2.2.1, VESDOC categorizes documented vessels based on the trade for which the vessel is 

licensed. One of the trade categories is ‘fishery’, which applies to vessels “licensed to engage in the 

fisheries trade in the navigable waters of the U.S. and on the Exclusive Economic Zone” (USCG, 2007b). 

Another trade category is ‘limited fishery only’, but the VESDOC metadata (USCG, 2007b) does not 

define this category further. Battelle has included this latter category in the commercial fishing vessel 

totals in the next paragraph. Any vessel owned by a U.S. citizen that commercially fishes in U.S. waters 

must be documented and, therefore, is included in the most recent VESDOC data. 

The May 2007 VESDOC data indicate that there are 33,550 commercial fishing vessels licensed to fish in 

U.S. navigable waters and the EEZ5. Due to the data problems associated with VESDOC (as described in 

Section 2.2.1), Battelle was unable to query the database by ‘hailing port’ which would have been a good 

indicator of the vessel’s geographic area of operation (USCG, 2007b). The contact state and/or city of a 

given vessel’s managing owner was available and, although the owner’s state may not in all cases be 

equivalent to the ‘hailing port’ state, it may also be a reasonable indicator of where the fishing vessel 

typically operates. Figure 3-3 illustrates the number of documented commercial fishing vessels by 

owner’s contact state.

5 There is about a 4,500 vessel difference between vessels with a vessel service type of ‘commercial fishing vessel’ 

(Table 3-6) and vessels with a trade indicator of ‘fishery’. This may be explained by the vessel owner’s opinion of 

what his vessel’s use was. For example, ‘fisheries trade’ may have meant, to some vessel owners, charter fishing or 

other fishing-for-hire activities, not solely commercial fishing. Therefore, the true number of commercial fishing 

vessels operating in U.S. waters is likely somewhere between 28,972 and 33,550.
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0

500

1000

1500

2000

2500

3000

3500

4000

4500

5000

AK

AL

AR

AZ

CA

CO

CT

DC

DE

FL

GA

HI

IA

ID

IL

IN

KSKY

LA

MA

MD

ME

MI

MN

MO

MS

MT

NC

NE

NH

NJ

NM

NV

NY

OH

OK

OR

PA

RI

SCSD

TN

TX

UTVA

VT

WA

WI

WVWY

US Territories

Unreported state

Number of Documented Commercial Fishing Vessels

Figure 3-3. Documented Commercial Fishing Vessels by Owner’s Contact State.

Source: USCG, 2007a
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3.2.3 Foreign Commercial Vessel Numbers

Information on foreign commercial vessels operating in U.S. waters was more difficult to obtain. 

MARAD provides general world fleet statistics, but does not have data on which waterways world fleet 

vessels typically operate.

One source for the number of foreign commercial vessels visiting U.S. waters is the U.S. Customs 

Entrances/Clearances records (U.S. CBP, 2007). These data are also discussed in Section 4.0, although in 

terms of what type of port (domestic or foreign) a vessel had visited immediately prior to entering the 

U.S. port at which it was recorded. As described in Section 2.3, the 2005 Entrances/Clearances records 

were the most recent available from the NDC. According to these data, there were a total of 90,328

vessel entrances to a major U.S. port or waterway in 2005 and 7,726 different vessels made these 

entrances (U.S. CBP, 2007). Of the 7,726 unique vessels making entrance, 6,982 flew one of 83 different 

foreign flags (the remaining 744 flew U.S. flags). In the CBP (2007) data, a foreign vessel may have 

been recorded under more than one flag; this was due to some vessels changing their flag of registry 

during the year and, therefore, being recorded under more than one flag. Table 3-7 presents the top twenty 

most frequently recorded flags of vessels entering a major U.S. port or waterway in 2005. 

Table 3-7. Top 20 Most Frequently Recorded Flags Entering U.S. Ports or Waterways in 2005

COUNTRY TOTAL 

ENTRANCES

Panama 13,670

United States and territories 11,216

Bahamas 9,682

Liberia 8,569

Canada 4,662

Antigua and Barbuda 4,578

Marshall Islands 3,227

Singapore 3,169

Cyprus 2,745

Norway 2,600

Greece 2,216

Netherlands 2,123

St. Vincent and the Grenadines 1,963

Hong Kong 1,946

Malta 1,839

Bermuda 1,743

Germany 1,641

United Kingdom 1,525

Danish International Register 868

Italy 692

Source: U.S. CBP, 2007.
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4.0 PORT FINDINGS

Information on the busiest ports in the U.S. is useful for understanding the characteristics of national 

waterway traffic, of both domestic and foreign arrivals. The following sections describe the various 

available information on U.S. port traffic, including number of vessel calls, flag registration of arriving 

vessels, and the last port of call of arriving vessels.

4.1 Calls to U.S. Ports

Figure 4-1 illustrates the number of vessel calls to U.S. coastal ports in 2005 by geographic region as 

provided by MARAD (2006). MARAD only recorded self-propelled vessels of greater than 10,000 tons 

deadweight6.

The U.S. Gulf region received nearly 31% of all coastal vessel calls in 2005, followed by the South 

Atlantic region with approximately 19%. Table 4-1 lists the total number of calls made by vessels to all 

coastal U.S. ports in 2005 (MARAD, 2006) along with the most frequent type of vessel calling there. 

Table 4-2 shows the top 20 coastal U.S. ports for 2005 vessel calls; these 20 ports will hereafter be 

referred to as the ‘major ports’. 

11,498

6,941

1,290

11,709 10,926

18,683

North Atlantic Pacific Northwest Puerto Rico

Pacific Southwest South Atlantic U.S. Gulf

Figure 4-1. 2005 Vessel Calls to U.S. Coastal Ports by Geographic Region.

Source: MARAD, 2006

North Atlantic: Ports from Eastport, ME to Baltimore, MD

South Atlantic: Ports from Alexandria, VA to Miami, FL

U.S. Gulf: Ports from Key West, FL to Brownsville, TX

Pacific Southwest: Ports from Crockett, CA to San Diego, CA and all Hawaiian ports

Pacific Northwest: Ports from Barrow, AK to Coos Bay, OR

Puerto Rico: Ports in Puerto Rico

6 Deadweight is defined as the total weight in metric tons of cargo, fuel, fresh water, stores and crew which a ship can carry when 

immersed to its load line (MARAD, 2006).
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Table 4-1. 2005 Vessel Calls at All U.S. Coastal Ports Organized by Geographic Region

State Porta Number of 

Calls Most Frequently Calling Vessels

NORTH ATLANTIC

CT Bridgeport 87 General cargo vessels

CT Groton 4 Tanker

CT New Haven 185 Tanker, General cargo vessels

CT New London 32 General cargo vessels

MA Boston 332 General cargo vessels, Tanker

MA Fall River 1 General cargo vessels

MA Salem 2 General cargo vessels

MA Sandwich 2 Tanker

MD Annapolis 134 General cargo vessels

MD Baltimore 1,825 General cargo vessels, Roll on-Roll Off cargo vessels

MD Cove Point 74 Tanker

MD Piney Point 50 Tanker

ME Bucksport 2 Tanker

ME Camden 1 General cargo vessels

ME Eastport 13 General cargo vessels

ME Portland 364 Tanker

ME Sandy Point 1 Tanker

ME Searsport 19 Tanker

NH Portsmouth 129 General cargo vessels, Tanker

NY Albany 1 General cargo vessels

NY Kingston 2 General cargo vessels

NY New York 4,902 General cargo vessels, Tanker

NY Northport 9 Tanker

NY Northville 47 Tanker

NY Riverhead 2 Tanker

NY Stony Point 2 General cargo vessels

PA Philadelphia 2,998 Tanker, General cargo vessels

RI Brayton Point 5 General cargo vessels

RI Davisville 78 Roll on-Roll Off Cargo Vessels

RI Jamestown 1 General cargo vessels

RI Newport 1 General cargo vessels

RI Providence 193 Tanker, General cargo vessels

PACIFIC NORTHWEST

AK Afognak 95 Roll on-Roll Off Cargo Vessels

AK Anchorage 150 General cargo vessels

AK Drift River Term. 1 Tanker

AK Dutch Hbr. 157 General cargo vessels

AK Hawk Inlet 2 General cargo vessels

AK Homer 79 Tanker

AK Hoonah 5 General cargo vessels

AK Hydaburg 15 General cargo vessels

AK Juneau 1 Tanker

AK Kake 5 General cargo vessels
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Table 4–1. 2005 Vessel Calls at All U.S. Coastal Ports Organized by Geographic Region, continued

State Porta Number of 

Calls Most Frequently Calling Vessels

AK Kenai 11 General cargo vessels

AK Ketchikan 4 General cargo vessels

AK Klawock 12 General cargo vessels

AK Kodiak 97 General cargo vessels

AK Nikiski 143 Tanker

AK Red Dog 9 General cargo vessels

AK Seward 7 General cargo vessels

AK Tolstoi Bay 5 General cargo vessels

AK Valdez 399 Tanker

OR Columbia River 2,189 General cargo vessels

OR Coos Bay 43 General cargo vessels

WA Anacortes 8 General cargo vessels

WA Bellingham 2 General cargo vessels

WA Bremerton 2 General cargo vessels

WA Cherry Point 209 Tanker

WA Everett 33 General cargo vessels, Roll on-Roll Off cargo vessels

WA Ferndale 123 Tanker

WA Manchester 11 Tanker

WA March Point 342 Tanker

WA Olympia 20 General cargo vessels, Roll on-Roll Off cargo vessels

WA Point Wells 19 Tanker

WA Port Angeles 277 Tanker

WA Port Townsend 3 General cargo vessels

WA Seattle 1,186 General cargo vessels

WA Tacoma 1,270 General cargo vessels

WA Westport 7 General cargo vessels

PUERTO RICO

PR Guanica 1 General cargo vessels

PR Guayanilla 125 Tanker

PR Las Mareas 7 General cargo vessels

PR Mayaguez 1 General cargo vessels

PR Ponce 19 General cargo vessels

PR Puerto Rico 9 Tanker

PR San Juan 1,086 General cargo vessels

PR Yabucoa 42 Tanker

PACIFIC SOUTHWEST

CA El Segundo 245 Tanker

CA LA/Long Beach 5,178 General cargo vessels

CA Port Hueneme 397 Roll on-Roll Off cargo vessels

CA S. California light. area 24 Tanker

CA San Diego 319 Roll on-Roll Off cargo vessels, General cargo vessels

CA San Francisco 3,871 General cargo vessels

HI Barbers Point 162 Tanker

HI Hilo 54 Roll on-Roll Off cargo vessels

HI Honolulu 586 General cargo vessels
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Table 4–1. 2005 Vessel Calls at All U.S. Coastal Ports Organized by Geographic Region, continued

State Porta Number of 

Calls Most Frequently Calling Vessels

HI Kahului 77 Roll on-Roll Off cargo vessels

HI Kawaihae 1 General cargo vessels

HI Nawiliwili 11 Roll on-Roll Off cargo vessels

HI Port Allen 1 Roll on-Roll Off cargo vessels

SOUTH ATLANTIC

FL Cape Canaveral 2 General cargo vessels, Roll on-Roll Off cargo vessels

FL Fernandina 6 General cargo vessels

FL Jacksonville 1,237 General cargo vessels, Roll on-Roll Off cargo vessels

FL Miami 1,299 General cargo vessels

FL Palm Beach 116 General cargo vessels

FL Port Canaveral 55 General cargo vessels, Roll on-Roll Off cargo vessels

FL Port Everglades 1,182 General cargo vessels, Tanker

GA Brunswick 243 Roll on-Roll Off cargo vessels

GA Savannah 2,333 General cargo vessels

NC Morehead City 36 General cargo vessels

NC Southport 1 Tanker

NC Wilmington 600 General cargo vessels, Tanker

SC Charleston 2,046 General cargo vessels

SC Georgetown 6 General cargo vessels

VA Virginia Ports 2,547 General cargo vessels

U.S. GULF

AL Mobile 811 General cargo vessels

FL Key West 2 Tanker

FL Panama City 6 General cargo vessels

FL Pensacola 19 General cargo vessels

FL Port Manatee 159 General cargo vessels

FL Tampa 1,003 Tanker, General cargo vessels

LA Gulf Gateway Term. 2 Tanker

LA Lake Charles 701 Tanker

LA LOOP Term. 401 Tanker

LA New Orleans 3,749 General cargo vessels, Tanker

LA Port Fourchon 1 Tanker

LA Southwest Pass light. 

area

3 Tanker

MS Gulfport 39 General cargo vessels

MS Pascagoula 233 Tanker

MS Pascagoula light. area 5 Tanker

TX Beaumont 72 General cargo vessels

TX Brownsville 158 General cargo vessels

TX Corpus Christi 989 Tanker

TX Freeport 759 Tanker

TX Freeport light. area 2 Tanker, Roll on-Roll Off cargo vessels

TX Galveston 429 General cargo vessels, Tanker

TX Galveston light. area 98 Tanker
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Table 4–1. 2005 Vessel Calls at All U.S. Coastal Ports Organized by Geographic Region, continued

State Porta Number of 

Calls Most Frequently Calling Vessels

TX Houston 5,891 Tanker, General cargo vessels

TX Ingleside 107 General cargo vessels, Tanker

TX Point Comfort 321 Tanker

TX Port Arthur 1,563 Tanker

TX S. Sabine Point light. 

Area 17 Tanker

TX Smith’s Bluff 1 Tanker

TX Texas City 1,142 Tanker

Source: MARAD, 2006.

a

Some of the port names in this table refer to groupings of geographically-similar ports. This was done to decrease the 

unwieldiness of the table and had been done by MARAD in previous years (MARAD, 2006). The groupings are described 

below.

Columbia River

· Includes the ports of Astoria, Kalama, Longview, Portland, Rainier, Vancouver, and Willbridge. 

L.A/Long Beach

· Includes the ports of Los Angles and Long Beach. 

New Orleans 

· Includes the ports of Ama, Arabi, Avondale, Baton Rouge, Belle Chasse, Boothville, Braithwaite, Burnside, 

Chalmette, Convent, Darrow, Davant, Destrechan, Donaldsonville, Empire, Garyville, Geismar, Good Hope, 

Gramercy, Gretna, Harvey, La Place, Magnolia, Marrero, Meraux, Michound, Myrtle Grove, New Orleans, Norco, 

Ostrica, Paulina, Pilottown, Plaquemine, Port Allen, Port Sulfur, Reserve, St. Bernard, St. James, St. Rose, Taft, 

Violet, Waggaman, and Westwago. 

Philadelphia 

· Includes the ports of Burlington, NJ, Camden NJ, Claymont, DE, Chester, PA, Delair, NJ, Delaware City, DE, 

Eddystone, PA, Fairless Hills, Gloucester, NJ, Marcus Hook, PA, Paulsboro, NJ, Philadelphia, PA, Reedy Point, 

DE, Salem, NJ, Tullytown, PA, Westville, NJ, and Wilmington, DE. 

San Francisco Bay

· Includes the ports of Alameda, Antioch, Bencia, Concord, Crockett, Martinez, Oakland, Pittsburg, Redwood City, 

Richmond, Rodeo, Sacramento, San Francisco, Selby, and Stockton. 

Virginia 

· Includes the ports of Chesapeake, Hampton Roads, Hopewell, Lynnhaven Roads, Newport News, Norfolk, 

Portsmouth, Richmond, and Yorktown

Table 4-2. Top 20 U.S. Ports by Number of Vessel Calls in 2005.

Coastal Region Port State Number of Calls

U.S. Gulf Houston TX 5,891

Pacific Southwest LA/Long Beach CA 5,178

North Atlantic New York NY 4,902

Pacific Southwest San Francisco CA 3,871

U.S. Gulf New Orleans LA 3,749

North Atlantic Philadelphia PA 2,998

South Atlantic Virginia Ports VA 2,547

South Atlantic Savannah GA 2,333

Pacific Northwest Columbia River OR 2,189

South Atlantic Charleston SC 2,046

North Atlantic Baltimore MD 1,825

U.S. Gulf Port Arthur TX 1,563

South Atlantic Miami FL 1,299

Pacific Northwest Tacoma WA 1,270
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Table 4–2. Top 20 U.S. Ports by Number of Vessel Calls in 2005, continued.

Coastal Region Port State Number of Calls

South Atlantic Jacksonville FL 1,237

Pacific Northwest Seattle WA 1,186

South Atlantic Port Everglades FL 1,182

U.S. Gulf Texas City TX 1,142

Puerto Rico San Juan PR 1,086

U.S. Gulf Tampa FL 1,003

Source: MARAD, 2006.

Table 4-2 shows that Houston, TX had more vessel calls than any other coastal U.S. port in 2005. 

The U.S. CBP data on vessel entrances and clearances (CBP, 2007) provide information on all U.S. ports 

(coastal and inland), including the date a vessel entered a given port (i.e., filed an entrance record), the 

vessel’s flag, and the previous port the vessel had called at. Having information on the previous port 

visited by a vessel can help evaluate the threat of invasive species introductions. Table 4-3 presents the 

number of calls that the previous port was foreign (‘foreign calls’) and the number of calls that the 

previous port was domestic (‘domestic calls’) for the 20 U.S ports with the most total calls in 2005,

according to the CBP data. The top 20 ports with the most calls in 2005 according to CBP may differ 

slightly from the MARAD data; MARAD recorded data only at coastal ports, while CBP recorded data at 

all U.S. ports. In addition, MARAD grouped some of the geographically similar coastal ports (see Table 

4-1) and CBP did not.

Table 4-3 shows that a number of the top 20 U.S. ports primarily receive foreign calls: Port Everglades, 

FL; Long Beach, CA; San Juan, PR; and Seattle, WA. Elizabeth River, VA was the U.S. port with the 

highest percentage of domestic calls, followed by Oakland, CA. One caveat presents itself with these 

data: a domestic call does not necessarily mean that there is less of an invasive species introduction threat 

than a foreign call. 

Table 4-3. 2005 Domestic and Foreign Vessel Calls at Top 20 U.S. Ports.

U.S Port

Number of 

Domestic 

Calls

Number of 

Foreign 

Calls

Percent 

Domestic 

Calls

Most Frequently Cited Last 

Port*

Houston, TX 2,032 3,585 36.2% Mexico

New York, NY 1,565 3,218 32.7% Canada

Port Everglades, FL 642 3,665 14.9% Bahamas

Miami, FL 788 2,937 21.2% Bahamas

Long Beach, CA 469 2,159 17.8% Mexico

San Juan, PR 333 2,186 13.2% U.S. Virgin Islands

Savannah, GA 1,671 725 69.7% Elizabeth River, VA

St. Thomas, VI 1,235 1,128 52.3% San Juan, PR

Seattle, WA 142 2,197 6.1% Canada

New Orleans, LA 1,067 1,222 46.6% Houston, TX (D); Mexico (F)

Charleston, SC 1,565 709 68.8% Elizabeth River, VA

Los Angeles, CA 368 1,856 16.5% Mexico

Baltimore, MD 1,175 812 59.1% New York, NY

Elizabeth River, VA 1,689 134 92.6% New York, NY
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Table 4–3. 2005 Domestic and Foreign Vessel Calls at Top 20 U.S. Ports, continued.

U.S Port

Number of 

Domestic 

Calls

Number of 

Foreign 

Calls

Percent 

Domestic 

Calls

Most Frequently Cited Last 

Port*

Oakland, CA 1,248 471 72.6% Los Angeles, CA

Bayou Lafourche, LA 14 1,679 0.8% Unknown*

Galveston, TX 75 1,520 4.7% Unknown*

Tacoma, WA 188 1,406 11.8% Canada

Jacksonville, FL 662 880 42.9% Bahamas

South Louisiana, LA 332 1,141 22.5% Mexico

Source: CBP, 2007

* According to CBP (2007), a port cited as ‘Unknown’ reported its last port as “high seas”

4.2 Receiving Water Characteristics

For each of the top 20 U.S. ports (as determined by total number of vessel calls and listed in Table 4-3), 

several sources were consulted to assess the current water quality conditions. In the following sections, 

each of the top 20 ports are briefly described in terms of their water quality and general condition. As 

described in Sections 2.4.4 and 2.4.5, the sources consulted for the following descriptions included EPA’s 

National TMDL database (EPA, 2007a), the 2007 NEP Coastal Condition Report (EPA, 2007b), and a 

collection of other sources that are cited below in the relevant sections. The water quality characteristics 

of the top 20 ports are described below from most vessel calls to fewest (based on CBP, 2007).

4.2.1 Houston, Texas

EPA’s National TMDL database lists chlordane (in tissue), dieldrin (in tissue), dioxin, heptachlor 

epoxide, polychlorinated biphenyls (PCBs) (in tissue), and sediment toxicity as the pollutants in 

exceedance of water quality standards in Port of Houston waters (as of 2004, the most recently-available 

year). According to the mapping feature of the National TMDL database, the water body segments that 

comprise the Houston Ship Channel and the Port of Houston include: Barbour’s Cut, Houston Ship 

Channel/San Jacinto River Tidal, Black Duck Bay, Tabbs Bay, Scott Bay, and Houston Ship 

Channel/Buffalo Bayou Tidal. All of these segments are impaired for one or more of the pollutants listed 

above. In addition, vessels traveling to and from the Port of Houston must traverse Upper Galveston Bay, 

which is impaired for bacteria, dioxins, and PCBs, prior to entering the Houston Ship Channel (EPA, 

2007a).

Galveston Bay is designated as an NEP estuary7, with the 2007 Coastal Condition Report describing

Galveston Bay as well-mixed and shallow and strewn with extensive oyster beds. The water quality in 

Galveston Bay is classified as ‘fair-to-poor’, with high DIN and DIP concentrations being the main causes 

of excessive chlorophyll a levels and poor water clarity. DO concentrations, however, were rated as 

‘good’. Total organic carbon (TOC) concentrations and sediment toxicity was both rated ‘good’, 

although sediment toxicity data were not available for 31% of the estuary. Finally, sediment contaminant 

levels were classified as ‘fair’ (EPA, 2007b). 

According to the Galveston Bay Estuary Program’s water quality monitoring program, nutrient (e.g., total 

nitrogen, ammonia, and total phosphorus) and chlorophyll a concentrations in Galveston Bay, its subbays, and tributaries have been generally declining since monitoring began in the 1970s, with many areas 

7 The Coastal Condition Report discussion of the waters surrounding the port of Houston is also relevant to 

Galveston Bay (Section 4.2.16).
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achieving a ‘ good’ or ‘very good’ rating. Other areas, however, especially those areas surrounding the 

shipping route through the Bay (e.g., Upper and Lower Galveston Bay, Houston Ship Channel, Buffalo 

Bayou) exhibit a ‘fair’ or ‘poor’ rating for nutrients and chlorophyll a. Enterococcus, Escherichia coli, 

and fecal coliform were also found in high concentrations in many tributaries surrounding Galveston Bay 

and the Port of Houston; for many of these tributaries, the bacterial levels have been consistently high 

since the 1970s (EPA, 2007b)

4.2.2 New York City, NY

The Port of New York City is comprised of facilities located in both New York and New Jersey. EPA’s 

National TMDL database lists PCBs, nitrogen, mercury, cadmium, oxygen demand, floatables, and 

dioxins as the pollutants in exceedance of water quality standards in Port of New York and New Jersey 

waters (as of 2004, the most recently-available year). According to the mapping feature of the National 

TMDL database, the water body segments that comprise the Port of New York include: Lower East River, 

Upper New York/New Jersey Harbor, Kill Van Kull, Newark Bay, and Arthur Kill and tidal tributaries. 

All of these segments are impaired for one or more of the pollutants listed above (EPA, 2007a). 

The water quality of the New York-New Jersey Harbor Estuary Program (HEP) is discussed in EPA’s 

2007 Coastal Condition Report and is rated as ‘poor’; however, there are no data available for 

approximately 62% of the estuarine area. According to available data, DIN and DIP levels were elevated 

over a wide area of the estuary and rated as ‘fair’ and ‘poor’, respectively. The estuary was rated ‘good’ 

for chlorophyll a, DO levels, and water clarity. Sediment quality, however, was generally considered 

‘poor’, with both sediment toxicity and sediment contaminants being elevated. TOC in sediment was 

rated ‘good’ for a majority of the estuarine area. On a positive note, none of the water quality indicators 

monitored by the HEP (i.e., fish tissue contamination, coliform bacteria levels, dissolved oxygen, harmful 

algal blooms, etc.) has exhibited downhill trends since monitoring began. Despite these positive trends, 

the overall health of the estuary is rated as ‘poor’ primarily because of the deteriorating trends in some 

wading bird and fish populations and ongoing fish consumption advisories (EPA, 2007b). 

4.2.3 Port Everglades, Florida

EPA’s National TMDL database lists coliforms, DO, and nutrients as the pollutants in exceedance of 

water quality standards in Port Everglades waters (as of 2002, the most recently-available year). 

According to the mapping feature of the National TMDL database, the water body segment that 

comprises the Port of Port Everglades includes the Intracoastal Waterway in Dade County (EPA, 2007a). 

Water quality sampling programs managed by the Broward County Department of Natural Resources and 

the South Florida Water Management District did not have stations located in or around the Port of Port 

Everglades.

4.2.4 Miami, Florida

EPA’s National TMDL database does not list any water quality exceedances in and around the Port of 

Miami. Water quality sampling programs managed by the Miami-Dade County Department of 

Environmental Resource Management and the South Florida Water Management District did not have 

stations located in or around the Port of Miami (EPA, 2007a).

4.2.5 Los Angeles/Long Beach, CA

EPA’s National TMDL database lists pesticides (dichloro-diphenyl-trichloroethane [DDT], toxaphene, 

chlordane, and dieldrin), polycyclic aromatic hydrocarbons (PAHs), PCBs, zinc, copper, chromium, lead, 

mercury, cadmium, nickel, and sediment toxicity as the pollutants in exceedance of water quality 

standards in the waters in and around the ports of Los Angeles/Long Beach (as of 2002, the most 

recently-available year). According to the mapping feature of the National TMDL database, the water 

body segments that comprise the Port of Los Angeles/Long Beach include: Los Angeles Harbor Main 
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Channel, Los Angeles Harbor Southwest Slip, Los Angeles Fish Harbor, Los Angeles Harbor 

Consolidated Slip, Long Beach Harbor Main Channel, and San Pedro Bay Near/Offshore Zones (EPA, 

2007a).

Although the Port of Los Angeles/Long Beach is located adjacent to Santa Monica Bay, one of the 28 

NEPs, the geographic scope of the monitoring described in the 2007 Coastal Condition Report does not 

cover the port. 

4.2.6 San Juan, Puerto Rico

EPA’s National TMDL database lists ammonia, fecal coliform, and DO as the pollutants in exceedance of 

water quality standards in the waters in and around the port of San Juan (as of 2004, the most recentlyavailable year) (EPA, 2007a). 

San Juan Bay is one of the NEPs described in the Coastal Condition Report (EPA, 2007b). The overall 

condition of the Bay was rated as ‘poor’, based on the water quality, sediment, benthic, and fish tissue 

indices. Water column DIN and DIP concentrations were rated as ‘fair’, although data for DIP were

unavailable for 78% of the estuarine area. 73% of the estuarine area was rated as ‘good’ for chlorophyll 

a levels and water clarity measurements were found to be ‘fair’ overall. DO concentrations were listed as 

‘fair’ for 57% of the estuary and ‘good’ for 36%. Sediment toxicity was ‘poor’ (with PCBs, DDT, 2-

ethylhexl phthalate, lead, and mercury among the most abundant sediment contaminants) and sediment 

TOC levels were rated ‘good’. Low benthic species diversity has resulted in a ‘poor’ rating for benthic 

conditions and, with 40% of fish tissue samples collected in the estuary exceeding EPA’s advisory levels, 

the fish tissue contaminants index was rated ‘poor’ (EPA, 2007b). 

4.2.7 Savannah, GA

EPA’s National TMDL database lists DO and mercury as the pollutants in exceedance of water quality 

standards in the waters in and around the Port of Savannah (as of 2002, the most recently-available year) 

(EPA, 2007a). According to the mapping feature of the National TMDL database, the water body 

segments that comprise the Port of Savannah include: Savannah River and Savannah Harbor (EPA, 

2007a).

4.2.8 St. Thomas, Virgin Islands

EPA’s National TMDL database lists DO, fecal coliform, oil and grease, and pH as the pollutants in 

exceedance of water quality standards in the waters in and around the Port of St. Thomas, U.S. Virgin 

Islands (as of 2004, the most recently-available year) (EPA, 2007a). According to the mapping feature of 

the National TMDL database, the water body segments that comprise the Port of St. Thomas include: 

Hassel Island at Haulover Cut to Regis Point and Sprat Bay (EPA, 2007a)

4.2.9 Seattle, WA

EPA’s National TMDL database lists total PAHs, pH, total PCBs, and fecal coliform as the pollutants in 

exceedance of water quality standards in the waters in and around the Port of Seattle (as of 2002, the most 

recently-available year) (EPA, 2007a). 

In the Coastal Condition Report, the Puget Sound NEP is given an overall ‘fair’ rating8. The water 

quality index is ‘fair’, with DIN and DO concentrations rated ‘good’, chlorophyll a and DIP levels rated 

‘fair’, and water clarity classified as ‘poor’. ‘Poor’ sediment toxicity measurements have resulted in a 

‘poor’ overall sediment quality rating, despite a ‘good’ rating for TOC levels. Benthic health was given a 

8 Both Seattle, WA and Tacoma, WA are located on Puget Sound. Therefore, the estuarine conditions (based on the 

Coastal Condition report data) described for Seattle also apply to Tacoma (Section 4.2.17).
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‘good’ rating and fish tissue contamination was rated as ‘fair’, with 14% of the fish having contaminant 

levels greater than EPA advisory levels (and the most frequently detected contaminant being PCBs) 

(EPA, 2007b).

4.2.10 New Orleans, LA

EPA’s National TMDL database lists fecal coliform as the pollutant in exceedance of water quality 

standards in the waters in and around the Port of New Orleans (as of 2002, the most recently-available 

year) (EPA, 2007a). 

4.2.11 Charleston, SC

EPA’s National TMDL database does not list any water quality exceedances in and around the Port of 

Charleston (EPA, 2007a). 

4.2.12 Baltimore, MD

EPA’s National TMDL database lists PCBs, zinc, and chromium as the pollutants in exceedance of water 

quality standards in and around the Port of Baltimore (as of 2004, the most recently-available year)(EPA, 

2007a). In addition, Middle Chesapeake Bay (through which vessels must pass en route to the Port of 

Baltimore) has water quality exceedances for nutrients. According to the mapping feature of the National 

TMDL database, the water body segments that comprise the Port of Baltimore include: Curtis Bay, Bear 

Creek, Southern Branch Elizabeth River, Eastern Branch Elizabeth River, and Indian River (EPA, 2007a)

4.2.13 Elizabeth River, VA

EPA’s National TMDL database lists phosphorus, fecal coliforms, PCBs, and benthic (unknown) as the 

pollutants in exceedance of water quality standards in the waters in and around the Port of Elizabeth River

(as of 2004, the most recently-available year) (EPA, 2007a). According to the mapping feature of the 

National TMDL database, the water body segments that comprise the Port of Elizabeth River include: 

Western Branch Elizabeth River, Southern Branch Elizabeth River, Eastern Branch Elizabeth River, and 

Indian River (EPA, 2007a)

Dedicated to restoring the health of the river, the Elizabeth River Project9has been studying its condition 

for several years, focusing on the benthic communities and toxic characteristics. Several of their reports 

have been posted on their website. The most recent benthic monitoring report (2005) indicates that, in 

general, benthic species diversity and biomass in the Elizabeth River watershed are below reference 

condition levels while abundance was often above reference condition levels and considered excessive. 

The reports characterizes the water quality of the Elizabeth River as follows: (1) nutrients have a poor 

status indicating high concentration levels, (2) there were improvements in long-term trends in total 

nitrogen levels and inorganic nitrogen levels, and (3) there were widespread improvements in long-term 

trends in total phosphorus levels. Nitrogen levels are highest in the Southern Branch with smaller 

differences between the branches of the river for phosphorus levels. Chlorophyll levels are good in both 

the Eastern Branch and Southern Branch in spite of high nutrient levels and good water clarity. 

Chlorophyll levels are fair in the Western Branch with an improving long-term trend. Bottom dissolved 

oxygen levels are fair to good in all branches (Dauer, 2006).

4.2.14 Oakland, CA

EPA’s National TMDL database lists chlordane, DDT, diazinon, dieldrin, dioxins, exotic species, 

mercury, PCBs, and selenium as the pollutants in exceedance of water quality standards in the waters in 

and around the Port of Oakland (as of 2002, the most recently-available year) (EPA, 2007a). 

9 www.elizabethriver.org 
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The Port of Oakland is located within the San Francisco Bay NEP and, therefore, is included in the 2007 

Coastal Condition report (EPA, 2007b). The overall condition of the NEP is rated as ‘fair’, with water 

quality in general classified as ‘fair’ to ‘poor’, with approximately 73% of the estuary rated ‘fair’ and 

20% rated ‘poor’. Chlorophyll a and DO concentrations were ‘good’ in 90% and 99% of the estuary, 

respectively. DIN levels were ‘fair’, while both DIP and water clarity were rated ‘poor’. The sediment in 

the estuary is in very good condition, with 100% of the estuary rated ‘good’ for sediment toxicity and 

96% rated ‘good’ for TOC levels. Benthic invertebrate communities are in ‘good’ condition, while fish 

tissue contaminants are rated ‘poor’, with 58% of fish caught exceeding EPA’s guidance values.

4.2.15 Bayou Lafourche, LA

EPA’s National TMDL database lists DO, nutrients, total coliform, and fecal coliform as the pollutants in 

exceedance of water quality standards in the waters in and around Bayou LaFourche (as of 2004, the most 

recently-available year) (EPA, 2007a). 

Currently, the state of Louisiana and the Louisiana Department of Natural Resources is studying a 

potential reintroduction of Mississippi River water into Bayou Lafourche. A water quality monitoring 

report was developed in February 2006 in which data collected in support of a hydrodynamic model were 

published. Data were collected via 18 permanent platforms installed along the bayou which were in data 

collection mode from February 2004 until January 2005. Parameters that were collected included 

temperature, specific conductance, water surface elevation (depth), salinity, and stream velocity, 

direction, and speed. Data from this project are available online.10

4.2.16 Galveston, TX

EPA’s National TMDL database lists bacteria as the pollutant in exceedance of water quality standards in 

the waters in and around the Port of Galveston (as of 2004, the most recently-available year) (EPA, 

2007a). 

The general condition of the waters surrounding the port of Galveston is described in the Section 4.2.1 

discussion of Houston. However, the Galveston NEP published a State of the Bay report in 200211 that 

described the water quality data and trends in the estuary. Generally speaking, concentrations of 

ammonia-nitrogen and total phosphorus have been occurring over the past three decades. Nitrate-nitrite 

data for the 1990s did not exhibit an upward or downward trend, but did indicate seasonal peaks in 

concentrations. Chlorophyll a levels have been declining over the past two decades and have reached 

25% of their 1975 values. Dissolved metals have declined in the Houston Ship Channel over the last ten 

years, although organic contamination in the Channel from spillage of petroleum products is substantial

(Galveston Bay Estuary Program, 2002).

4.2.17 Tacoma, WA

EPA’s National TMDL database lists total PCBs, bis(2-ethylhexyl) phthalate, DDT, PAHs, and pesticides

as the pollutants in exceedance of water quality standards in the waters in and around the Port of Tacoma 

(as of 2002, the most recently-available year) (EPA, 2007a). 

The Port of Tacoma is located on Puget Sound. Refer to the Section 4.2.9 discussion on Seattle for more 

information on the overall ecosystem health of the waters surrounding this port, according to EPA’s 2007 

Coastal Condition Report.

10 http://www.bayoulafourche.org/default.asp?id=64

11 http://gbic.tamug.edu/sobdoc/sob2/sob2page.html
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4.2.18 Jacksonville, FL

EPA’s National TMDL database lists coliforms, nutrients, total suspended solids, and turbidity as the 

pollutants in exceedance of water quality standards in the waters in and around the Port of Jacksonville 

(as of 2002, the most recently-available year) (EPA, 2007a). 

4.2.19 South Louisiana, LA

The Port of South Louisiana is comprised of facilities along 54 miles of the Mississippi River in St. 

James, St. Charles, and St. John parishes. EPA’s National TMDL database lists fecal coliform as the 

pollutant in exceedance of water quality standards in the waters in and around the Port of South Louisiana 

(as of 2002, the most recently-available year) (EPA, 2007a). 

5.0 DISCHARGE FINDINGS

5.1 Discharges Incidental to the Normal Operation of a Vessel

As described in Section 2.5, the vast majority of information on discharges originating from vessels came 

from the UNDS reports on discharges from Armed Forces vessels. One of the products from Phase I was 

a list of the 25 Armed Forces vessel discharges that should require a MPCD. EPA and DoD also 

identified 14 additional discharges that they determined would not require an MPCD when discharged 

from an Armed Forces vessel, based on the nature of the discharge, the environmental effects, and the 

economic costs and practicability of a MPCD for an Armed Forces vessel. In the following sections, 

Battelle has included information on the group of 25 Phase I discharges that should require an MPCD, 

except for one: Catapult Water Brake Tank and Post-Launch Retraction Exhaust. A catapult is the 

mechanism used to help launch aircraft from a carrier and aircraft carriers are exclusively used by the 

military. The 24 UNDS Phase I discharges that should require an MPCD are listed in Table 5-1, along 

with a brief description.

On June 21, 2007, the EPA published an Advanced Notice of Proposed Rulemaking (ANPRM) in the 

Federal Register (Vol. 72, No. 119, p. 34241) providing background information on the pending NPDES 

permitting program. The ANPRM requested that commentors provide information or data sources that 

might help the EPA better comprehend the universe of vessels and discharges that will be affected by the 

new permitting scheme. Six commentors provided specific lists and/or descriptions of discharges that 

were relevant to certain types of vessels:

· Liberty Maritime Corporation (LMC): a civilian company that transports military and food aid 

cargo for the U.S. government

· Crowley Maritime Corporation (CMC): operates a fleet of vessels, including roll on-roll off, lift 

on-lift off, tankers, tugs, and barges.

· World Shipping Council (WSC): a trade association that represents all types of ocean carriers.

· Cruise Lines International Association (CLIA): represents the interests of 24 cruise line 

companies.

· Pacific Seafood Processors Association (PSPA): represents floating seafood processing vessels.

· American Waterways Operators (AWO): a national trade association for the inland and coastal 

tugboat, towboat, and barge industry.

Several of these commentors stated that some UNDS vessel discharges that had not been included in the 

first draft of this report (i.e., that did not require an MPCD when discharged from an Armed Forces 

vessel) were relevant to specific types of civilian vessels. In light of this new information, these additional 

discharges are listed in Table 5-2 and more detailed descriptions are included in the sections below. 
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Table 5-1. Phase I UNDS Armed Forces Vessel Discharges Requiring an MPCD.

Armed Forces Vessel 

Discharge Description

Aqueous Film-Forming Foam

Fire-fighting agent used for flammable liquid fires on vessels. A concentrated 

liquid mixed with ambient water to form a solution which is discharged during 

planned maintenance and inspections.

Chain Locker Effluent

Ambient water 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

Ambient water that is transferred into and out of dedicated tanks to adjust a 

surface ship’s draft and to improve stability under various operating conditions. 

The discharge is generated when the ballast is no longer required and the tanks 

are partially or completely emptied.

Compensated Fuel Ballast

Ambient water 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 ambient water 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 ambient water 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

Ambient water that is occasionally pumped into empty fuel tanks for the specific 

purpose of improving ship stability. Before taking on ambient water, 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 ambient water. 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 bilge water.

Firemain Systems

Ambient water 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.

Grey Water 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

Ambient water used to compensate for expended motor gasoline (MOGAS) used 

to operate equipment stored on some vessels. MOGAS is stored in a 

compensating tank system to which ambient water is added to fuel tanks as fuel 

is consumed. The discharge occurs as a result of refueling when the displaced 

water is discharged overboard.
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Table 5–1. Phase I UNDS Armed Forces Vessel Discharges Requiring an MPCD, continued.

Armed Forces Vessel 

Discharge Description

Non-Oily Machinery 

Wastewater

Generated from the operation of distilling plants, water chillers, low- and highpressure 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 bilge water, 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, fixerbath 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

Ambient water injected into the exhaust of small boat engines for cooling and to 

quiet operation. Exhaust gas constituents are entrained in the injected ambient 

water and discharged overboard as wet exhaust.

Sonar Dome Discharge

Some domes that house detection, navigation, and ranging equipment are filled 

with ambient water 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 Bilge water

Sources of bilge water 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 Bilge water/OilWater Separator Discharge

Sources include condensate from steam systems, boiler blowdowns, water 

fountains, and machinery space sinks that drain to the bilge. Bilge water is either 

held for shore-side 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, nondestructive testing, masker belt repairs, and painting operations.

Welldeck Discharges

Water and residuals from precipitation, equipment and vehicle washdowns, 

washing gas turbine engines, grey water from stored landing craft, and general 

washdowns of welldecks and vehicle storage areas.

Source: EPA, 1999a.

Table 5-2. Phase I UNDS Armed Forces Vessel Discharges Not Requiring an MPCD.

Armed Forces Vessel 

Discharge Description

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

treatment chemical concentrations from accumulating.

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.
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Table 5–2. Phase I UNDS Armed Forces Vessel Discharges Not Requiring an MPCD, continued.

Armed Forces Vessel 

Discharge Description

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.

Source: EPA, 1999a

Some of these discharges listed in Tables 5-1 and 5-2 are more likely than others to be found on civilian 

commercial and recreational vessels. Given the range of sizes and types of vessels that will potentially be 

affected by the pending vessel vacatur, the entire scope of discharges incidental to the normal operation of 

a vessel that could potentially be discharged by a vessel to U.S. navigable waters were included here.

As stated in Section 2.5.1, some of the UNDS-identified discharges had detailed reports available that 

included extensive information on the discharge characteristics, while others had only summary reports 

with less detailed information. Each of the discharges is described briefly below. A caveat to this 

information that bears repeating is that the discharge information provided by EPA and DoD relates to 

Armed Forces vessels. If data on discharge rates or concentrations were available and are included in this 

section, they apply specifically to the type(s) of Armed Forces vessel(s) discussed in the UNDS reports. 

In a similar vein, Battelle’s ability to associate discharges to particular civilian vessel types was limited, 

given the specific applicability of the UNDS reports to Armed Forces vessels. Some discharges can be 

easily connected to certain types of vessels while other discharges may or may not apply to any number of 

vessels. Deck runoff, for instance, will be a factor for virtually all commercial and recreational vessels, 

whereas elevator pit effluent will not be a discharge for vessels without elevators (i.e., smaller 

recreational vessels). With these caveats in place, the following sections describe each of the discharges.

5.1.1 Aqueous Film Forming Foam (AFFF)

The information on aqueous film forming foam (AFFF) was obtained from EPA (1999b) and five

comments12 on EPA’s ANPRM.

Discharge Summary

AFFF is a synthetic firefighting agent used aboard USCG and Navy vessels and possibly civilian vessels. 

Consisting of fluorosurfactants and/or fluoroproteins, AFFF can extinguish as well as prevent fires by 

forming an oxygen-excluding barrier over the area. AFFF concentrate is mixed with ambient water to 

form a 6% dilution and is never discharged from a vessel in its undiluted form. The discharge of AFFF, 

as discussed in this section, refers to the direct overboard discharging of the AFFF system. Some 

maintenance, inspection, and training activities may result in AFFF accumulating on the vessel deck; in 

these cases, the AFFF becomes a part of other discharges, such as deck runoff, chain locker effluent, 

elevator pit effluent, or bilge water.

12 These comments included EPA-HQ-OW-2007-0483-0619 (AWO), EPA-HQ-OW-2007-0483-1177 (LMC), EPAHQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), EPA-HQ-OW-2007-0483-1498 (WSC).
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AWO, CMC, WSC, and the CLIA all cited AFFF as a potential discharge from some of their vessels. 

AWO specifically stated that some of their towing vessels are equipped with AFFF systems, especially 

those transporting flammable liquid cargo. They also stated that maintenance, testing, and training 

activities lead to AFFF being either discharged directly overboard or discharged onto the deck and then 

subsequently washed overboard. CMC stated that commercial vessels are required by international and 

U.S. law to test AFFF systems periodically, although no specific law was cited. They also stated that 

AFFF is discharged from all commercial vessel types, including unmanned barges. A comment by LMC

stated that they do not conduct firefighting training using foam in U.S. waters.

When and Where Discharge Occurs

Discharge of AFFF can occur during planned maintenance and inspection activities that, on Armed 

Forces vessels, take place on an annual or semi-annual basis. On Armed Forces vessels, these 

maintenance and inspection activities occur by discharging the AFFF hose over the vessel’s side. 

Following these maintenance and inspection activities, any AFFF on the vessel deck is washed down with 

the firemain and becomes a part of other vessel discharges. Maintenance discharges can only occur when 

the Armed Forces vessel is outside territorial waters (i.e., 12 nautical miles [nmi]). Discharges due to 

inspections and certifications can occur anywhere, unless the AFFF has been washed into the vessel’s 

bilge tank, which cannot be discharged within 12 nm. Civilian vessels may have different self-imposed 

restrictions for direct AFFF discharge.

Unless equipped with a fixed extinguishing system that must be tested, recreational vessels will not have 

this discharge. When used to fight fires on either commercial or recreational vessels, fire-fighting foam is 

not considered a discharge incidental to the normal operation of a vessel.

In their comments to the EPA’s ANPRM, CLIA stated that AFFF discharge occurs whenever testing and 

maintenance activities are scheduled, which happen as often as needed to maintain fire fighting systems, 

and to ensure crew proficiency and vessel safety. However, they also state that these discharges typically 

occur outside of 12 nmi from land.

Discharge Rates, Concentrations, and Constituents

Along with the ingredients in the AFFF itself, the discharge will contain the constituents of the firemain 

water and the AFFF piping. The specific ingredients of the AFFF concentrate will vary by manufacturer. 

EPA (1999b) lists constituents, although they are specific to the brand of concentrate used by the Armed 

Forces and are not necessarily relevant to civilian vessels. These constituents include: water (which 

makes up 80% of the ingredients by weight), 2-(2-butoxyethoxy)-ethanol, urea, alkyl sulfate salts (2 in 

number), amphoteric fluoroalkylamide derivative, perfluoroalkyl sulfonate salts (5), triethanolamine, and 

methyl-1H-benzotriazole. As discussed in Section 5.1.10, constituents of the firemain water in Armed 

Forces vessels may include residue from the copper-nickel alloy pipes. AFFF piping in Armed Forces 

vessels is also constructed of copper-nickel alloy; therefore, perfluoroalkyl sulfonate salts, total nitrogen, 

bis(2-ethylhexyl) phthalate, copper, nickel, sulfides, and iron may be discharge constituents. The results 

of sampling by EPA and DoD indicated that each of these pollutants exceeded the most stringent state 

water quality standards in the U.S.13 Ambient water from the firemain system has little potential for

harboring invasive species.

5.1.2 Boiler Blowdown

The information on boiler blowdown was obtained from EPA (1999c) and from four comments on EPA’s 

ANPRM14

13 EPA and DoD used state water quality standards to evaluate discharge constituents and compared the sampling 

results (when available) to the state with the most stringent standards for a given constituent.

14 These comments included EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPAHQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).
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Discharge Summary

For steam-powered vessels, onboard boiler systems must be supplied with feedwater to maintain the 

water level. On some Armed Forces vessels, a treatment is added to the feedwater to prevent corrosion 

and minimize scale formation in the boiler system. As the feedwater is boiled to produce steam, the 

concentration of particulates and chemicals (from the added treatment) increases in the feedwater 

remaining to be boiled. Boiler systems must periodically undergo a ‘blowdown’ to control the treatment 

concentrations and to remove accumulated sludge. A blowdown involves releasing the water from the 

boiler and from the ship altogether, into the ambient water through hull fittings below the waterline. 

Different types of blowdowns release different percentages of boiler water, but, typically, blowdowns 

remove between 1% and 10% of the total volume of water in the boiler. The UNDS report indicates that 

the volume of this discharge from Armed Forces vessels is rarely greater than 310 gallons and that the 

discharge is ejected from the vessel at high pressures (up to 1200 psi) and high temperatures (above 

325°F). Boiler blowdown discharge can originate from any vessel with steam propulsion or a steam 

generator. 

Comments submitted in response to the ANPRM indicated that boiler blowdown is a discharge associated 

with some types of civilian vessels. LMC, a civilian company that transports military and food aid cargo 

for the U.S. government, cited boiler blowdown as one of the discharges incidental to the operation of its 

vessels. CMC operates a fleet of vessels, including roll on-roll off, lift on-lift off, tankers, tugs, and 

barges. Their comment indicated that boiler blowdown was a relevant discharge for their fleet, although 

they did not specify which types of vessels. The WSC is a trade association that represents all types of 

ocean carriers and boiler blowdown was included in a non-annotated list of discharges relevant to their 

industry. Finally, the CLIA, which represents the interests of 24 cruise line companies, cited 

“boiler/economizer washdown waste” as a discharge relevant to cruise ships. A definition provided with 

their comment indicates that this discharge is equivalent to boiler blowdown.

When and Where Discharge Occurs

The UNDS report states that the frequency of boiler blowdown is dependent on the needs of the particular 

boiler system. Therefore, this discharge can occur whenever and wherever necessary to maintain the 

boiler system. In their comment, CLIA stated that, on cruise ships, boiler blowdowns occur as needed to 

maintain performance, which is typically on a weekly or monthly basis. However, they indicated that this 

discharge is nearly always done while underway and as far from land as practicable. 

Discharge Rates, Concentrations, and Constituents

The constituents of boiler blowdown discharge will be dependent on the type(s) of anti-scaling and anticorrosion treatment originally added to the feedwater. Numerous constituents found in boiler blowdown 

discharges from Armed Forces vessels were defined as priority pollutants by the EPA: antimony, arsenic, 

cadmium, copper, chromium, lead, nickel, selenium, thallium, zinc, and bis(2-ethylhexyl) phthalate. 

Other detected constituents are listed in Table 3 of the UNDS report (EPA, 1999c). 

Thermal modeling using Armed Forces vessel specifications and described in the UNDS report showed 

that the high temperatures of the boiler blowdown discharge did not exceed the thermal mixing zone 

criteria of Virginia and Washington State, the only two U.S. states with such standards.

5.1.3 Cathodic Protection

The information on cathodic protection was obtained from EPA (1999d) and from three comments on

EPA’s ANPRM15.

15 These comments included EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and 

EPA-HQ-OW-2007-0483-1498 (WSC).
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Discharge Summary

According to the UNDS report on this discharge, nearly all Armed Forces vessels use cathodic protection 

systems (usually in conjunction with corrosion-resistant coatings) to prevent steel hull or metal 

underwater structure corrosion. Vessels with hulls made of fiberglass, wood, aluminum, or other nonferrous material do not require cathodic protection systems. Two types of cathodic protection are most 

common on Armed Forces vessels: sacrificial anodes and Impressed Current Cathodic Protection (ICCP)-

based systems. Sacrificial anodes are physically connected to an underwater vessel structure or 

component (which acts as the cathode). The anode is preferentially corroded (or ‘sacrificed’) which, via 

the electrolytic properties of seawater, produces a flow of electrons to the cathode, thereby preventing the 

cathode from corroding. Sacrificial anodes are used on most Armed Forces vessels, particularly those 

with mandatory dry-dock inspection or overhaul intervals of less than three years. When immersed, the 

anodes continue to corrode and have to be maintained and routinely replaced; zinc anodes need to be 

replaced at least every six years. Anodes can also be constructed of aluminum. The ICCP-based 

mechanism of protection is identical to sacrificial anodes, except ICCP systems use direct current (DC) 

from a source within the vessel in lieu of current supplied from anodes. 

According to comments submitted in response to EPA’s ANPRM, cathodic protection system discharge 

can originate from civilian vessels. CLIA, the WSC, and CMC all cited cathode protection discharge as 

relevant to the types of vessels they represent in their ANPRM comments. 

When and Where Discharge Occurs

For vessels equipped with sacrificial anodes, the discharge occurs continuously whenever the vessel’s hull 

is submerged. The comment submitted by CLIA also stated that this discharge occurs continuously

Discharge Rates, Concentrations, and Constituents

Ionized zinc or aluminum can be released into the surrounding water column as sacrificial anodes are 

consumed by corrosion. At the cathode, the water is reduced, forming hydroxyl ions which can form zinc 

or aluminum hydroxide if enough oxygen is present in the water. ICCP systems can generate chlorineproduced oxidants (CPOs), but the specific types will vary according to the specific chemistry or the 

surrounding water. These oxidants can include hypochlorous and hypobromous acids, hypochlorite and 

hypobromite, chloro- and bromo-organics, chloride, bromide, chloramines, and bromamines. Utilizing a 

tidal prism modeling approach, the receiving water concentrations of zinc and CPOs were estimated and 

none of the concentrations were found to exceed the most stringent state water quality standards. 

5.1.4 Chain Locker Effluent

The information on chain locker effluent was obtained from EPA (1999e) and from four comments16 on 

EPA’s ANPRM.

Discharge Summary

Armed Forces vessels, along with other civilian vessels, store their anchor chain(s) in a below deck 

compartment (chain locker) when not in use. In the locker, the chain rests on a grate below which is a 

sump that collects liquids and materials that enter the chain locker via rain and green water17. Most large

surface vessels have at least one chain locker (EPA, 2003a). Chain locker effluent is generated during 

anchor retrieval (which, according to CLIA’s comment, occurs weekly) or during storm events, when 

water may wash over the deck of a vessel. The sump in the chain locker is emptied either directly 

overboard (with assistance from firemain water) or is drained into the bilge tank for later disposal.

16 These comments included EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPAHQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).

17 Green water refers to fresh or salt water that washes over the deck of a vessel from wave action.
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LMC, CMC, WSC, and CLIA all cited chain locker effluent as a discharge relevant to their types of 

vessels. CLIA further states that this is a discharge on all the vessels they represent. 

When and Where Discharge Occurs

Navy vessels do not directly discharge chain locker effluent within 12 nmi of shore. Civilian vessels may 

have different self-imposed restrictions for direct chain locker effluent discharge. 

Discharge Rates, Concentrations, and Constituents

Chain locker effluent has the potential to contain marine organisms, which may have been introduced into 

the sump from the anchor and chain, through the firemain system, or via green water. However, the Navy

practice of washing down the anchor and chain as they are retrieved and the 12 nmi discharge limit makes 

the introduction of invasive species from chain locker effluent unlikely. Similar practices by civilian 

vessels will help prevent species introduction. Other constituents can include residue from materials used 

in the chain locker, such as rust, paint chips, grease, and zinc, as well as residue from copper-nickel alloy 

firemain pipes. The actual materials used in the construction of the chain locker or firemain pipes will 

vary for civilian vessels.

Discharge concentrations and annual mass loadings for chain locker effluent were not calculated for the 

UNDS report due to the expected minimal amount of discharge and the 12 nmi discharge limit followed 

by Armed Forces vessels.

5.1.5 Clean Ballast

The information on clean ballast was obtained from EPA (1999f) and from six comments18 on EPA’s 

ANPRM.

Discharge Summary

Clean ballast is water that is taken onboard to assist with vessel draft, buoyancy, and stability and stored 

in dedicated ballast tanks that have never contained anything but ballast water (as opposed to 

Compensated Fuel Ballast and Dirty Ballast). Clean ballast tanks (sometimes called segregated ballast 

tanks [SBT]) can be filled from the firemain or by ballast pumps that take in ambient water. Large 

commercial vessels (e.g., cargo, tankers, ro-ro, passenger) typically have ballast tanks, although they may 

not have clean ballast tanks. Under recent amendments to MARPOL 73/78 (Regulation 13G), all tankers 

must now have SBT configurations or be double-hulled. SBT arrangements are associated with smaller 

volume oil spills because the oil is carried in multiple tanks. According to the National Academy of 

Sciences (NAS) (2003), approximately two-thirds of the worldwide tanker fleet (crude and product) uses 

SBT, although this number has likely increased since that source’s publication. 

Recreational boats typically do not have ballast water tanks. However, boats used for wakeboarding are 

now being marketed with ballast tanks (e.g., Centurion Boats, Correct Craft) or existing boats can be 

retrofitted with expandable, portable ballast tanks (e.g., BoardStop). Normally, these tanks are filled and 

emptied with the same source water.

Comments submitted in response to EPA’s ANPRM indicate that clean ballast discharge is relevant to 

several different types of vessels. LMC, WSC, and CMC all specifically cited clean ballast as their 

discharge. In their comment, American Waterway Operators stated that their towing vessels are ballasted 

for stability and trim and that a large number of their towing vessels are only ballasted with water from 

municipal or commercial sources, except in emergencies. They also stated that tank barges are purposely 

ballasted for a variety of reasons, including to maintain proper trim during loading and unloading 

18 These comments included EPA-HQ-OW-2007-0483-0619 (AWO), EPA-HQ-OW-2007-0483-1168 (PSPA), 

EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 

(CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).
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operations, to improve tow configurations, and to permit passage underneath obstructions such as bridges. 

However, tank barges taking up ballast while at sea for trim purposes is very rare and, when this must 

occur, the ballast taken onboard is kept to a minimum. Because the crew of a tank barge must transit 

from the tugboat to the barge to perform ballasting or deballasting operations, operators will retain ballast 

onboard whenever feasible. If there is an emergency, the operator will only release enough ballast to 

continue with safe operations. 

PSPA cited ballast water as a relevant discharge for the vessels they represent, but it was not specified 

that clean ballast tanks were used.

When and Where Discharge Occurs

Armed Forces vessels cannot discharge ballast water within 12 nmi of shore and must perform at least 

two exchanges prior to entering the 12 nmi zone. 

AWO commented that ballasting and deballasting operations on their towing vessels are conducted during 

major shipyard maintenance and to replace spent fuel (which is stored in separate tanks) to retain vessel 

stability. They also stated that coastal tugboats discharge their ballast water outside the demarcation 

line19 whenever possible or retained it onboard for disposal at a shore-side facility. For their tank vessels, 

AWO stated that ballast is frequently taken on and discharged in the same location.

CLIA also cited ballast water as a relevant discharge for the vessels they represent, although they do not 

specify whether the ballast tanks are ‘clean’. They stated that ballast water is discharged as needed to 

ensure the safety of the ship, which, typically, is several times per week.

Discharge Rates, Concentrations, and Constituents

Ballast water discharged from clean ballast tanks may contain marine organisms as well as material from 

inside the tank, piping, or other machinery. Ballast tanks filled via the firemain may contain residue from 

the firemain pipes. The actual materials and contents used in civilian ballast tanks will vary. Some 

possible constituents may include rust inhibitors, flocculant compounds, epoxy coating materials, zinc or 

aluminum (from anodes), iron, nickel, copper, bronze, and silver. Accumulated sediments from the 

bottom of the tank may also be discharged. 

The discharge rate and constituent concentrations of clean ballast water from civilian vessels will vary by 

vessel type, ballast tank capacity, and type of deballasting equipment. According to a study published by 

the Bluewater Network (Maddison, 2006), typical cruise ships have a ballast capacity of approximately 

1,000 metric tons and have a ballast discharge rate of between 250-300 metric tons per hour. The Prince 

William Sound Regional Citizens’ Advisory Council estimates that oil tankers can carry between 

5.1.6 Compensated Fuel Ballast

The information on compensated fuel ballast was obtained from EPA (1999g).

Discharge Summary

Some vessels have a series of connected ballast tanks that store fuel and, as the fuel is consumed, water is 

introduced to the same tanks via the firemain to ‘compensate’ for the lost weight of the spent fuel. The 

water fills in the spaces vacated by the fuel. Then, as the vessel is refueled, the fuel, being denser, 

‘pushes’ the ambient water back through the tanks. At the end is an overflow/ expansion tank with an 

overboard discharge pipe; this expansion tank always contains ambient water and prevents fuel from 

being accidentally discharged into open waters if the fuel tanks are overfilled. Compensated fuel ballast 

tanks are only completely emptied during maintenance activities. 

19 This ‘demarcation line’ is not further defined in the comment.
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It is notable that none of the commentors that listed the relevant discharges for their vessel types cited 

compensated fuel ballast.

When and Where Discharge Occurs

Discharge of compensated fuel ballast water may occur through the overflow/expansion tank during 

refueling, which can occur while the vessel is at port or at sea. For Armed Forces vessels, at sea refueling 

occurs only outside the 12 nmi limit. Civilian vessels may have different refueling policies. 

Discharge Rates, Concentrations, and Constituents

Studies on Armed Forces vessels have detected oil in compensated fuel ballast discharge in 

concentrations ranging from below detection level to 370 milligrams per liter (mg/L). Other research has 

tested discharges for a suite of parameters and discovered copper, nickel, silver, thallium, zinc, benzene, 

phenol, and toluene were present in measurable amounts. Mercury, total petroleum hydrocarbons (TPH), 

and hexane extractable material (HEM) (which corresponds to the amount of oil and grease present) were 

also detected. Research conducted by EPA and DoD determined that several constituents detected in 

compensated fuel ballast exceeded the most stringent state water quality standards: ammonia, 

nitrate/nitrite, HEM, total phosphorus, mercury, copper, nickel, silver, thallium, zinc, 2-propenal, and 

benzene. According to EPA (1999g), invasive species are not likely to be introduced during refueling 

operations.

For Armed Forces vessels, compensated fuel ballast is discharged at a rate of up to 400 gallons per minute 

(gpm) per ballast tank group (maximum of 2,400 gpm per vessel) during at port refueling operations, 

which take place approximately twice a year. Civilian vessels with compensated ballast tanks will have a 

variety of discharge rates, dependant on vessel size and type. 

5.1.7 Controllable Pitch Propeller Hydraulic Fluid

The information on controllable pitch propeller hydraulic fluid was obtained from EPA (1999h) and two 

comments20 on EPA’s ANPRM.

Discharge Summary

Controllable pitch propellers (CPPs) are variably-pitched propeller blades that can change the speed or 

direction of a vessel without requiring the vessel’s main propulsion system to change speed or direction. 

Hydraulic control oil is provided to each CPP hub, which is surrounded by seals meant to keep the oil 

from coming into contact with the surrounding water. Many civilian ocean-going vessels may use CPP 

technology.

Two commenter’s on EPA’s ANPRM cited controllable pitch propeller hydraulic fluid as a relevant 

discharge for the vessels they represent.

When and Where Discharge Occurs

Hydraulic oil can leak past the CPP’s protective seals (if they are worn or defective). These leaks can 

occur at any time, while the vessel is at port or underway in open water, although they are more likely 

while the vessel is underway since the seals are under higher pressure. Regular maintenance activities on 

the CPP system, which can occur portside, can also cause oil discharge.

In their comment, CMC stated that controllable pitch propeller maintenance activities on the vessels they 

represent is typically done while the vessel is in dry-dock. When dry-docking is not an option, then 

maintenance will occur pierside. 

20 These comments included: EPA-HQ-OW-2007-0483-1248 (CMC) and EPA-HQ-OW-2007-0483-1498 (WSC).
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Discharge Rates, Concentrations, and Constituents

Constituents of the hydraulic oil will vary by manufacturer. Other potential discharge constituents 

include copper, tin, aluminum, nickel, and lead from the piping, hub, and propeller.

Oil leaks from around defective or worn seals are believed to be negligible. During maintenance 

activities, small amounts of oil may be discharged. EPA (1999h) estimates that approximately 20 ounces 

of oil may be released for every CPP blade that is replaced (the Armed Forces estimates there are about 

30 blade replacements annually). When the blade replacement includes removal of the blade port cover 

(during about seven of the 30 instances), a worst case scenario of five gallons of oil may be discharged. 

5.1.8 Deck Runoff

The information on deck runoff was obtained from EPA (1999i) and six comments21 on EPA’s ANPRM.

Discharge Summary

The majority of vessel deck runoff is attributable to precipitation, although deck washdowns and green 

water washover can also contribute. All vessels, regardless of size or type, discharge some amount of 

deck runoff. 

Comments submitted in response to EPA’s ANPRM by WSC, LMC, and CMC cited deck runoff as a 

relevant discharge from the vessels they represent. In their comment, CLIA stated that deck runoff from 

the vessels they represent may include detergent or soap residue left behind from deck or window 

cleaning. Deck runoff discharge will occur upon a rain event or during weekly (or more frequently, as 

needed) deck washdowns. AWO stated that, on their towing vessels, rain water is allowed to freely and 

quickly run off the decks. Accumulated water on decks can create problems for vessel stability and make 

deck surfaces slippery, compromising the safety of the crew. Tank barges also generate deck runoff, 

although AWO’ comment states that an increasing number of tank barges are being fitted with perimeter 

spill rails and/or drip pans. These technologies are further described in Section 6.6. Finally, the same 

commentor stated that deck and hopper barges also generate deck runoff and rain water that collects in 

open, but contained areas22 is pumped periodically into waterways. AWO also listed wash water as a 

separate discharge on their towing vessels. According to the comment, towing vessels periodically have 

their topsides washed down with potable water (or clean ambient water) and biodegradable and 

phosphate-free detergent. 

PSPA listed rain, snow, ice, waves, water from fishing gear brought onboard, and deck washdown water 

as the types of deck runoff that may be relevant to the vessels they represent.

When and Where Discharge Occurs

Precipitation can occur anywhere at anytime and will instigate deck runoff (unless it is otherwise 

contained). Green water washover can happen virtually anywhere to smaller vessels, whereas larger 

vessels may only experience deck washover while at sea or during extreme weather conditions. Deck 

washdowns are typically done while the vessel is at port or otherwise stationery. 

According to their comment on EPA’s ANPRM, the frequency of AWO water wash discharges vary 

greatly by vessel size and service.

21 These comments included EPA-HQ-OW-2007-0483-0619 (AWO), EPA-HQ-OW-2007-0483-1168 (PSPA), 

EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 

(CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).

22 The comment did not further specify what these ‘open, but contained areas’ were.
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Discharge Rates, Concentrations, and Constituents

Vessel decks can accumulate a variety of residues originating from various on-deck activities. Topside 

machinery and refueling operations may contribute oil and grease to the deck, while general debris (e.g., 

paper, wire, garbage) can also be washed overboard if left unsecured. Spilled oil cargo may be present on 

the decks of some oilers in the Armed Forces. Residue from cleaners and detergents used to wash the 

deck may be present in runoff, as can soot particles (from fuel burning) and AFFF remnants. The specific 

constituents will vary.

Discharge rates for deck runoff vary from vessel to vessel and will depend on the weather as well as the 

frequency of deck washdowns. EPA (1999i) developed a formula to estimate the amount of annual 

precipitation-caused deck runoff from Armed Forces vessels which takes into account the deck surface 

area, annual precipitation, and the number of days a vessel is within 12 nmi of shore. This formula may 

be useful for determining reliable deck runoff rates for vessel vacatur purposes; however, the wide variety 

of formula inputs that would be required may not make using the formula realistic. 

5.1.9 Dirty Ballast

The information on dirty ballast was obtained from EPA (1999j).

Discharge Summary

Dirty ballast tanks are similar to compensated fuel ballast tanks in that the ballast water can come into 

contact with the vessel’s fuel. Unlike compensated fuel ballast, however, dirty ballast is water that is 

pumped from outside the vessel directly into the same tank that once held fuel, once that fuel was been 

spent and space is available. When discharged, the dirty ballast water may contain fuel residuals and 

similar constituents. 

It is notable that none of the commentors that listed the relevant discharges for their vessel types cited 

dirty ballast.

When and Where Discharge Occurs

The policy of the few Armed Forces vessels that still maintain dirty ballast systems is to not discharge the 

dirty ballast water within 12 nmi of shore. 

Discharge Rates, Concentrations, and Constituents

According to EPA (1999j), dirty ballast water constituents are similar to those found in compensated fuel 

ballast water. 

5.1.10 Distillation and Reverse Osmosis Brine

The information on distillation and reverse osmosis brine was obtained from EPA (1999k) and four 

comments23 on EPA’s ANPRM.

Discharge Summary

Some vessels have onboard plants that distill seawater into fresh, potable water or high-purity feedwater. 

The remnants of the distillation process, which can include brine and any residue or constituents from the 

distillation plant itself is typically discharged overboard. Condensate is also produced during the 

distillation process, but this is usually either reused in the boiler system or is collected as non-oil 

machinery wastewater. Anti-scaling treatments as well as acidic cleaning compounds may also be 

injected into the distillation system. Plants that utilize reverse osmosis (RO) produce water of lesser 

purity than distillation, but generate discharges without anti-scaling or cleaning compounds. 

23 These comments included: EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPAHW-OW-2007-0438-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).
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CLIA, LMC, WSC, and CMC all cited distillation and RO brine as a relevant discharge from the vessels 

they represent. CMC also stated that distillation systems are installed on most commercial vessels.

When and Where Discharge Occurs

Distilling plants on steam-propelled vessels operate whenever the vessel’s boilers are operating; therefore, 

distillation and RO brine discharge can occur at any time while the vessel is underway or at port. 

According to EPA (1999k), gas- or diesel-powered Armed Forces vessels rarely operate their distillation 

or RO plants within 12 nmi of shore. However, civilian vessels equipped with these systems have the 

potential to operate them anywhere. 

Discharge Rates, Concentrations, and Constituents

Onboard distillation and RO systems discharge brine, which is essentially concentrated seawater and 

possessive of the same properties and constituents of seawater, including dissolved and suspended solids 

and metals. Distillation plants are manufactured of metal that can be corroded by seawater, particularly at 

the elevated temperatures at which these plants are operated; in Armed Forces vessels, this corrosion 

process could introduce such constituents as copper, chromium, nickel, and zinc to the brine. Plants 

found on civilian vessels may be constructed of various materials that may leach into brine prior to 

discharge. RO plants are not operated at high temperatures and are not expected to release corrosive 

materials to brine. Constituents of anti-scaling compounds utilized by civilian vessels will vary by 

manufacturer, although the Armed Forces compounds consist of such materials as polyacrylates and antifoaming additives. EPA and DoD conducted effluent sampling on a collection of Armed Forces vessels 

and detected that the following constituents (along with copper, nickel, and zinc) exceeded the most 

stringent water quality standards: iron, lead, total nitrogen, and total phosphorus. These materials may or 

may not be present in the discharge from civilian vessels. The brine mixture will also be warmer than 

ambient temperatures, constituting a thermal discharge. Thermal plume modeling (EPA, 1999k) 

indicated that discharge temperatures may reach a maximum of 120°F and, in the two states used in the 

model (Washington and Virginia), the discharge did not exceed thermal mixing zone standards. 

5.1.11 Elevator Pit Effluent

The information on elevator pit effluent was obtained from EPA (1999l) and one comment24 on EPA’s 

ANPRM.

Discharge Summary

Large vessels with multiple decks are equipped with elevators to facilitate the transportation of 

maintenance equipment, people, and cargo between decks. Some vessels may have multiple elevators 

utilized for various purposes. Only elevators that are operated within a shaft will have a pit at the bottom, 

along with a sump to collect materials and liquids that may find their way into the shaft. Much of what 

ends up in the elevator pit and sump is deck runoff along with residue and materials used in elevator 

maintenance and repair. On Armed Forces vessels, waste that accumulates in elevator pits is removed by 

gravity draining, by educting overboard using the firemain, by using a vacuum or sponges to transfer the 

waste for treatment as bilge water or graywater, or by containerizing it for shore disposal. On Armed 

Forces vessels, direct, untreated overboard discharge of elevator pit effluent is rare and, if necessary, 

typically occurs more than 50 nmi from shore and only if the effluent is non-oily. 

The comment on EPA’s ANPRM from WSC simply listed elevator pit effluent as a discharge relevant to 

the vessels they represent.

24 This comment was EPA-HQ-OW-2007-0438-1498 (WSC).
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When and Where Discharge Occurs

While the Armed Forces does not discharge elevator pit effluent within 12 nmi of shore, civilian vessels 

may empty their pits at anytime while underway or pierside. 

Discharge Rates, Concentrations, and Constituents

Elevator pit discharge will have constituents similar to those found in deck runoff and firemain water. On 

Armed Forces vessels, elevator maintenance and repair residues may include lubricants, cleaning 

solvents, soot, and paint chips. Tests conducted by EPA and DoD discovered that some detected 

constituents from elevator pit effluent exceeded the most stringent state water quality standards, including 

total nitrogen, bis(2-ethylhexyl) phthalate, copper, iron, and nickel, all of which are present in deck runoff 

and firemain water.

Determining the rates and concentrations of elevator pit effluent discharge is difficult given the variety of 

types and sizes of Armed Forces and civilian vessels as well as the differences in the elevator 

maintenance frequency. 

5.1.12 Firemain Systems

The information on firemain systems was obtained from EPA (1999m) and four comments25 on EPA’s 

ANPRM.

Discharge Summary

Most vessels have some sort of fire fighting system, whether this consists of individual fire extinguishers, 

as may be found on smaller, recreational vessels, or built-in water- and foam-distribution systems, which 

are more practical on larger vessels. For this latter category, a firemain system uses a sea chest to pump 

ambient water into the vessel, which can then be distributed via fire hose stations, sprinkler systems, or 

AFFF distribution stations. Firemain systems can be ‘wet’ (i.e., water is pressurized and is available on 

demand) or ‘dry’ (i.e., water is unpressurized and not available on demand). Besides fire fighting 

activities, the firemain system can be used for what EPA (1999m) terms ‘secondary services’, which 

include deck and equipment washdowns, machinery cooling water, and ballast tank filling. Other 

activities may require firemain usage on civilian vessels. This section describes only firemain water that 

is discharged directly overboard during maintenance and inspection activities. Discharges that contain 

firemain water from secondary services are described in their respective sections. 

Comments on EPA’s ANPRM from LMC and WSC cited firemain discharges as a relevant discharge 

from the vessels they represent. In their comments, CLIA stated that firemain discharges take place 

during anchor chain washdowns, firemain testing, and various maintenance and training activities. CMC

stated that all of the vessels they represent are equipped with firemain systems. 

When and Where Discharge Occurs

On Armed Forces vessels, firemains are discharged directly overboard during testing and maintenance, 

inspections, training activities, and anchor chain washdown. If water demand is low, the firemain system 

may also produce bypass discharges to prevent the pumps from overheating. Civilian vessels may have 

other activities that cause the firemain to discharge water directly overboard. Other vessel discharges 

may contain firemain water (e.g., ballast discharges, AFFF, chain locker effluent, elevator pit effluent, 

deck runoff, etc.), but these are discussed in their respective sections. 

For Armed Forces vessels, the discharge of water from the firemain system directly overboard typically 

occurs at any time and any place and whenever maintenance, repair, testing, inspection, or training 

25 These comments included: EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPAHW-OW-2007-0438-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).
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activities are occurring. Civilian firemain discharge will occur at a variety of frequencies and locations, 

dependent on the demands of the particular vessel and crew.

CMC stated in their comments that while firemain system discharges may occur both within and beyond 

12 nmi from land, typical operating policies mandate that testing of the system take place only beyond 12 

nm.

Discharge Rates, Concentrations, and Constituents

Firemain water contains a variety of constituents. The firemain pipes found on most Armed Forces 

vessels are constructed of copper, zinc, and nickel, which can be eroded from the system due to high fluid 

velocity or abrasive materials being caught in the flow. Other constituents can include aluminum, tin, 

silver, iron, titanium, and chromium, which can erode from sections of the firemain pumps, valves, and 

sea chests. The firemain systems, and therefore the discharges, on civilian vessels may not contain these 

materials. EPA (1999m) found that (aside from copper, iron, and nickel) bis(2-ethylhexyl) phthalate, 

nitrate/nitrite, and total nitrogen were the constituents that exceeded the most stringent water quality 

standards. Thermal discharge is a risk with Armed Forces firemain systems used for cooling systems. 

Due to the short residence times of water in most firemain systems, NIS introductions are a minimum 

risk. 

Firemain types, configurations, and sizes can vary from vessel to vessel, a fact that is true for Armed 

Forces as well as civilian vessels. The frequency of use also has bearing on the discharge rate. EPA 

(1999m) estimated that firemain systems on USCG vessels are operated an average of 5 minutes a week 

per pump (the USCG is obligated to have at least two pumps per vessel). However, the actual discharge 

rate varies by the flow rate of the pumps, the number of days the vessel is in use, etc. Civilian vessels 

will have an entirely different set of variables to consider when determining rate and concentration values. 

Additionally, the actual type of firemain system has bearing on discharge amounts because continuously 

discharging wet firemain systems will produce more discharge than dry firemain systems.

5.1.13 Freshwater Layup

The information on freshwater layup was obtained from EPA (1999n) and two comments26 to EPA’s 

ANPRM.

Discharge Summary

Seawater cooling systems serve to condense low pressure steam from propulsion plant or generator 

turbines on some vessels. When a vessel is at port or pierside for an extended period of time, the cooling 

systems are not circulated, risking the accumulation of biological growth and reduced system efficiency. 

The freshwater layup process includes removing all seawater from the condensers (using pressurized air) 

and filling the condensers with potable water, where it remains stagnant for two hours before being blown 

overboard, again using pressurized air. Following this flushing process, the condensers are again filled 

with potable water, which remains in the condensers for 21 days before being blown overboard. 

Following this step, the condensers are filled with potable water and emptied on a 30-day cycle until the 

vessel returns to normal operations. 

Civilian vessels with a seawater cooling system will require freshwater layup cycles if they are not 

operated for an extended period. CMC stated in their comments that some of their vessels need to be 

periodically laid up. WSC included freshwater layup as one of the discharges relevant to the vessels they 

represent.

26 These comments included EPA-HQ-OW-2007-0483-1248 (CMC) and EPA-HQ-OW-2007-0483-1498 (WSC).
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When and Where Discharge Occurs

When a vessel is pierside or in port for more than three days, the main steam plant is shut down, the 

condensers are not circulating, and a freshwater layup cycle is required. This discharge will only occur 

while the vessel is in port.

Discharge Rates, Concentrations, and Constituents

Freshwater layup discharge will include the constituents of the potable water along with residual seawater 

and any residue that has leached from the condenser while the water is being held. Potable water may 

contain disinfectants like chlorine or chloramine.

5.1.14 Gas Turbine Water Wash

The information on gas turbine water wash was obtained from EPA (1999o) and one comment27 on 

EPA’s ANPRM.

Discharge Summary

On some vessels, gas turbines are used for propulsion and electricity generation. To maintain efficiency, 

the turbines must occasionally be washed down of the byproducts that can accumulate, including salt, 

lubricants, and combustion residuals. On Armed Forces vessels, a cleaning compound is added to the 

freshwater washdown, although civilian vessel water wash may contain different constituents. Water 

wash discharge may be channeled to a dedicated holding tank for onshore disposal (in which case no 

overboard discharge occurs), or the water may become a component of deck runoff, welldeck discharge, 

or bilge water. 

CLIA was the only commentor that cited gas turbine water wash as a relevant discharge to the vessels 

they represent. However, they stated that not every one of their vessels was equipped to produce this 

discharge, and, of the ones that are so equipped, this discharge is a rare occurrence.

When and Where Discharge Occurs

The location and frequency of gas turbine water wash discharge will vary according to where the used 

water wash is channeled. 

Discharge Rates, Concentrations, and Constituents

Gas turbine water wash discharge will contain constituents of the particular cleaning solvent added to the 

fresh water, which will vary according to manufacturer. The Navy utilizes gas path cleaner which may 

include naphthalene and other hydrocarbon compounds. EPA and DoD found that naphthalene exceeded 

the most stringent state water quality standards. The constituents of cleaners used by civilian vessels will 

vary by manufacturer. 

Rates and concentrations of gas turbine water wash discharge vary according to the frequency of 

washdown. Most Armed Forces vessels have washdowns at least once every 48 hours of operation and 

EPA and DoD estimated that approximately 122 gallons of wash is generated for every turbine washed. 

The gas turbine wash practices for civilian vessels will likely differ.

5.1.15 Grey Water

The information on grey water was obtained from EPA (1999p) and six comments28 on EPA’s ANPRM.

27 This comment was EPA-HQ-OW-2007-0483-1494 (CLIA).

28 These comments included EPA-HQ-OW-2007-0483-0619 (AWO), EPA-HQ-OW-2007-0483-1168 (PSPA), 

EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 

(CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).
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Discharge Summary

Grey water is non-sewage wastewater, including water from showers, baths, sinks, and laundry facilities.

Vessels may collect and store grey water discharge for later disposal or may continuously discharge it.

Grey water discharges occur in any vessel equipped with a kitchen or a bathroom, which can include a 

large scope of vessels from recreational boats to large cruise ships. Since grey water may contain fecal 

coliform, Armed Forces vessels frequently treat it as black water. 

LMC, WSC, PSPA, and CMC all cited grey water (without further comment) as a relevant discharge from 

the vessels they represent. AWO stated that the amount of grey water generated and discharged from a 

towing vessel varies with respect to crew numbers and habits. They stated that grey water from the 

laundry, shower, and kitchen is released directly overboard from towing vessels on a daily basis, although 

the detergents and cleaners used onboard these vessels are biodegradable and phosphate-free.

When and Where Discharge Occurs

Most Armed Forces vessels without a holding tank discharge grey water outside of 3 nmi from shore. 

However, grey water can be discharged while pierside if the vessel is not equipped with an alternative 

collection system. Civilian grey water discharge practices will vary. 

In their comment, CLIA stated that grey water was either discharged untreated from their vessels while 

underway or it was treated as part of an Advanced Wastewater Purification System. No further 

description of this system was provided. 

Discharge Rates, Concentrations, and Constituents

Grey water discharges can contain a variety of constituents, including bacteria, pathogens, oil and grease, 

detergent and soap residue, metals (cadmium, chromium, lead, copper, zinc, silver, nickel, mercury), 

solids, and nutrients. Of these constituents, sampling conducted by EPA and DoD found that ammonia, 

copper, lead, mercury, nickel, silver, and zinc exceeded the most stringent state water quality standards. 

The constituents found in civilian vessel grey water is likely to be similar. 

The volume of grey water generated by a vessel is dependent on the number of passengers and crew. It is 

estimated that 30 – 85 gallons of grey water is generated per person per day (Copeland, 2007). Vessels 

that carry a large number of passengers, such as cruise ships, generate a large volume of grey water, 

which can be 90-95% of all the liquid waste onboard. Large cruise ships can carry thousands of 

passengers. For example, Royal Caribbean’s ship, Vision of the Seas, can carry 3,200 passengers and 

crew generating an estimated volume of 96,000 to 272,000 gallons of grey water per day (Alaska DEC, 

2007). 

According to EPA (1999p), Navy designers use a generation standard of 30 gallons per person per day 

when constructing grey water collection systems. A Bluewater Network report (Schmidt, 2000) stated 

that, on an average one-week journey, a typical cruise ship with 3,000 passengers and crew generates an 

estimated 1,000,000 gallons of grey water. 

The Alaska Cruise Ship Initiative (ASCI) was a federal, state, and local collaborative effort to identify, 

characterize, and manage waste streams from cruise ships plying Alaskan waters. Sampling of large 

cruise ships indicated that the sanitation devices onboard these vessels did not operate effectively. While 

the USCG mandates that the type of sanitation devices installed on these cruise ships must discharge 

effluent of no more than 200 fecal coliforms per 100 mL, sampling results from 2000 showed that the 

effluent coming from grey water discharges had concentrations as high as 32 million fecal coliform per 

100 mL. Surprisingly, the fecal coliform concentration in grey water was twice as high as that detected in 

sewage effluent (black water). 
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5.1.16 Hull Coating Leachate

The information on hull coating leachate was obtained from EPA (1999q) and four comments29 on the 

EPA’s ANPRM. 

Discharge Summary

The hulls of some vessels may be covered with anticorrosive and antifouling coatings to prevent rust and 

marine growth, respectively. The antifouling coating is applied over the anticorrosive coating and the 

latter should not leach into the receiving water, provided the antifouling coating is intact. Only vessels 

that have had their hulls coated in antifouling material are included as contributors to this discharge.

Comments from WSC and LMC on EPA’s ANPRM cited (without further comment) hull coating 

leachate as a relevant discharge from the vessels they represent. CLIA also cited hull coating leachate, 

although they stated that not every one of their vessels generated this discharge. CMC stated that all of 

the vessels they represent use antifouling compounds on their hulls. 

When and Where Discharge Occurs

Hull antifouling coatings will continuously leach into receiving waters whenever the vessel is in water. 

Discharge Rates, Concentrations, and Constituents

Armed Forces vessels use very specific types of antifouling coatings which may not have the same 

constituents as the coatings applied to civilian vessels. However, most vessels use copper- or zinc-based 

antifouling coatings and these metals may leach into receiving waters. 

Although it is no longer found on Armed Forces vessels, some civilian vessels may have tributyltin 

(TBT)-based antifouling hull coatings. While an effective preventative of invasive species introductions, 

TBT is extremely toxic to marine life. 

A Navy study (Navy Research and Development Division, 1997) cited in the UNDS report tested copper 

antifouling paint leaching rates for stationery and underway Naval vessels. The long-term average release 

rates for a vessel cruising at 17 knots were 17 micrograms per square centimeter per day (mg/cm2/day) for 

copper and 6.7 mg/cm2/day for zinc. When the vessel was stationery, the leaching rates were 8.9 and 3.6, 

respectively. EPA (1999q) determined that copper leachate from antifouling hull coatings was a 

significant contributor to total copper levels in several specific Naval ports, with, for example, localized 

areas around vessels in San Diego Harbor exhibiting twice the average ambient copper concentration of 

3.7 mg/L. 

Recent civilian research (Schiff et al., 2003) on fiberglass hulls with copper-based coating indicated that 

passive leaching rates (i.e., when the vessel was stationary and had not been recently cleaned) of copper 

were between 3.7 to 4.3 μg/cm2/day. If the hull had been cleaned within one day of sampling, the 

leaching rates were between 15 and 18 μg/cm2/day, with these rates decreasing with each day removed 

from the cleaning activity. While the copper leaching rate was higher around cleaning activities, the 

researchers found that only 4-7% of monthly copper emissions were attributable to cleaning. The 

remaining 93-96% of monthly emissions were from passive leaching. These rates were extrapolated to 

typical recreational vessels: a 9.1m (~30 foot) motorboat that is cleaned once a month (using the best 

management practices described in Section 6.20) contributes from 22 to 26 grams of dissolved copper per 

month to the surrounding waters.

29 These comments included EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPAHQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).
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5.1.17 Motor Gasoline Compensating Discharge

The information on motor gasoline compensating discharge was obtained from EPA (1999r).

Discharge Summary

Motor gasoline (MOGAS) is gasoline used as fuel, identical to that which is put into automobiles. Some 

vessels may transport MOGAS-powered vehicles, equipment, or machinery which may be brought 

onboard fully loaded with MOGAS. MOGAS may also be transported in drums or other containers or 

stored in the vessel’s permanent ambient water compensating tanks, if present. When a vessel with builtin MOGAS tanks gets overhauled, it must empty its tanks to pierside trucks, transit 50 nmi offshore and 

perform three tank exchanges of ambient water before filling up the tanks completely for the transit back 

to shore. When the MOGAS is reloaded to the vessel, the ambient water that was in the tanks is 

discharged.

It is notable that none of the commentors that listed the relevant discharges for their vessel types cited 

MOGAS.

When and Where Discharge Occurs

Armed Forces vessels with MOGAS tanks are overhauled prior to redeployment, which occurs about 

once annually. Civilian vessels with MOGAS tanks may have a different timetable. The compensating 

ambient water is discharged directly overboard as the vessel’s tanks are refilled pierside.

Discharge Rates, Concentrations, and Constituents

The discharged ambient water may contain traces of gasoline constituents, which vary depending on the 

specific manufacturer. Generally, gasoline will contain alkanes, alkenes, aromatics, metals, and additives. 

A 1992 study cited in EPA (1999r) detected a variety of compounds in gasoline, including benzene, 

toluene, ethylbenzene, phenol, and naphthalene. 

MOGAS compensating ambient water is discharged at the same rate at which the fuel trucks refill the 

tanks. EPA (1999r) estimated this rate at 50 gpm or less, although the actual rate for civilian vessels will 

vary according to vessel and fuel supplier.

The concentration of MOGAS constituents will also vary according to manufacturer, although EPA 

(1999r) estimated the concentrations of various constituents in MOGAS compensating discharge. Based 

on the most stringent state standards, benzene, toluene, ethylbenzene, phenol, and naphthalene exceeded 

water quality criteria. 

5.1.18 Non-Oily Machinery Wastewater

The information on non-oily machinery wastewater was obtained from EPA (1999s) and four comments30

on EPA’s ANPRM.

Discharge Summary

Non-oily machinery wastewater systems are meant to separate machine-generated wastewater that must 

go to the bilge compartment (i.e., that has an oil content) from the wastewater that can be collected in 

tanks before being discharged directly overboard (i.e., that has no oil content). Vessels can have 

numerous sources of non-oily machinery wastewater, including (among others) distilling plants start-up 

discharge, chilled water condensate drains, fresh and saltwater pump drains, potable water tank 

overflows, and leaks from propulsion shaft seals. However, the major source is desalination distillation 

30 These comments included EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPAHQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).
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plant discharge which occurs after the start-up of the distillation system and before the desired level of 

salinity has been achieved, when the discharge ends. 

Comments from WSC, LMC, and CMC on EPA’s ANPRM cited (without further comment) non-oily 

machinery wastewater as a relevant discharge from the vessels they represent. CLIA also cited scrubber 

wash water (i.e., seawater used to rinse scrubbers) as a discharge which falls into the non-oily machinery 

wastewater category, but that only one of their vessels generated this discharge. They also stated that the 

scrubber wash water was discharged directly overboard after scrubbing operations. 

When and Where Discharge Occurs

Non-oily machinery wastewater discharge can occur continuously for machinery located above deck. 

Wastewater from machinery located below deck must be held in tanks and is pumped overboard 

intermittently. Since there is no oil present, the wastewater may be discharged anywhere.

CLIA stated that their scrubber wash water was discharged within 12 nmi of land.

Discharge Rates, Concentrations, and Constituents

Constituents of non-oily machinery wastewater discharge include a suite of classical pollutants, metals, 

and organics. Many of the specific constituents examined in EPA (1999s) exceeded the water quality 

standards of the most stringent U.S. state, including copper, nickel, silver, zinc and a collection of 

nutrients. Mercury was also detected, but concentrations did not exceed the most stringent water quality 

standards.

Non-oily machinery wastewater discharge flow rates vary by vessel size and operation type. EPA (1999s) 

estimated discharge rates from distillation plant start-up to range from 100 gallons per hour (gph) to over 

4,000 gph, depending on the size of the plant. These rates are not entirely applicable to the vessels that 

will be covered under the vacatur, but the rate variability is instructive. EPA (1999s) did not provide rates 

or concentrations for overall non-oily machinery wastewater discharge. 

5.1.19 Photographic Laboratory Drains 

The information on photographic laboratory drains was obtained from EPA (1999t).

Discharge Summary

When a vessel has the capability to develop photographs onboard, there is accumulated waste associated 

with the developing process. Given the recent move toward digital photography, however, it is expected 

that many civilian vessels that once had the ability to process photographs will now do so digitally and, 

therefore, without waste. In the case that a vessel will retain its ability to manually process photographs, 

the amount of accumulated waste is expected to be small enough to be held onboard for onshore disposal.

It is notable that none of the commentors that listed the relevant discharges for their vessel types cited 

photographic laboratory drain discharge.

When and Where Discharge Occurs

Navy guidance prohibits the discharge of photographic laboratory drains within 12 nmi from of shore and 

mandates the containerization of all discharge for onshore disposal. Despite the allowance of such 

disposal beyond the 12 nmi limit, most vessels containerize all photographic laboratory drain contents for 

onshore disposal. If the drains are discharged further than 12 nmi from land, additional treatments must 

be employed. Fixer solution must pass through a silver recovery unit prior to overboard discharge and 

black-and-white and x-ray effluent must pass through the ship’s blackwater collection, holding, and 

transfer system. Civilian vessels may have different policies for this discharge. 
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Discharge Rates, Concentrations, and Constituents

Photographic laboratory drains may contain constituents found in developing solutions, fixers, and rinse 

water (e.g., silver). EPA (1999t) provides an extensive table listing some of the potential constituents of 

commonly used photographic laboratory solutions. 

5.1.20 Refrigeration/Air Conditioning Condensate Discharge

The information on refrigeration/air conditioning condensate was obtained from EPA (1999u) and five

comments31 on EPA’s ANPRM.

Discharge Summary

Condensation forms when warm air comes into contact with the cold refrigeration or evaporator coils of 

an air conditioning system or refrigeration unit on a vessel. The condensation drips from the coils and 

collects in drip troughs which typically channel to a drainage system. On Armed Forces vessels, 

condensate that is collected above the vessel’s waterline is immediately discharged overboard while 

condensate collected below the waterline is held onboard for a period of time before being discharged 

overboard. Some vessels may channel condensate in the drain to other areas, such as the bilge tank or the 

sewage system tanks, for temporary holding until those tanks can be disposed of onshore or discharged 

overboard according to the relevant regulations. Refrigeration and air conditioning systems on Armed 

Forces vessels typically have coils constructed of copper. 

In the ANPRM comments, PSPA, CMC, WSC, CLIA, and AWO all cited refrigeration/air conditioning 

condensate as discharges that were relevant to their particular types of civilian vessels. AWO stated in 

their comments that all their towing vessels are equipped with continuously running refrigeration units 

and air conditioners which drain very small amounts of condensation directly overboard. 

When and Where Discharge Occurs

Refrigeration/air conditioning condensate can be discharged wherever and whenever these systems are in 

operation.

Discharge Rates, Concentrations, and Constituents

This discharge may contain metals from the refrigeration/air conditioning coils and drainage systems, 

including aluminum, bronze, copper, iron, lead, nickel, silver, tin, and zinc. Traces of mild detergent may 

also be found in this discharge from the cleaning of refrigerated spaces, as can seawater (used to defrost 

some cargo spaces) and freshwater (used to flush residual seawater from these cargo spaces). 

5.1.21 Rudder Bearing Lubrication Discharge

The information on rudder bearing lubrication was obtained from EPA (1999v) and three comments32 on 

EPA’s ANPRM.

Discharge Summary

Rudder bearings allow a vessel’s rudder to turn freely and, on Armed Forces vessels, rudder bearings can 

be either grease-, oil-, or water-lubricated. Grease-lubricated rudder bearings on Armed Forces vessels 

discharge grease directly to the bilge tank while oil-lubricated bearings are kept at a slightly positive 

pressure in relation to the outside ambient water pressure and will only discharge into the surrounding 

water if a leak occurs around the rudder mechanism. Many vessels install hull seals where the rudder 

penetrated the hull to prevent the type of leaks that could lead to oil discharges. 

31 These comments included EPA-HQ-OW-2007-0483-619 (AWO), EPA-HQ-OW-2007-0483-1168 (PSPA), EPAHQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), EPA-HQ-OW-2007-0483-1498 (WSC).

32 These comments included EPA-HQ-OW-2007-0483-619 (AWO), EPA-HQ-OW-2007-0483-1248 (CMC), and 

EPA-HQ-OW-2007-0483-1498 (WSC).
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Three commentors to the EPA’s ANPRM cited rudder bearing lubrication discharge as relevant to their 

types of civilian vessels: CMC, WSC, and AWO.

When and Where Discharge Occurs

This discharge occurs primarily when the vessel is underway and the rudder is in use; turning the rudder 

can cause gaps in the hull seal. These gaps can become larger if the rudder is turned sharply or the vessel 

is moving at a high rate of speed. If oil-lubricated rudder bearings are present, leakage may occur at any 

time (even when the vessel is stationery) because the lubricant is slightly pressurized.

Discharge Rates, Concentrations, and Constituents

Depending on the type of rudder bearings in use, this discharge can cause oil or grease to be released into 

the water column. With a malfunctioning or failing seal, Armed Forces vessels can leak one gallon of oil 

per day while at sea or one pint per day while in port. This amount of oil does not exceed federal oil 

sheen standards or the most stringent state water quality criteria.

5.1.22 Seawater Cooling Overboard Discharge

The information on seawater cooling overboard discharge was obtained from EPA (1999w) and six

comments33 on EPA’s ANPRM.

Discharge Summary

Seawater cooling systems onboard vessels use ambient water pumped in directly or through the firemain 

to absorb the heat from the propulsion system and auxiliary heat exchangers. This water is then 

discharged back overboard. Cooling water demand is continuous, particularly for larger vessels, and 

seawater spends approximately one minute in the cooling system before being discharged. Some vessels 

add seawater piping biofouling prevention chemicals to the cooling water to keep marine organisms from 

becoming established and clogging the system. Strainer plates are used to prevent clogging from larger 

material; the strainer plates must occasionally be cleared using low-pressure air or steam. Anything that 

had been caught on these plates would also be considered a discharge.

In their comments on EPA’s ANPRM, LMC, WSC and CMC all cited seawater cooling overboard 

discharge as relevant discharges from the vessels they represent. PSPA’s comments also listed cooling 

activities as producing discharge, but, along with engine cooling water, they also listed (without further 

comment) hydraulic system cooling water, refrigeration cooling water, and processing factory cooling 

water as relevant discharges. CLIA also cited engine cooling water as a relevant discharge that originates 

from all the vessels they represent and that this discharge occurs continuously. AWO stated that their 

towing vessels produced this discharge on a continuous basis.

When and Where Discharge Occurs

Seawater cooling systems are used both while vessels are pierside and while they are underway. 

Discharge Rates, Concentrations, and Constituents

The potential constituents of seawater cooling overboard discharge include entrained or dissolved 

materials from the system itself. Although the specific constituents will vary depending on the vessel and 

the type of cooling system, EPA (1999w) identified copper, iron, aluminum, zinc, nickel, tin, titanium, 

arsenic, manganese, chromium, lead, and oil and grease as possible contents of the discharge. Mud, biota, 

and other debris that were stuck to the strainer plates may also be discharged. The seawater is also being 

discharged at a higher temperature than when it was taken up and constitutes a thermal discharge into the 

33 These comments included EPA-HQ-OW-2007-0483-619 (AWO), EPA-HQ-OW-2007-0483-1168 (PSPA), EPAHQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), 

and EPA-HQ-OW-2007-0483-1498 (WSC).
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receiving water. EPA (1999w) estimates that the thermal difference between seawater intake and 

discharge can range from 5 to 25°C, with a maximum discharge temperature of 140°C. 

Seawater cooling discharge flow rates vary by vessel size and operation type. EPA (1999w) estimated 

rates ranging from 1,500 gpm for a pierside destroyer to over 170,000 gpm for an in-transit aircraft 

carrier. These rates are not entirely applicable to the vessels that will be covered under the vacatur, but 

the rate variability is instructive. Constituent concentrations will also be variable, depending on the 

residence time, the quality of the intake water, and the erosion and corrosion of cooling system 

components. However, EPA studies indicated that copper, nickel, and silver concentrations exceeded the 

most stringent state water quality standards. 

5.1.23 Seawater Piping Biofouling Prevention

The information on seawater piping biofouling prevention was obtained from EPA (1999x) and three 

comments34 on EPA’s ANPRM.

Discharge Summary

Seawater cooling systems onboard vessels use ambient water pumped in directly or through the firemain 

to absorb the heat from the propulsion system and auxiliary heat exchangers. This water is then 

discharged back overboard. To prevent biofouling of the cooling system, low amounts of chlorinating 

substances are sometimes injected near the seawater intakes to kill any organisms that may have been 

sucked in. 

In their comments on EPA’s ANPRM, WSC cited (without further comment) seawater piping biofouling 

discharge as relevant to the vessels they represent. CLIA also cites this type of discharge, although they

stated that only 13 of the vessels they represent are so equipped. Finally, CMC stated that most 

commercial vessels are equipped with seawater piping biofouling systems.

When and Where Discharge Occurs

Discharge will occur wherever and whenever a vessel equipped with biofouling prevention equipment is 

underway.

Discharge Rates, Concentrations, and Constituents

Seawater that has been discharged after being treated with chlorinating substances will contain free 

chlorine and reaction products (collectively called ‘chlorine-produced oxidants). These reaction products 

include chloride ions, chloramines, free bromine, and chloroorganics. EPA (1999x) provided estimates of 

discharge rates and concentrations for specific classes of Armed Forces vessels, but these estimates are 

not reproduced here.

5.1.24 Small Boat Engine Wet Exhaust

The information on small boat engine wet exhaust was obtained from EPA (1999y) and five comments35

on EPA’s ANPRM.

Discharge Summary

Smaller vessels take in ambient water to cool their engines and then discharge it back into the receiving 

waters. The water passes through the engine and some components of the exhaust transfer to the water 

before it is discharged as ‘wet exhaust’. Both inboard and outboard engines have this type of cooling 

34 These comments included EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and 

EPA-HQ-OW-2007-0483-1498 (WSC).

35 These comments included EPA-HQ-OW-2007-0483-619 (AWO), EPA-HQ-OW-2007-0483-1177 (LMC), EPAHQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 

(WSC).
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system, although inboard engines discharge their wet exhaust above the water line while outboard engines 

discharge underwater. Inboard engines are usually powered by diesel while outboard engines run on

gasoline.

In their comments on EPA’s ANPRM, WSC, LMC, and AWO listed (without further comment) small 

engine wet exhaust as a relevant discharge from the vessels they represent. CLIA stated that the boat 

tenders that accompany their cruise ships generate this discharge, although only when in port which can 

be three to five days a week. 

When and Where Discharge Occurs

This discharge can occur anywhere and will occur anytime an inboard or outboard engine is operating.

Discharge Rates, Concentrations, and Constituents

Research by EPA and DoD found that the constituents discharged by outboard engines differ from those 

discharged by inboard engines, due to the different fuel types. For outboard engines, a handful of 

constituents were estimated to exceed the most stringent state water quality standards: benzene, toluene, 

ethylbenzene, and naphthalene. Inboard engines are expected to exceed standards for polycyclic aromatic 

hydrocarbons (PAHs), including acenaphthylene, phenanthrene, chrysene, benzo(a)pyrene, 

benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene, and others. Additionally, wet exhaust 

can contain nitrogen oxides, hydrocarbons and other organic compounds, carbon monoxide, and 

particulates. 

EPA (1999y) estimates that outboard engines discharge wet exhaust at a rate of 20 gpm while inboard 

diesel engines have an estimated discharge rate of 150 gpm

5.1.25 Sonar Dome Discharge

The information on sonar dome discharge was obtained from EPA (1999z).

Discharge Summary

Sonar domes are attached to a vessel’s hull and protect the equipment used for navigation and detection. 

To equalize pressure within the sonar dome, freshwater is added to the inside and any water that is lost is 

replenished using ambient water from the firemain system. Maintenance on the sonar dome, while 

typically (but not always) done while a vessel is in dry dock, can involve the release of the inner sonar 

dome water. In addition, the components of the outside of the sonar dome can leach into the surrounding 

waters.

It is notable that none of the commentors that listed the relevant discharges for their vessel types cited 

sonar dome discharge.

When and Where Discharge Occurs

Discharges from the exterior of the sonar dome occur continuously as long as the vessel is in water. 

Repairs and maintenance to the interior of the sonar dome (which necessitates the release of the water on 

the inside) only occurs (if at all) while the vessel is pierside. 

Discharge Rates, Concentrations, and Constituents

On Armed Forces vessels, the components that make up the outside of sonar domes can include TBT, 

plastic, steel, rubber, and antifouling coatings. Along with these materials, tin, zinc, copper, nickel, and 

epoxy paints may be found on the inside of sonar domes. Studies conducted by EPA and DoD indicated 

that, of these constituents, TBT, copper, nickel, and zinc exceeded the most stringent state water quality 

standards. Although the firemain system was occasionally used to replenish lost water from inside the 

sonar dome, EPA and DoD found that the constituents found in firemain water negligibly contributed to 

the discharge.
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The rates of discharge will depend on the size of the sonar dome as well as the frequency of which repair 

or maintenance is required. For Armed Forces vessels, EPA and DoD estimated that as little as 300 

gallons and as much as 74,000 gallons would be discharged from inside the sonar dome with every repair 

event. This amount will vary for civilian vessels. 

5.1.26 Steam Condensate

The information on steam condensate discharge was obtained from EPA (1999aa) and from one

comment36 on EPA’s ANPRM.

Discharge Summary

When in port, some Armed Forces vessels utilize shore-based steam resources to power auxiliary systems 

(such as laundry or heat). As the steam is pumped from boilers on land through the vessels’ steam lines 

and to the equipment that requires it, it cools and condenses into water. This condensed water collects in 

insulated tanks before being pumped overboard. This discharge only occurs when Armed Forces vessels 

are using shore-based steam; condensed water from steam created on ship is recycled as boiler feedwater. 

The UNDS reports refer to the shore steam capabilities of naval facilities, but it is unclear following a 

brief internet search whether shore steam systems are widely available at civilian ports. 

In response to EPA’s ANPRM, WSC cited (without further comment) steam condensate as a relevant 

discharge to the vessels they represent.

When and Where Discharge Occurs

Steam condensate is only discharged when an Armed Forces vessel is in port and using shore steam 

resources. If steam condensate is a relevant discharge for civilian vessels, the same would be true.

Discharge Rates, Concentrations, and Constituents

Steam condensate is primarily water that contains material from the piping and heat exchangers. 

Depending on the construction of the vessel, these materials may include metals, organics (e.g., 4-chloro3-methylphenol, benzidine, bis(2-ethylhexyl)phthalate), oil and grease, and volatile residue, among oher 

classical pollutants. The steam condensate may also be discharged at a higher temperature than the 

surrounding water column. Based on modeling activities, EPA and DoD determined that steam 

condensate may exceed Washington State’s thermal water quality criteria, but the exceedance would be 

brief. When discharged, the thermal plume would be narrow and shallow and any disturbance of the 

water would cause enough mixing to dissipate the plume. 

Based on steam condensate discharge sampling, a handful of constituents exceeded the most stringent 

state or federal water quality standards. Copper exceeded both state and federal standards, while nickel, 

ammonia, benzidine, and bis(2-ethylhexyl)phthalate) exceeded the most stringent state standards.

5.1.27 Stern Tube Seals and Underwater Bearing Lubrication

The information on stern tube seals and underwater bearing lubrication was obtained from EPA (1999bb) 

and from three comments37 on EPA’s ANPRM.

Discharge Summary

On Armed Forces vessels, stern tube seals and bearings are associated with the propeller shaft; the former 

prevents water from entering the vessel and the latter support the weight of the propeller shaft. Depending 

on the type of vessel, seawater, freshwater, or oil provides the lubrication for the bearings and seals.

36 This comment was EPA-HQ-OW-2007-0483-1498 (WSC).

37 These comments included EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and 

EPA-HQ-OW-2007-0483-1498 (WSC).
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Seawater lubrication is delivered via the firemain or the auxiliary seawater cooling main while freshwater 

comes from the port water supply, although only rarely is freshwater used as a bearing and seal lubricant. 

In response to EPA’s ANPRM, WSC, CMC, and CLIA all cited stern tube seals and underwater bearing 

lubrication as a relevant discharge for the vessels they represent. CMC stated that almost all vessels have 

stern tube seals and bearings that require lubrication.

When and Where Discharge Occurs

This discharge is continuous because the stern tube seals and bearings require constant lubrication.

Discharge Rates, Concentrations, and Constituents

Given that the seawater from the firemain is only very briefly in contact with the bearings and seals, the 

majority of the constituents will be those contained in the firemain or auxiliary seawater cooling main 

water and piping systems. Seawater used for lubrication may contain bis(2-ethylhexyl) phthalate, copper, 

nickel, and iron. If the shaft is turning, rubber may be contained in the discharge. Discharge from 

freshwater lubrication may contain chlorine as a disinfectant for the port facility water system.

Discharge sampling indicated that bis(2-ethylhexyl) phthalate, copper, nickel, and iron exceeded the most 

stringent state water quality criteria. 

5.1.28 Submarine Bilge Water

The information on submarine bilgewater was obtained from EPA (1999cc).

Discharge Summary

Similar to the bilge water that collects in surface vessels, submarine bilge water is a combination of water, 

effluent, and other materials that drain from various areas of the vessel to the lowest compartment. In 

Armed Forces submarines, the bilge area consists of a non-oily collection tank, an oily bilge tank, and a 

waste oil collection area. Non-oily waste is sent via a segregated piping system to the non-oily bilge tank, 

where it is discharged directly overboard. In some Armed Forces submarine, bilge water that has oil or 

potentially has oil in it is sent through a gravity separation system, where the water is settled out of the 

oily mixture and discharged overboard. The remaining oily substance is sent to the waste oil collection 

area where it is held for onshore disposal. 

When and Where Discharge Occurs

The times and places submarine bilge water is discharged depends on vessel operations, distance from 

shore, and depth. Generally, most Armed Forces submarines discharge all non-oily bilge water outside of 

12 nmi of land or hold all bilge water (oily and non-oily) for onshore disposal.

Discharge Rates, Concentrations, and Constituents

Pearl Harbor Naval Station estimates that 2,000-3,000 gallons of bilge water are generated per day while 

an Armed Forces submarine is pierside. One class of submarine is estimated to dispose of 31,500 gallons 

on shore, zero gallons within 12 nmi of land, and 300,000 gallons outside of 12 nm, while another class 

disposes of 54,000 gallons onshore, 80,540 gallons within 12 nmi of land, and 400,200 gallons outside of 

12 nm. 

Submarine bilge water effluent sampling has detected 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. High total suspended solids (TSS) and chemical oxygen demand 

(COD) may also be present. The measured levels of oil and grease, copper, nickel, silver, and zinc 

exceeded both the federal and state water quality standards, while mercury, heptachlor, heptachlor 

epoxide, chlorine, and cadmium exceeded the most stringent state standards, but not the federal.
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5.1.29 Surface Vessel Bilge Water/Oil-Water Separator (OWS) Discharge

The information on surface vessel bilge water/oil-water separator discharge was obtained from EPA 

(1999dd) and from four comments38 on EPA’s ANPRM.

Discharge Summary

The bilge is a compartment in a vessel’s hull where water and other residue originating from the decks 

and interior of the vessel accumulate. According to EPA (1999dd), most of the bilge contents (or bilge 

water) in Armed Forces vessels come from vessel machinery and engine room drainage. 

Comments on EPA’s ANPRM from WSC cited (without further comment) discharge from the onboard 

oily water separator as relevant to the vessels they represent. CLIA stated that their bilge water is 

discharged (after being treated by an OWS) typically several times per week and that all their vessels 

have this discharge. AWO stated that their towing vessels are equipped with a segregated bilge system, 

which keeps oily bilge liquids (e.g., from the vessels’ machinery spaces) separate from any oil-free water 

that may accumulate in the bilge areas surrounding the propeller shafts. Their oily bilge liquids are stored 

and disposed of onshore at the appropriate facility. 

When and Where Discharge Occurs

Armed Forces vessels are not permitted to discharge bilge water unless it has been treated with an OWS 

and only then if the oil content of the bilge water is less than 15 mg/l prior to discharge. If an OWS is 

used and the oil content is below the limit, than bilge water may be discharged anywhere and anytime. 

Discharge Rates, Concentrations, and Constituents

Several studies on the bilge water content have been conducted on Armed Forces vessels. The 

constituents that were detected included oil, grease, volatile and semi-volatile organic compounds, 

inorganic salts, and metals. Additionally, on some vessels, effluent from the chain locker drains into the 

bilge as do elevator pit effluent and discharge from the gas turbine water wash. Schmidt (2000) stated 

that, on a one week journey, an average cruise ship with 3,000 passengers and crew can generate 25,000 

gallons of oily bilge water. 

5.1.30 Underwater Ship Husbandry

The information on underwater ship husbandry was obtained from EPA (1999ee) and from three 

comments39 on EPA’s ANPRM.

Discharge Summary

Many vessels are too large to be regularly removed from the water and any repair or maintenance 

required on the hull or hull appendages must occur while the vessel is pierside. Specifically, EPA 

(1999ee) defines underwater ship husbandry to include hull cleaning, fiberglass repair, welding, sonar 

dome repair, tests/inspections, masker belt repairs, and paint operations, as well as other activities that are 

specific to Armed Forces vessels only. All of these husbandry activities are also conducted on civilian 

vessels, although the size and type of vessel will dictate the extent of the maintenance. In addition, most 

recreational and other smaller vessels are removed from the water during husbandry operations; therefore, 

underwater ship husbandry discharges may not be applicable to them. 

38 These comments included EPA-HQ-OW-2007-0483-619 (AWO), EPA-HQ-OW-2007-0483-1248 (CMC), EPAHQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).

39 These comments included EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and 

EPA-HQ-OW-2007-0483-1498 (WSC).
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In their comments on EPA’s ANPRM, the WSC and CMC both cited (without further comment) 

underwater ship husbandry as a relevant discharge from the vessels they represent. CLIA stated that hull 

and propeller cleaning on all their vessels is conducted annually via remote operated vehicles or by divers 

using scrubbers or pressure washers. They also state that this cleaning is only done while in port or at 

anchor.

When and Where Discharge Occurs

Most underwater husbandry is done while the vessel is at port. The frequency with which the 

maintenance and repair activities occur is dependent on the type of vessel and the nature of the 

maintenance. EPA (1999ee) estimates that Armed Forces vessels receive about one full hull cleaning 

annually, with more frequent cleanings of hull appendages (e.g., propellers). Fiberglass repair and 

welding operations on Navy vessels each occur about twelve times per year fleetwide.

The frequency with which a vessel’s hull needs to be cleaned depends on a variety of factors, including 

water temperature, water chemistry characteristics (i.e., nutrient concentrations), and frequency of use. A 

demonstration project by California Sea Grant (Johnson and Gonzalez, 2006) in San Diego Bay tested the 

efficacy and other characteristics of three different types of anti-fouling hull coatings (epoxy, ceramicepoxy, and silicone-rubber), including during hull cleaning activities. Boats participating in this project 

included three powerboats between 28 and 42 feet and three sailboats between 21 and 46 feet in length, 

representing a range of typical recreational vessels. The researchers stated that recreational boats are 

typically cleaned on a schedule set by the owners with input from their hull cleaning companies. The 

project boats with epoxy or ceramic-epoxy coatings were cleaned approximately every 15-18 days, while 

the vessels with silicone-rubber coatings were cleaned more frequently: every 7-12 days. 

Another study commissioned by California Sea Grant along with the California Department of Boating 

and Waterways (Carson et al., 2002) evaluated the possible policy options for reducing the use of copperbased hull anti-fouling paint on recreational boats in San Diego Bay. One of the factors they examined 

was hull cleaning frequency. Generally, they found that recreational vessel hulls that were treated with 

coatings that were not copper-based (‘alternative paints’) required more frequent cleaning: from once a 

week to once every three weeks. 

Discharge Rates, Concentrations, and Constituents

The constituents discharged due to underwater ship husbandry differ depending on the specific activity. 

For example, hull cleaning may discharge copper and zinc from the antifouling paint. Fiberglass, resins, 

and hardeners may enter the water during fiberglass repair, although the specific ingredients in the resins 

and hardeners will vary by manufacturer. Welding activity may introduce metals, including chromium, 

iron, nickel, manganese, and beryllium while the repair of the sonar dome and masker belts may 

discharge rubber and sealant (the contents of which will vary by manufacturer). The constituents of the 

particular paint used may also enter the water column. 

Additionally, invasive species that have attached to the vessel’s hull may be a constituent of the 

discharge. Some states have begun to document the transport mechanisms of the marine invasive species 

found in their waters. Hawaii, for example, recently estimated that about 73% of the marine invasive 

species observed in Hawaiian waters were transported via vessel hulls and 90% of those have become 

established. A recent study also found that 72% of organisms that have been cleaned off a vessel hull 

remain viable. 

The variability of maintenance and repair activities, as well as the variety of vessel sizes and types, makes 

estimating discharge rates and concentrations difficult. During each fiberglass repair, approximately one 

quart of resin is discharged. Welding operations each emit approximately five pounds of metal slag. 

Discharges from the other activities will vary. 
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5.1.31 Welldeck Discharges

The information on welldeck discharges was obtained from EPA (1999ff).

Discharge Summary

A welldeck is typically located at the stern of a large vessel and is a floodable platform used for launching 

or loading smaller, satellite vessels or vehicles as well as to facilitate cargo loading operations. The floors 

of an Armed Forces welldeck are lined with pressure-treated lumber. Residues and materials that 

accumulate on the welldeck can be discharged via green water washover or the intentional washdown of 

vessels or vehicles stored on the welldeck. The U.S. Department of Agriculture (USDA) requires that any 

vessel or vehicle that comes into contact with foreign soil must be washed down to remove any invasive

species. These washdowns typically occur on the welldeck while still in the foreign port, once the vessel 

has been brought on board the ship or the vehicle has been loaded.

It is notable that none of the commentors that listed the relevant discharges for their vessel types cited 

sonar dome discharge.

When and Where Discharge Occurs

Welldeck discharges can occur at anytime or anyplace. 

Discharge Rates, Concentrations, and Constituents

On Armed Forces vessels, the potential constituents of welldeck discharges include fresh water, distilled 

water, firemain water, grey water, air-conditioning condensate, sea-salt residues, paint chips, wood 

splinters, dirt, sand, organic debris and marine organisms, oil, grease, fuel, detergents, combustion byproducts, and lumber treatment chemicals. Discharges from civilian vessels will vary depending on the 

vessel type and the activity in which the vessel is engaged. 

6.0 Pollution Control Technologies and Best Management Practices

The following sections describe PCTs or BMPs available to either lessen the volume or environmental 

impact of vessel discharges. Many of the discharges do not have PCTs because they have never been 

regulated; therefore, for some of the discharges listed below, information is limited. A handful of the 

discharges did not have either PCTs or BMPs and these will not be discussed further in this section: boiler 

blowdown, cathodic protection, non-oily machinery wastewater, refrigeration/air conditioning 

condensate, rudder bearing lubrication, steam condensate, stern tube seals and underwater bearing 

lubrication, submarine bilgewater, and welldeck discharges. Focus is put on the discharges with the most 

available information.

6.1 Aqueous Film Forming Foam

Battelle did not identify any specific PCTs or BMPs for AFFF discharge. However, a variety of 

manufacturers exist (e.g., Kidde, OmniQual, Amerex) and some foam formulas may have fewer 

pollutants than others. 

As stated in Section 5.1.1, one Armed Forces BMP for AFFF discharge is that maintenance discharges 

may only occur farther than 12 nmi from shore. However, inspection and certification discharges have no 

distance limit for Armed Forces vessels. 

6.2 Chain Locker Effluent

Battelle did not identify any specific PCTs for chain locker effluent discharge. 

One Navy BMP for chain locker effluent discharge is that chain lockers may only be washed down 

beyond 12 nmi from shore. Civilian vessels may have different self-imposed restrictions for chain locker 
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effluent discharge. A comment in response to EPA’s ANPRM from CLIA40 provides two additional 

BMPs for this discharge. The anchor chain should be carefully and thoroughly washed down (i.e., more 

than a cursory rinse) as it is being hauled out of the water to remove sediment and marine organisms. In 

addition, chain lockers should be cleaned thoroughly during dry docks to eliminate accumulated 

sediments and any potential accompanying pollutants (EPA, 2003a).

Australia’s Department of Agriculture, Fisheries, and Forestry commissioned a research study (Taylor 

and Rigby, 2002) to study vessel invasive species prevention management practices and some of the 

suggested methods pertained to chain lockers (as described in Section 5.1.4, the chain locker has the 

potential to harbor invasive species). The suggestions provided in this report included the following:

· Chain lockers should include a grate at the bottom, raised about 0.5 meters above the bottom of 

the locker, with manhole access for cleaning the space.

· Extra washing nozzles should be installed to more efficiently and completely clean the space.

· Prior to entering nearshore waters (preferably in deep ocean), the space beneath the chain locker 

should be inspected, cleaned, and pumped out.

· Prior to entering nearshore waters, anchor cables should be reinspected and, upon any sign of 

sediment or organisms, they should be rewashed.

· Chain lockers should be regularly maintained, and painted to prevent corrosion and rust formation 

which can trap sediment and organisms.

6.3 Clean Ballast

Ballast water PCTs generally fall under one of two main types of process technologies: solid-liquid 

separation and disinfection (Lloyds Register, 2007). Figure 6-1 illustrates these processes. 

Solid-liquid separation involves the separation of suspended solid material, including larger suspended 

micro-organisms, from the ballast water either by sedimentation (allowing the solids to settle out by 

weight), or by surface filtration (the pores in the filtering material being smaller than the size of the 

particle or organism).

Disinfection removes and/or inactivates organisms using one or more of the following methods:

· Chemical inactivation of the organism

· Physicochemical inactivation by irradiation with ultraviolet light (UV), which prevents an 

organism from reproducing. Ultrasound or cavitation (or “microagitation”) are also 

physicochemical disinfection methods.

· Deoxygenation either by displacement of the DO with an inert gas injection or stripping it by 

means of a vacuum, asphyxiating organisms.

Most commercial systems comprise two stages of treatment with a solid-liquid separation stage being 

followed by disinfection, though some disinfection technologies are used in isolation. One ballast water 

treatment technology also employs chemical enhancement (i.e., coagulation/flocculation) prior to solidliquid separation; another uses titanium dioxide to intensify UV irradiation. Some of the manufacturers of 

ballast water treatment technologies as well as the corresponding technologies utilized, capital costs, and 

operational costs are listed below (Table 6-1).

40 Comment No. EPA-HQ-OW-2007-0483-1494
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Figure 6-1. Types of Processes Utilized by Ballast Water Treatment Technologies.

Adapted from: Lloyd’s Register, 2007

Table 6-1. Characteristics of Example Ballast Water Treatment Systems

Capital Cost ($’,000)

Manufacturer Technology Capacity 

(GPM) 880 

GPM

8,806 

GPM

O&M Cost 

($/264,172 

gal)

Ecochlor, Inc. Chlorine dioxide >44,029 260 400 60

Electrichlor, Inc. Filtration + electrolysis/

electrochlorination >44,029 350 NA NA

Environmental 

Technologies, Inc. Filtration + ultrasound >44,029 NA 500 5

Greenship

Hydrocyclone + 

electrolysis/

electrochlorination

>44,029 300 2300 NA

Marenco

Technology Group Filtration + UV 4,403 135 NA 100

MH Systems, Inc. Deoxygenation >44,029 650 950 55

NEI Treatment 

Systems, Inc.

Deoxygenation + 

cavitation >44,029 150 250 50

Nutech 03 Ozonation >44,029 350 800 320

Physical Solid-Liquid Separation:

Disinfection:

Or

Chemical enhancement:

- Flocculation/coagulation

Treatment:

- Hydrocyclone or surface filtration

Chemical Treatment:

- Chlorination

- Electrochlorination or electrolysis

- Ozonation

- Peracetic acid

- SeaKleen

- Chlorine dioxide

Physical:

- UV radiation

- UV + titanium dioxide

- Deoxygenation

- Gas injection

- Ultrasonic treatment

- Cavitation

Residual control (necessary

after chlorination or 

electrolysis):

- Chemical reduction

(sulfite/bisulfate)

Physical enhancement:

- Ultrasonic treatment

- Cavitation
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Table 6–1. Characteristics of Example Ballast Water Treatment Systems, continued

Capital Cost ($’,000)

Manufacturer Technology Capacity 

(GPM) 880 

GPM

8,806 

GPM

O&M Cost 

($/264,172 

gal)

Optimarin AS Filtration + UV >44,029 500 NA NA

Resource Ballast 

Technology

Filtration + electrolysis/

Electrochlorination + 

cavitation

>44,029 150 250 NA

Severn Trent De Nora

Filtration + electrolysis/

Electrochlorination + 

reduction

>44,029 350 500 20

Techcross Electrolysis/

Electrochlorination >44,029 150 NA 10

Adapted from: Lloyd’s Register, 2007

In the United States, the USCG has requirements for the treatment and management of ballast water. 

First, any vessel, including tugs and barges, equipped with ballast water tanks must file a report with the

USCG 24 hours prior to arrival at a United States port (including inland ports) (33 CFR. §151.2041). 

Second, all vessels equipped with ballast water tanks must have a vessel-specific ballast water 

management (BWM) plan (33 CFR. §151.2305(7)). Lastly, all vessels equipped with ballast water tanks

entering U.S. waters after operating beyond the EEZ must perform one of the following BMPs (33 CFR 

151.2035(b)):

· Open Ocean Exchange: a vessel empties all of its ballast water in the open ocean. The vessel 

then refills its tanks (and often empties and refills multiple times as a precaution) and proceeds to 

its destination ports. Although organisms may be present in the ballast water, the vast majority of 

them will be pelagic and unlikely to survive or thrive in nearshore environments. 

· Retain ballast water on board while the vessel is in U.S. waters: this virtually eliminates the 

chance for introduction of invasive species via ballast water. All vessels operating in U.S. waters 

with ballast water that was taken up within 200 nmi of any coast after operating beyond the U.S. 

EEZ must perform either one of the above BMPs, or 

· Use an alternative environmentally sound method of ballast water management that has 

been approved by the Coast Guard. 

Other BWM practices are mandated under 33 CFR 151.2035(a) and apply to all vessels with ballast tanks 

operating on U.S. waters regardless of whether the vessel left the U.S. EEZ. These mandatory BMPs 

include:

· Avoiding ballast operations in or near marine sanctuaries, preserves, parks, or coral reefs

· Avoiding ballast water intake:

o Where infestation, harmful organisms, and pathogens are located

o Near sewage outfalls

o Near dredging operations

o Where tidal flushing is poor or where a tidal stream is known to be turbid

o In darkness when organisms may rise up in the water column

o In shallow water or where propellers may stir up the sediment

o In areas with whale pods, convergence zones, and boundaries of major currents

· Cleaning ballast tanks regularly to remove sediment 

· Only discharging minimal amounts of ballast water in coastal and internal waters
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· Rinsing anchors and anchor chains during retrieval to remove organisms and sediments at their 

place of origin

· Removing fouling organisms from piping, hull, and tanks on a regular basis and disposing of any 

removed substances in accordance with regulations

· Maintaining a vessel-specific ballast water management plan

· Training crew in ballast water and sediment management and treatment procedures.

In addition, USCG has accelerated its efforts to evaluate and approve prototype and experimental 

shipboard installations of ballast water management equipment on vessels, implementing the Shipboard 

Technology Evaluation Program in 2004. USCG is also collaborating closely with EPA in the quantitative 

evaluation of specific ballast water treatment systems. The Environmental Technology Verification 

Program seeks to accelerate the development of environmental technologies based on rigorous and 

credible performance tests conducted according to standardized protocols. These policy and regulatory 

efforts continue41.

In the international arena, the International Maritime Organization (IMO) developed the International 

Convention for the Control and Management of Ships’ Ballast Water and Sediments which regulates 

discharges of ballast water with the goal of reducing the risk of introducing invasive species. Regulation 

D-2 of the Convention sets the treatment standards that systems must meet (Table 6-2). 

Table 6-2. Ballast Water Treatment System Standards.

Organism category Standard

Organisms, > 50 μm in minimum dimension <10 cells/m3

Organisms, 10 – 50 μm <10 cells/ml

Organisms, < 10 μm No standard

Toxicogenic Vibrio cholerae <1 cfu/100 ml

Escherichia coli < 250 cfu/100 ml

Intestinal Enterococci < 100 cfu/100ml

6.4 Compensated Fuel Ballast

PCTs and BMPs for compensated fuel ballast discharge are similar to those described for clean ballast 

discharge. Other BMPs are utilized by the Navy and include filling fuel storage tanks to no greater than 

85% of capacity while in port to prevent overflow through the expansion tank, limiting the in-port 

refueling rate to 400 gpm, and positioning personnel to watch for overflows or monitor fuel levels during 

refueling.

6.5 Controllable Pitch Propeller Hydraulic Fluid

Battelle did not identify any specific PCTs for CPP hydraulic fluid discharge. 

EPA (1999h) identified a handful of BMPs employed by Armed Forces vessels to control and reduce this 

discharge. An oil boom is typically used during underwater CPP activities to contain hydraulic oil 

leakage. The aft third of a vessel (plus an additional 20 feet beyond the stern) is enclosed within the 

boom during these procedures. Additionally, oil spill response personnel and equipment (e.g., absorbent 

pads) must be present while underwater CPP work is underway and, in the event of any spillage, the oil 

will be removed from within the boom using vacuum trucks and other technology. 

41 EPA-HQ-OW-2007-1093 (FedNav, Ltd.)
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6.6 Deck Runoff

An internet and literature search performed by Battelle indicated that there are no deck runoff treatment 

technologies currently on the market or in development. The UNDS Discharge Assessment report on 

deck runoff (EPA, 2003b) provided some information on PCTs and BMPs that had been evaluated for use 

on Armed Forces vessels. Several technologies were assessed, including capture and containment 

systems, flocculation, water oxidation, and filter media. However, for the purposes of the Armed Forces, 

none of the PCTs that were evaluated were appropriate at the time for use aboard military vessels, 

primarily because none of the technologies had been developed for use on waterborne vessels. However, 

EPA (2003b) determined that developing and utilizing a topside management plan (TMP) describing deck 

runoff pollution reduction methods and practices was the best strategy for controlling deck runoff at the 

time. 

Some Armed Forces fleets have instituted their own BMPs for deck runoff. A few Naval ports require the 

containment of deck runoff that contains cleaning agents while pierside. The USCG manually clears its 

vessels’ decks of debris and garbage prior to conducting deck washdowns. Armed Forces oilers must 

plug up deck openings during the loading and unloading of fuel cargo and any spillage is directed to the 

oily waste treatment system. Oil spill cleanup kits are also present on these types of vessels.

In comments on EPA’s ANPRM, AWO42 stated that an increasing number of tank barges are being fit 

with perimeter spill rails fitted with scuppers (pluggable holes) that permit the runoff of rain water.

During cargo transfer operations, the scuppers are plugged up, thereby containing any spilled cargo on 

deck and preventing it from being discharged into the water. After cargo loading is complete, the 

scuppers are not unplugged until the accumulated water on deck is examined for signs of oil 

contamination (e.g., sheen) or spills of other materials. If contamination is detected, the accumulated 

water is removed and held for disposal at an onshore facility. Drip pans are also found on tank barges 

underneath the end of the cargo pipeline. As cargo is being loaded onto the vessel, small amounts of 

cargo can be spilled in the course of connecting and disconnecting transfer hoses. The drip pan catches 

this spillage and the contents are held for shore-side disposal. 

AWO also stated that deck and hopper barges can collect rain water in open, but contained spaces. Clean 

rain water is routinely pumped overboard from these spaces, but accumulated water that may be 

contaminated is left where it is and the space is covered or contained to prevent discharge over the side. 

The contents are then properly disposed of onshore.

6.7 Dirty Ballast

PCTs and BMPs for dirty ballast discharge are similar to those described for clean ballast discharge and 

compensated fuel ballast. On Armed Forces vessels, dirty ballast must be screened prior to discharge by 

an oil content monitor (OCM) that measures the amount of oil in the water. If the oil content exceeds 15 

parts per million (ppm), an alarm sounds and deballasting operations must cease until an OWS can be

employed to reduce the water’s oil concentration. 

6.8 Distillation and Reverse Osmosis Brine

During the UNDS Phase I process, EPA and DoD investigated different pollution control options for 

distillation and RO brine discharge from Armed Forces vessels (EPA, 1999gg). They evaluated five 

options for reducing or eliminating the concentrated brine discharge:

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1. Restrict the operation of water purification plants while a vessel is in port.

2. Layup non-essential water purification plants with freshwater when in port.

3. Require RO technology on new vessels.

4. Substitute freshwater for seawater in distilling plants on stem-powered vessels while in port.

5. Change distillation and RO plant construction materials.

The EPA and DoD concluded that Option 3 was the most desirable option because RO systems have 

lower life cycle costs than distillation plants and do not require chemical feed and cleaning agents. With 

no other source of feedwater, Option 1 may have resulted in compromised vessel operations or high 

monetary costs for providing an alternative feedwater source. Options 2 and 4, while cost effective and 

benign to vessel operations, may not provide the reduced metals concentrations in discharges needed to 

meet water quality standards. The dearth of available purification equipment constructed from alternative 

materials made Option 5 not attractive at the time of the report. 

6.9 Elevator Pit Effluent

Battelle did not identify any specific PCTs for elevator pit effluent discharge, although many Armed 

Forces vessels will transfer elevator pit effluent to the bilge tank (if oily), the gray water treatment system 

(if non-oily) or contain the effluent for onshore disposal. In these cases, the elevator pit effluent will be 

treated by a bilge treatment system, a grey water treatment system, or an onshore treatment system. 

Elevator pit effluent is very rarely discharged directly overboard of Armed Forces vessels without 

treatment.

6.10 Firemain Systems

Battelle did not identify any specific PCTs for firemain system discharge. However, utilizing a ‘dry’ 

firemain system, rather than a ‘wet’ one, will minimize the amount of discharge from this source because 

‘dry’ systems are not continuously pressurized and do not provide water on demand. Therefore, ‘dry’ 

systems cannot provide water for the various other shipboard activities that may need it, such as engine 

cooling or anchor chain washdown. According to EPA (1999m), ‘dry’ firemain systems produce 0.1% of 

the discharge produced by a ‘wet’, continuously pressurized system. 

6.11 Freshwater Layup

Battelle did not identify any specific PCTs for freshwater layup discharge. 

According to EPA (1999n), rather than discharging directly overboard, some vessels of the Armed Forces 

route the used freshwater effluent from the condensers to the bilge tank, where it can be treated with an 

OWS. 

6.12 Gas Turbine Water Wash

Battelle did not identify specific PCTs for gas turbine water wash discharge. 

As a BMP, Navy vessels collect gas turbine water wash effluent in a dedicated tank for onshore disposal. 

6.13 Grey Water

Since 2000, the Alaska Department of Environmental Conservation (DEC) has been closely monitoring 

the treatment systems of cruise ships in Alaskan waters. The most recent data supplied by Alaska DEC 
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(as of August 2007) indicate that 29 ‘large’ and 17 ‘small’43 cruise ships have been in Alaskan waters so 

far in 2007. Very few of the large ships had separate grey water treatment systems onboard, with about 

65% of them combining grey water with black water prior to treatment. The currently available treatment 

technologies for combined grey water/black water wastestream consist of methods also utilized by 

onshore municipal treatment plants, the most common being biological degradation and membrane 

separation. Other technologies employed by vessels with a large passenger capacity include vibrating 

membrane filtration, physical/chemical treatment, and effluent disinfection via electrolytic oxidation. An 

example of a treatment system developed by Hydroxyl Systems, Inc. for cruise ships is found in 

Figure 6-2. Examples of grey water treatment technologies and corresponding costs are presented in 

Table 6-3.

Figure 6-2. Grey Water Treatment System

43 ‘Large’ cruise ships have overnight accommodations for over 250 or more passengers.
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Table 6-3. Grey Water Treatment Technology Costs

Technology Manufacturers Capacity 

(gal/day)

Cost 

($’,000US) Sources

Physical/chemical

treatment Zodiac 21,240 58.3 Shirley Frederick, Zodiac

Membrane bioreactor Zodiac 14,998 506 Shirley Frederick, 

Zodiac

Biological treatment Zodiac 3,460 35 Shirley Frederick, 

Zodiac

Electrochemical cell/NaOCl 

disinfection

Severn Trent 

De Nora 14,794 120 George Starolis, Severn Trent de Nora

264,172 2,200 - 2,400

528,344 2,600 - 2,800

792,516 3,100 - 3,300

3,100 - 3,300

Biofilm carrier/

dissolved air 

flotation/filtration

Hydroxyl 

Systems, Inc.

1,056,688 3,600 – 3,800

3,600 - 3,800

Dan Turner, Hydroxyl 

Other vessels are allowed to discharge grey water outside of no discharge zones. However, the USCG and 

various state agencies are promoting BMPs for grey water to minimize the volume of wastewater 

discharged. For example, Alaska has established grey water BMPs: 

· Limiting wastewater discharges while the vessel is stationary or in port (i.e., holding water in 

port)

· Discharge only while vessel is greater than one nautical mile from shore and traveling at a speed 

>6 knots.

· Vessels that cannot hold water (i.e., do not have any or sufficient holding tank space):

o Can minimize grey water production by limiting usage of washers, dishwashers, etc. 

while in port and 

o Train crew to limit their usage of water while in port.

Several states have developed grey water discharge BMPs for recreational boats. Washington State 

Department of Ecology (1998) recommends, for example, using biodegradable and low nitrogen, 

phosphate-free detergents, providing adequate garbage receptacles to prevent the overboard disposal of 

food waste, and avoiding using dish soaps onboard. Massachusetts Office of Coastal Zone Management 

(2001) cites boater education as a key to preventing grey water discharge pollution, along with 

encouraging the use of shore-based dishwashing stations and shower facilities. 

6.14 Hull Coating Leachate

During the UNDS Phase I process, EPA and DoD evaluated a handful of potential pollution control 

methods for reducing the discharges associated with hull coatings from Armed Forces vessels (EPA, 

2003c; EPA, 1999hh). Three potential options were assessed for feasibility:

1. Use Less Toxic Fouling Release Coatings.

2. Control the Maximum Allowable Anti-Fouling Release Rate.

3. Limit or Eliminate Use of TBT Paints.

EPA and DoD determined that Options 2 and 3 were the most feasible, with establishing a maximum 

copper release rate (Option 2) having estimated costs of $300,000 to $500,000, as long as the coatings

with the reduced release rate were still effective at preventing hull fouling. Option 3, which would 

involve replacing TBT coatings with copper- or silicone-based coatings, was less desirable because 

copper coatings may accelerate the corrosion of aluminum-hulled vessels and silicone coatings are 

effective only once a vessel attains a minimum speed. However, at the time of the report, silicone-based 
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coatings were not yet proven effective on Armed Forces vessels, which was the problem EPA and DoD 

had with Option 1. 

Today, Option 1 may indeed be a feasible option for many types of vessels, including civilian. Siliconebased hull coatings are non-leaching and the slippery surface they provide cause marine organisms to 

slide off when the vessel achieves a minimum speed. International Marine Coatings44 (IMC) currently 

manufactures Intersleek®900, a fluoropolymer low-friction coating that prevents most organisms from 

latching on to a hull. Those that do succeed in attaching are easily removed when the vessel reaches a 

minimum speed of 10 knots. IMC estimates that vessels using Intersleek®900 can achieve approximately 

6% in fuel savings (hull fouling can increase drag on a vessel and decrease efficiency), resulting in 

reduced air emissions. Intersleek®900 is specifically appropriate for large and active scheduled vessels, 

such as dry cargo vessels (e.g., container ships, refrigerated cargo vessels, roll on-roll off ships, vehicle 

carriers), tankers, and cruise ships. Costs for Intersleek®900 are approximately $100/liter, with a typical 

liquefied natural gas carrier requiring 13,000 liters, for example (Alperowicz, 2007). Other 

manufacturers of silicone-based hull coatings include PPG Protective and Marine Coatings, Hempel, 

Jotun, Wearlon, and SeaCoat Technology, LLC. 

Other antifouling coatings are available that slowly release a rapidly biodegradable biocide into the water 

surrounding the hull. Many of these biocides use non-metallic compounds, including SeaNineTM 211N, 

manufactured by Rohm and Haas45. SeaNineTM 211N is specifically recommended for large vessels 

operating in shipping lanes or harbors and in marine or brackish environments. Large recreational yachts 

may also benefit from application. 

Finally, a collection of non-coating methodologies are available to prevent hull fouling, including sonic 

technology. BarnacleanTM (manufactured by SeaCure) uses sonic resonance transmitted through the 

vessels hull to cause fouling organisms like barnacles to detach and the rapidly-moving water that 

surrounds the hull as a result makes it difficult for algae and other organisms to attach. According to the 

company’s website46, to outfit an average-sized boat (34 feet) would cost less than $2,000. However, 

because it is designed to complement other preventative activities, the company recommends utilizing 

Barnaclean in conjunction with some sort of anti-fouling paint. 

BMPs for reducing hull coating leachate discharge during cleaning are provided in Section 6.26 on 

underwater ship husbandry PCTs and BMPs. However, as described in Section 5.1.16 on hull coating 

leachate discharges, passive leaching from vessel hulls coated with copper-based paints can contribute a 

significant amount of copper to the water column. The researchers for this same study (Schiff et al., 

2003) stress that, due to the heavy contribution of passive leaching to dissolved copper concentrations, 

BMPs should focus on changing the type of hull protection, rather than on hull cleaning activities. 

6.15 Motor Gasoline Compensating Discharge

Battelle did not identify any PCTs specific to motor gasoline compensating discharge.

Similar to compensated fuel ballast, several BMPs are in place on relevant Armed Forces vessels to 

prevent or reduce the likelihood of MOGAS discharge. First, the MOGAS tanks are only filled to 80% 

capacity and the truck supplying the MOGAS is only loaded with the amount of fuel needed to achieve 

this capacity. Fuel loading rates cannot exceed 50 gpm. Individuals are assigned to visually watch for 

problems during refueling. Containment systems are also deployed around all locations (e.g., hose 

44 www.international-marine.com

45 www.rohmhaas.com

46 www.barnaclean.com
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connections) where leakages could conceivably occur. Civilian measures for preventing MOGAS 

discharges may vary.

6.16 Photographic Laboratory Drains

Battelle did not identify any PCTs that reduce or eliminate discharge from photographic laboratory drains.

Currently, the Armed Forces may discharge all photographic laboratory drains outside of 12 nmi from 

shore; however, the most common procedure involves collecting such waste for onshore disposal (EPA, 

2003d). The UNDS team did not identify other PCTs or BMPs for this discharge given the high 

unlikelihood of discharge within 12 nm.

6.17 Small Boat Engine Wet Exhaust

During the development of the UNDS Phase I reports, EPA and DoD researched potential PCTs and 

BMPs to control small boat engine wet exhaust on Armed Forces vessels and published a brief report 

(EPA, 1999ii). Specifically, EPA and DoD were investigating methods, practices, or technologies that 

would reduce or eliminate the discharge of combustion by-products, including hydrocarbons, VOCs, and 

oil and grease, into the water. After screening several options (all of which were not described), EPA and 

DoD determined that wet exhaust discharge from Armed Forces small boat engines could best be reduced 

by:

1. Mandating all new Armed Forces boats with inboard engines be fitted with a dry exhaust 

system.

2. Converting inboard engines on existing Armed Forces boats to dry exhaust.

3. Replacing existing outboard engines on Armed Forces boats with low-emission models.

Option 1 was determined to be a feasible option for vessels with inboard engines. There may be some 

additional costs associated with design, but additional installation costs would be limited to materials, 

since the labor needed to install dry exhaust engines is no different than that needed to install wet exhaust 

engines. The report went on to conclude that Option 2 was cost prohibitive. Retrofitting Armed Forces 

vessels with dry exhaust systems would require numerous modifications and a detailed feasibility study. 

EPA and DoD estimated that just to retrofit Navy inboard engines with dry exhaust systems would cost 

$36 million in study, design, and installation costs. This does not include the small vessels in other 

branches of the Armed Forces. Option 3 was estimated to cost approximately $9 million for Navy boats, 

with the only negative determination being that the cost of the conversion may exceed the cost of the 

vessel itself. However, if this option were implemented through attrition, the annual costs were estimated 

to be about $34,000. 

6.18 Sonar Dome Discharge

Battelle did not identify any PCTs for reducing or eliminating sonar dome discharge.

The UNDS report (EPA, 1999z) states that most sonar dome repair is done while the vessel is in drydock. If the repair involves releasing the inner sonar dome water, this water should be containerized and 

disposed of at the appropriate facility. 

6.19 Surface Vessel Bilge Water/Oil-Water Separator Discharge

According to EPA (1999cc), Armed Forces vessels are equipped with an oily waste holding tank where 

bilge water is retained until it can either be disposed of onshore or treated with an oil-water separator 

discharged overboard. Oil content monitors evaluate the bilge water as it passes through the OWS and 

will sound an alarm if the allowable concentration of oil is exceeded. 
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IMO regulations (MEPC 107(49)) specify that the total oil concentration (free and emulsified oil) of bilge 

water cannot exceed 15 ppm if it is to be discharged overboard. Most shipboard bilge water treatment 

systems involve an oil-water separator (OWS), which separates the oil and water using mechanical means 

(e.g., centrifugation, filtration) and/or employ bacteria to digest the organic material. Because of the new 

regulations, manufacturers are frequently combining several technologies in order to break up oil 

emulsions as well as to separate and remove the oil. The following list includes technologies used in bilge 

water separation equipment (EPA, 2003e):

· Centrifuge and Hydrocyclone: uses high-speed rotation to separate the heavier liquids and 

solids from the lighter oils.

· Dissolved Air Flotation: uses high-pressure air to separate suspended solids and insoluble 

liquids from water.

· Evaporation: uses heat to evaporate the water, leaving only oil, sludge, and other solids.

· Biological Treatment: uses microorganisms to digest organic material from bilge.

· Flocculation (Coalescence): using electrical current or separating agents to cause smaller 

particles to coagulate and precipitate out of the solution for later disposal.

· Gravity Coalescence: allows oil and water to form separate layers.

· Oil-Absorbing Socks: designed to absorb oil and repel water when placed in bilge water.

· Filtration: separates high molecular weight constituents from fluids using filter media. 

For recreational vessels, discharge of bilge water is allowed outside of marinas, provided the discharge 

does not contain oil or oily waste. A comment47 on EPA’s ANPRM cited a bilge treatment system that 

has been specifically developed for recreational and other small vessels. A pollution control device 

designed for use in any vessel with a bilge tank and bilge pump, HarborGardTM48 prevents petroleum 

waste that ends up in the bilge tank from being discharged overboard and potentially violating federal and 

state water pollution laws. According to the commentor, Paul Clukies of HarborGard, LLC, units can be 

purchased and installed on an average-sized recreational vessel for less than $50. 

Other bilge tank technology available for recreational vessels is produced by Mycelx Technologies 

Corporation49. Their BilgeKleenTM filtering system comes in three different sizes and is installed on the 

bilge pump discharge line. The filter within the system removes 100% of hydrocarbons from bilge water 

before it is pumped overboard and includes a SmartPadTM that can be placed at the bottom of the bilge 

tank to absorb any other contaminants. RGF Environmental Group, Inc. manufactures an inline bilge 

filtering system designed for small- to medium-sized recreational vessels. Table 6-4 presents the 

examples of commercial and recreational bilge water separator technologies and the corresponding 

capacities and costs (if available).

47 This comment was EPA-HQ-OW-2007-0483-0254 (Paul Clukies, HarborGard)

48 www.harborgard.com

49 www.mycelx.com
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Table 6-4. Bilge Water Treatment Technology Costs

Technology Type of Vessels Examples of 

Manufacturers

Capacity 

(GPM)

Capital 

Cost 

($’,000)

Sources

0.694 5

2 10 -23

5 12 -30

8.8 -10 16 -40

OWS with 

coalescence and 

filtering

Facet: Large 

commercial

RGF: recreational and 

commercial

Ecologix: commercial

Facet International,

RGF Environmental, 

Ecologix Env. Systems

44 - 45 27 -55

Mike Wood, Facet; 

Bill Speck, RGF; 

OWS with 

microbial action Commercial EnSolve Biosystems 1.04 – 3.75 39 - 99 Jason Caplan, EnSolve

High speed 

centrifugal 

separator

Commercial Alfa Laval EcoStream 8.8 100 Larry Bozha, Alfa 

Laval

Filter system Recreational power or 

sail boats Mycelx 20 - 66 .14 -.4 www.mycelx.com

Not available Recreational power or 

sail boats HarborGard Not available .05

Comment EPAHQ-OW-2007-

0483-0254

The Massachusetts Office of Coastal Zone Management (2001) provided suggested BMPs for bilge water 

handling for recreational vessels and marinas, including making oil-absorbent pads available dockside, 

providing bilge vacuum systems for boaters, encouraging the installation of bilge oil filters, promoting the 

use of onboard OWSs or providing portable OWSs, and educating and informing boaters. Guidance 

provided by the Oregon Department of Environmental Quality (2002) adds to these suggestions by 

recommending that soap and emulsifiers not be used to clean a bilge tank; rather, oil-absorbent pads 

should be used if discharge directly to a sanitary sewer is not feasible. They also suggest that drip pans 

be kept under the engine compartment to prevent oil from entering the bilge and that all oil used during 

repairs should be contained and disposed of properly onshore. Numerous other states provide BMPs for 

marinas, including Georgia, Washington, and California, 

6.20 Underwater Ship Husbandry

In the UNDS MPCD report (EPA, 1999jj), EPA and DoD identified four potential pollution control 

options for Armed Vessel discharges associated with underwater ship husbandry:

1. Underwater Ship Husbandry Management Plan (USHMP)

2. Variable Cleaning Pressure Equipment

3. Improved Brushes

4. Underwater Ship Husbandry Discharge Collection Equipment

Options 1 and 2 were determined to be the most feasible for Armed Forces vessels. A USHMP, while 

useful for the Armed Forces (an organized group with a clear line of command), may not be as useful for 

recreational vessels. However, companies that own and operate large numbers of vessels may benefit 

from defining ship husbandry requirements and establishing a routine, if such a plan is not already in 

place. Option 2 involves using lighter cleaning pressure when removing soft fouling organisms (e.g., 

algae, grass) that detach fairly easily. This would not only decrease the discharge associated with the 

cleaning, but potentially extend the life of the hull coating. However, this option only addresses 

discharges that originate from the hull coating and does not address other husbandry-related discharges 

(e.g., fiberglass from repair work or metals from welding). 
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Underwater ship husbandry activities can also cause invasive species to be detached from a vessel’s hull 

and introduced to the water column. Research in New Zealand (Floerl et al., 2004) has indicated that 

approximately 72% of organisms that were removed from the hull of a small vessel (< 49 meters in 

length) during cleaning activities remained viable. Scott Godwin of the Hawaii Coral Reef Assessment 

and Monitoring Program is one of the few experts on hull fouling as an invasive species vector. In a 

recent report (Godwin et al., 2006), he offers numerous suggestions for reducing or eliminating the 

discharge of invasive species during underwater ship husbandry activities. One of the most obvious 

approaches is to maintain protective anti-fouling coatings or technologies in top working order, which can 

be done by increasing the frequency of shipyard service; however, this can be costly to the owner is not 

likely a viable option. Another management practice he suggests is to teach port authority personnel how 

to identify vessels with high potential for hull fouling invasive species introductions. These ‘high-risk’ 

vessels include barges, floating dry-docks, and vessels from military decommission yards (purchased as 

scrap metal or for the fleets of developing nations). Barges, for example, move slowly and spend 

considerable time in port, creating a situation conducive to the settlement and establishment of fouling 

organisms. Vessel decommission yards house vessels that have been idle for years and poorly maintained. 

Port authorities should require hull maintenance records for high-risk vessels and deny port entry based 

on these records. For those vessels unable to produce such documents, a quarantine area could be set up

in deep water greater with remote video or commercial diver inspection capabilities. 

The California State Lands Commission (CSLC) published a report (CSLC, 2006) in which they 

compiled the current mandatory or voluntary management practices in use around the world to prevent 

invasive species from being introduced via the hulls of commercial vessels. Table 6-5 is reproduced from 

their report.

Table 6-5. Global BMPs for Preventing Vessel Hulls from being Invasive Species Vectors.

Country/State Management Strategy Details

U.S. Federal

California

Embedded in ballast water 

regulation

Embedded in ballast water 

statute

Rinse anchor chains and anchors at place of origin

Remove fouling from hull, piping and tanks on a regular basis. 

Dispose wastes in accordance with local, state, and federal law.

Hawaii

Information Framework 

Targeting High Risk Vessels 

(Proposed)

Pro-active measures: Education/outreach, vessel arrival monitoring, 

evaluation for high-risk arrivals

Re-active measures: Rapid response/investigation of high risk event

Post-event measures: Long term regulations for high-risk events

• Limit time in port

• Vessel quarantine

• Out of water cleaning

Survey (On Ballast Water 

Declaration Form)

1. When and where was the vessel last dry-docked and cleaned?

2. Has the vessel been laid-up for 3 months or more since it was last drydocked and cleaned? If YES, state when and where. (Also requests start 

and end date laid up)

3. Do you intend to clean the hull of the vessel in New Zealand? If YES, 

state when and where

New Zealand

Voluntary Codes of Practice 

(Fishing Industry)

Chartered foreign owned or sourced fishing vessels must be substantially 

free from plant or animal growth prior to entering New Zealand’s EEZ.

If no assurance, vessel inspected and cleaned before departure.

Otherwise inspected in NZ and if necessary, fouling removed so no 

foreign organisms enter the marine environment
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Table 6–5. Global BMPs for Preventing Vessel Hulls from being Invasive Species Vectors, 

continued.

Country/State Management Strategy Details

Prohibition

(States/Territories/Ports)

States and territories prohibit in-water cleaning.

Many require containment and disposal regulations of fouling debris 

removed during out-of-water cleaning.

Australia

Regulation

(Vessels less than 25 m)

Keep ancillary gear and internal seawater systems clean of marine pests 

and growths

Before departing your last port for Australia...

o Clean hull within one month before arrival OR

o Apply antifouling paint within one year before arrival OR

o Book vessel for slipping and cleaning within one week of 

arrival (cleaning should be in a shipway where material 

removed can be collected and disposed of away from the sea)

Australia and New 

Zealand 

Environmental 

Conservation 

Council (ANZECC)

Codes of Practice

In-water hull cleaning prohibited, except under extraordinary 

circumstances.

Sea-chests, sea suction grids, other hull apertures may be allowed under 

permit, if debris not allowed to pass to water column or sea bed.

Polishing propellers may be allowed under permit.

Merchant 

Classification 

Societies

Requirements

(Applies to majority of 

merchant fleet)

Dry dock requirements vary somewhat depending on classification 

society. Generally:

o Dry dock every 5 years. Cleaning and painting is usually 

conducted, but is at the discretion of the company.

o Interim in-water cleanings: Periodicity at the discretion of 

the company. Typically dependent on results of fuel 

consumption tests.

California Sea Grant (2003) offers the following BMPs to mariners who must clean their vessel’s hull 

while it is still submerged:

· Wait 90 days to clean the vessel’s hull after applying new paint. Paints release more toxicant 

when new. 

· Soft sloughing or ablative paints release toxicant and paint to water when cleaned. On these 

boats, clean only running gear and zinc anodes. 

· Use only soft materials (e.g., piece of carpet, sponge) to clean the hull. 

· Use soft nylon or similar material on rotary brush machines. 

· Use stainless steel brushes and pads on non-painted, metal areas only. 

· Use more rigorous cleaning pads only as needed to remove hard marine growth. 

· Do not sand or strip hull paint underwater. 

· Bring zinc anodes back to shore; recycle or dispose of properly. 

· Clean gently to avoid creating a plume or cloud of paint in the water. 

EPA (2001) adds to these suggestions:

· Wash boat hulls above the waterline by hand. Where feasible, remove boats from the water and 

clean them where debris can be captured and properly disposed of.

· Attempt to wash boats frequently enough that the use of cleansers will not be necessary.

· If using cleansers, buy and use ones that will have minimal impact on the aquatic environment.
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· Switch to long-lasting and low-toxicity or nontoxic antifouling paints.

· Avoid in-the-water hull scraping or any abrasive process done underwater that could remove 

paint from the boat hull.

· Ensure that adequate precautions have been taken to minimize the spread of exotic and invasive 

species when boats are transferred from one water body to another.

7.0 Laws, Regulations, and Conventions

A number of international standards, federal laws, and state permitting schemes exist or are pending that 

concern some of the discharges covered in this report. This section provides information for EPA to 

consider during the nationwide permitting framework development, including whether existing standards, 

laws, or state programs may become redundant or ineffectual upon the institution of the new NPDES 

program.

7.1 International and National Laws and Regulations 

Several international treaties and national laws apply to discharges incidental to the normal operation of a 

vessel. While all of the regulations listed in this section do not necessarily apply to every one of the 

discharges described in Section 5.0, depending on the constituents of the discharge, one or more of the 

regulations discussed below may be applicable. Even if a constituent or discharge is not directly 

regulated by any national or international law, a close examination of the potentially relevant legislation 

may be informative and prevent legal repercussions.

7.1.1 International Standards

Annexes I, II, and V of the International Convention for the Prevention of Pollution from Ships 

(MARPOL 73/78) may be relevant. In the U.S., these annexes are implemented through APPS, which 

applies to all U.S.-flag vessels operating anywhere in the world and to all foreign-flag vessels operating or 

at port within U.S. navigable waters. In its implementation of MARPOL Annex I, APPS regulates oil 

discharges from U.S.- and foreign-flagged seagoing vessels (33 CFR, parts 151, 155, 156, 157). 

MARPOL’s Annexes II and V are also implemented by APPS. Annex II regulates pollution from 

noxious liquid substances in bulk (33 CFR 151). Annex V regulates garbage pollution of the ocean by 

ships from operational or accidental causes and restricts the discharge of maintenance waste, which 

includes paint chips (33 CFR 151). 

With regard to hull coating leachate, international standards governing the discharge of copper or zinc 

antifouling coatings do not exist. The International Convention on the Control of Harmful Antifouling 

Systems on Ships (AFS Convention) was adopted by the IMO in 2001, although it is not yet in force. 

Once in force, no vessels from signatory nations to the AFS Convention may bear TBT-based antifouling 

coatings, unless covered by an approved sealant (Showalter and Savarese, 2005). 

7.1.2 National Law

As described in EPA (2000), the Oil Pollution Act (OPA) (33 U.S.C. §§ 2701 et seq.) is a comprehensive 

statute designed to expand oil spill prevention, preparedness, and response capabilities of the Federal 

government and industry. It amends §311 of the CWA to clarify federal response authority, increase 

penalties for spills, establish USCG response organizations, require tank vessel and facility response 

plans, and provide for contingency planning in designated areas. OPA prohibits the discharge of oil or 

hazardous substances, in such quantities as may be harmful, into or upon: U.S. navigable waters, 

adjoining shorelines, waters of the contiguous zone, or waters which may affect natural resources in the 

Exclusive Economic Zone (extending some 200 miles offshore). Within twelve miles of shore, OPA’s 

regulations prohibit the discharge of oil unless it is passed through an oil-water separator, and does not 
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cause a visible sheen or exceed 15 ppm (33 CFR §151.10). Beyond twelve miles, oil or an oily mixture 

may be discharged while proceeding en route if the oil content of the effluent without dilution is less than 

100 ppm. Vessels are required to maintain an Oil Record Book, which records, among other things, the 

disposal of oily residues and the discharge or disposal of bilge water (33 CFR §151.25). CWA 

§311(b)(5) mandates that any person in charge of a vessel which discharges or spills oil into the navigable 

waters of the U.S. must notify the appropriate federal agency, who will then notify the state(s) that 

potentially could be affected.

Individual U.S. states have the authority (under CWA §303(c)) to set their own water quality standards 

applicable within state waters and vessels in state waters must abide by these standards.

The Comprehensive Environmental Response and Community Right-to-Know Act (CERCLA) may be 

relevant to some vessel discharges. CERCLA establishes notification requirements upon the 

environmental release of specific hazardous substances, listed in 40 CFR 302.4. Petroleum and any 

refinery-added substances (e.g., xylene, benzene, toluene) are specifically excluded from CERCLA due to 

their coverage under other regulations. However, if the vessel vacatur leads to discharges (and their 

constituents) being permitted via the NPDES system, CERCLA liability and reporting provisions will no 

longer apply to those permitted discharges. 

Under the Organotin Antifouling Paint Control Act (33 USC 2041), TBT-based antifouling coatings are 

partially banned in the U.S., with vessels less than 25 meters (82 feet) in length no longer permitted to 

apply it (unless the vessel has an aluminum hull or the TBT is applied only to the outboard motor or 

lower drive unit of such a vessel) and the sale and delivery of organotins-based paints with a release rate 

of 4.0 mg/cm2/day or more prohibited. In 2004, EPA released ambient water quality criteria for TBT that, 

while not legally enforceable, can help states establish their own water quality standards (Showalter and 

Savarese, 2005).

Under the requirements of NISA, the USCG enforces mandatory ballast water BMPs for all vessels with 

ballast tanks operating in U.S. waters, as described in 33 CFR 151.2035(a) and (b). The specific 

mandatory activities are described in the Clean Ballast discharge description. Other provisions of NISA 

include mandatory ballast water reporting requirements and the funding of treatment technology research. 

NISA technically expired in 2002 (although the specific regulations promulgated under it remain binding; 

33 CFR 151) and, for several years, bills have been introduced in the U.S. House of Representatives and 

the U.S. Senate seeking to reauthorize it as the National Aquatic Invasive Species Act. The most recent 

bill was introduced in the winter of 2007, but whether the bill will make it out of committee during this 

congressional session remains to be seen.

7.1.3 State Law

Some states have developed their own permitting mechanisms, mostly pertaining to ballast water 

discharge, or have permitting plans in the works. 

Table 7-1. Current or Pending State Permitting Systems Pertaining to Vessel Discharges Covered 

in this Report.

State Permitting Systems Pertaining to Vessel Discharges Covered in this Report

Alaska AS 46.03.100: permit is required for the discharge of graywater

Pending: Large Commercial Passenger Vessel Wastewater Discharge General Permit (2007DB0002)

Indiana

Pending: Senate Bill 219 of 2006-- would allow vessels to operate in the waters of IN only if ballast 

water and sediment in the vessel have been sterilized. Ballast discharge would be allowed only with a 

permit.
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Table7–1. Current or Pending State Permitting Systems Pertaining to Vessel Discharges Covered in 

this Report, continued.

State Permitting Systems Pertaining to Vessel Discharges Covered in this Report

Maine General Permit for the Discharge of Graywater or a Mixture of Graywater and Blackwater 

from Large Commercial Passenger Vessels to Coastal Waters (Permit no. W008222-5Y-A-N)

Michigan

Ballast Water Control General Permit No. MIG140000: ballast water discharges only permitted if 

in compliance with treatment requirements and other methods described in the general permit. 

Ships may apply for an individual permit if they prefer to use an alternate treatment method but they 

must demonstrate that the method is both environmentally sound and its treatment effectiveness is 

equal to or better than the treatment methods included in the general permit.

Minnesota

Pending: H.F. No. 3705 (2006), Reintroduced S.F. No. 53 (January 2007)—oceangoing vessels with 

ballast tanks would need a permit and the vessel is equipped to discharge ballast in compliance with 

set rules.

Ohio

Pending: House Bill 298 (2007-2008)-- oceangoing vessels capable of discharging ballast will not be 

permitted to operate without a permit, which will be issued only if it can be demonstrated either that 

discharge will not happen or that approved treatment methods will be used. 

Pennsylvania

Pending: House Bill 1736, Session of 2007-- would require vessels using PA ports to obtain a permit 

proving that the vessel cannot take on ballast water or that it is outfitted with approved treatment 

technology.

Wisconsin

Pending: 2005 Assembly Bill 919 (Introduced January 17, 2006)—would require vessels using WI 

ports to obtain a permit proving that the vessel cannot take on ballast water or that it is outfitted with 

approved treatment technology.

8.0 CONCLUSIONS

With the scheduled date for implementation of the vessel vacatur on the horizon, EPA must fully 

comprehend the scope of the NPDES permitting changes that must be instituted. This report provides an 

overview of available information on vessel populations and characteristics, as well as port statistics and 

existing information on the various types of discharges incidental to the normal operation of a vessel. 

Table 8-1 summarizes the statistical findings for vessel and port information. 

Table 8-1. Summary of Statistical Findings for Vessels and Ports.

VESSELS

Recreational

Total Registered Recreational Vessel Population in 2005 12, 942,414

Top 3 U.S. Regions with Largest Recreational Registration in 2005

Great Lakes

Inland waterways

South Atlantic

Top 3 U.S. States with Largest Recreational Registration in 2005

California

Florida

Michigan

Percent of All Recreational Vessels Mechanically Propelled in 2005 93%

Percent of Mechanically Propelled Vessels Equipped with Outboard 

Engine (s) in 2005 70%

Percent of Mechanically Propelled Recreational Vessels < 26 Feet in 

Length in 2005 95%

Commercial

Total Cargo/Passenger Vessel Population in 2005 41,028

Percent of Cargo/Passenger Vessels Operating Chiefly on the MS River 

System of the Gulf Intracoastal Waterway in 2005 78%

Number of Industrial Vessels (e.g., cable layers, dredges) in 2007 823
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Table 8-2. Summary of Statistical Findings for Vessels and Ports.

VESSELS

Number of Towing Vessels in 2007 6,898

Number of Offshore Supply Vessels in 2007 1,114

Number of Commercial Fishing Vessels in 2007 33,550

Top 3 U.S. States with Most Documented Commercial Fishing Vessels

in 2007

Alaska

Florida

Washington

Top 3 Most Frequently Recorded Foreign Flags Entering U.S. Ports in 

2005

Panama

Bahamas

Liberia

PORTS

Top U.S. Region for Vessel Port Calls in 2005 Gulf of Mexico

Percent of All 2005 Port Calls Received in the Gulf of Mexico 31%

Top 3 U.S. Ports for 2005 Vessel Calls

Houston, TX

Los Angeles/Long Beach,CA

New York, NY

For discharges incidental to the normal operation of a vessel, the discharges that will be relevant for the 

greatest number of vessels include clean ballast, deck runoff, grey water, bilge water, hull coating 

leachate, small boat engine wet exhaust, and underwater ship husbandry. The other discharges may be 

applicable to a collection of commercial vessels; however, these seven discharges will likely be of the 

highest concern to EPA in light of the vessel vacatur. 

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ATTACHMENT A

State-by-state Recreational Vessel Registration 

Information
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