### United States Environmental Protection Agency Office of Wastewater Management Washington, DC 20460

EPA 800

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‐ 004 November 2011 

# Underwater Ship Husbandry DischargesUnderwater Ship Husbandry Discharges Table of Contents

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S ECTION 1 I NTRODUCTION ............................................................................................................... 1 1.1 What is Underwater Ship Husbandry? .................................................................... 1 1.2 Environmental Impacts of Hull Husbandry ............................................................ 2 1.3 Survey of Regulations and Guid elines for Hull Husbandry ................................... 2

S ECTION 2 F ACTORS E FFECTING B IOFOULING ................................................................................. 7 2.1 Immobile Periods .................................................................................................... 7 2.2 Vessel Speed ........................................................................................................... 8 2.3 Voyage Duration ..................................................................................................... 8 2.4 Vessel Movement Patterns ...................................................................................... 9 2.5 Environmental Factors (Salinity, Temperature and Nutrients) ............................. 10

S ECTION 3 : ANTIFOULING COATINGS ................................................................................... 11 3.1 AFCs Containing Biocides ................................................................................... 11 3.2 Non-Biocidal AFCs .............................................................................................. 12 3.3 Best Management Practices for AFC Leachate .................................................... 13

S ECTION 4 H ULL H USBANDRY B EST M ANAGEMENT P RACTICES ................................................... 14

S ECTION 5 V ESSEL H USBANDRY D EBRIS C ONTAINMENT O PTIONS ................................................ 16 5.1 U.S. Navy Advanced Hull Cleaning System (AHCS) and Automated Hull Maintenance Vehicle (AHMV) ............................................................................. 16 5.2 Scat Harding (Norway) CleanHull AS ................................................................. 17

S ECTION 6 H ULL H USBANDRY C OSTS ............................................................................................ 18

S ECTION 7 R EFERENCES ................................................................................................................. 21Underwater Ship Husbandry Discharges List of Tables

ii LIST OF TABLES

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Table 1. Summary of Current Internationa l and U.S. Management Strategies for Underwater Ship Husbandry ................................................................................................4
Table 2. Hull Husbandry Best Management Practices (BMPs) for International Organizations, the U.S., States and Classification Societies .............................................15

Table 3. Estimated Costs of One-Time Out- of-Water and Underwater Hull Husbandry .............19

The EPA technical contacts for this document are Ryan Albert (202) 564-0763 and Robin Danesi (202) 564-1846.Underwater Ship Husbandry Discharges Section 1 - Introduction

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## SECTION 1

INTRODUCTION

The 2008 Vessel General Permit (VGP) regulates discharges incidental to the normal operation of vessels operating as a means of transportation. The VGP, like other general permits, is issued by the permitting authority (in this case , EPA) and covers multiple facilities within a specific category for a specific period of time (not to exceed 5 years). The 2008 VGP includes the following limits or requirements: general effluent limits applicable to all discharges; effluent limits applicable to 26 specific discharge streams; narrative water-quality based effluent limits; inspection, monitoring, recordkeep ing, and reporting requirements; and additional requirements applicable to certain ve ssel types (USEPA, 2008a).

Because EPA plans to reissue the VGP, the Ag ency continues to gather information on vessel wastewater sources while examining technol ogies that can be used to remove pollutants before discharge into waters of the United States. 1 This document contains updated information on recent developments in best management practices (BMPs) for reducing pollutant discharges during underwater ship husbandry.

1.1 W HAT IS U NDERWATER S HIP H USBANDRY ?

Underwater ship husbandry is the maintenan ce of the underwater po rtions of a vessel. Underwater ship husbandry, commonly referred to as hull husbandry, is usually initiated in response to marine biofouling of the underwater hull and hull appendages of boats and ships including propellers, rudders, through-hull fittings, and corrosion control equipment. While certain hull husbandry activities such as insp ection, cleaning and appl ication of antifouling coatings (AFCs) take place out of the water (in dry dock, slipway or haul-out facilities) others such as hull cleaning and propell er polishing are carried out wh ile the vessel is afloat.

Hull husbandry is practiced by the shipping industry primarily for economic reasons. Biofouling on a ship’s hull increa ses the hydrodynamic drag of the vessel, leading to increased fuel consumption (Chambers et al., 2006). For example, annual cleaning has been estimated to reduce fuel consumption for a 175 m long containe r ship by 9,000 tons over a 5-year drydocking period (Schat Harding, 2009). Depending on the type of vessel, fuel may make up about 50 percent of the operational costs of a ship, and it has been estimated that fouling increases the annual fuel consumption of the world’s commerci al shipping fleet by 40 percent, or 120 million tons of fuel at a cost of about $ 7.5 bi llion per year (2000 dollars) (GISP, 2008).

Hull husbandry controls biofouling and micr obial induced corrosion of the ships’ propulsion and seawater cooling sy stems which can lead to poor maneuverability and engine damage (Chambers et al., 2006).

1 “Waters of the United States” as defined in 40 CFR 122.2.Underwater Ship Husbandry Discharges Section 1 - Introduction

2 1.2 E NVIRONMENTAL I MPACTS OF H ULL H USBANDRY

Hull husbandry practices can have environm ental consequences. Two important issues for aquatic ecosystem health that are directly re lated to hull husbandry in clude (1) the discharge of toxic chemicals used as biocides in AFCs a nd (2) biofouling as a vector for aquatic nuisance species (ANS) transport. Underw ater hull cleaning using currentl y available methods can release both toxic chemicals and ANS into receiving waters.

Virtually all vessels that are kept in saltwater use AFCs (Minchin and Gollasch, 2003) to control biofouling of the hull and other underwater equipment. The AFCs that contain biocides prevent the attachment of aquatic organisms to the hull by conti nuously leaching substances into the surrounding water that are toxi c to aquatic life. While a variet y of different ingredients may be used in these coatings, the most commonl y used biocide is copper. Copper can inhibit photosynthesis in plants and interfere with en zyme function in both plants and animals in concentrations as low as 4 μg/l (Takata et al., 200 6). The release of biocides such as copper from hull coatings could lead to water quality impair ments, particularly in crowded boat basins. For this reason, copper containing-AFC s are under regulatory scrutiny in a number of locations in the U.S., especially the southern California coastal areas.

Vessel biofouling has been identified as an important pathway for the transport and introduction of ANS (Johnson et al., 2007). While ballast water receives the most attention regarding the movement of ANS, hull fouling is also a significant vector. For example, 90 percent of the 343 marine aquatic invasive spec ies in Hawaii are thought to have arrived through hull fouling (Carlton, 2001), while 36 percent of the nonnative coas tal marine species established in continental North America could be attr ibuted to hull fouling (Bax et al., 2003). In comparison, ballast water, by itself, may acc ount for 20 percent of documented invasions (Carlton, 2001). Over the last decade, the possible transfer of species by hull fouling has received growing attention and is now recognized as one of the most important pathways of ANS translocation (Candries, 2009).

1.3 S URVEY OF R EGULATIONS AND G UIDELINES FOR H ULL H USBANDRY

Internationally, the 2001 Inte rnational Convention on the Control of Harmful Antifouling Systems on Ships, which entered into fo rce in September of 2008, prohibits the use of harmful organotins such as tr ibutyltin (TBT) in AFCs used on international vessels and establishes a mechanism to prevent the potential fu ture use of other harmful substances in antifouling systems. The Intern ational Marine Organization’s (IMO) Marine Environmental Protection Committee (MEPC) adopted Guidelines for the Contro l and Management of Ships' Biofouling to Minimize the Trans fer of Invasive Aquatic Species at MEPC 62 in July 2011 (IMO, 2011). The management measures outlined within these voluntary guidelines are intended to complement current maintenance practices carried out within the industry. Specifically, the Guidelines address:

 Choosing the anti-fouling system : Different anti-fouling systems are designed for different ship operating profiles.Underwater Ship Husbandry Discharges Section 1 - Introduction

3  Installing, re-installing, or repairing the anti-fouling system : Whether installing, re-installing or repairing the anti-fouling system, care should be taken in surface preparation to en sure all biofouling residues, flaking paint, or other surface contamination is completely rem oved, particularly in niche areas, to facilitate good adhesion and durabil ity of the anti-fouling system.

 Procedures for ship maintena nce and recycling facilities: Ship maintenance and recycling facilitie s should adopt measures (consiste nt with applicable national and local laws and regulati ons) to ensure that viable biofouling organisms or chemical and physical pollutants are not released into the local aquatic environment.

Despite the use of effectiv e anti-fouling systems and ope rational practices, the MEPC Biofouling Guidelines acknowledge that undesira ble amounts of biofouling may still accumulate during the intended lifetime of th e anti-fouling system. To mainta in a ship as free of biofouling as practical, it may be advisable for the ship to undertake in-water inspection, cleaning and maintenance.

In the U.S., the Vessel General Permit (USEPA , 2008) limits discharges originating from AFCs, underwater ship husbandry, and seawater piping fouling. AFCs and chemicals used for fouling prevention subject to registrati on under FIFRA (see 40 CFR § 152.15) must be registered, sold or distributed, applied, mainta ined, and removed in a manner consistent with applicable requirements on the coatings’ FIFRA label. For biocides not subject to FIFRA registration (i.e., not produced fo r sale and distribution in the Un ited States), hull coatings must not contain any biocides or toxi c materials banned for use in the United States (including those on EPA’s List of Banned or Severe ly Restricted Pesticides). This requirement applies to all vessels, including those registered and painted outside the United States. The use of TBT AFCs is explicitly prohibited under the VGP, and vessels must remove such coatings or paint over them to prevent toxic leaching 2 . Under the VGP, underwater ship husbandry must be conducted in a manner that minimizes the discharge of f ouling organisms and AFCs, and the cleaning of copper-based AFCs must not produce a visible plume of paint.

The U.S. Coast Guard currently addresses hull fouling and hull hus bandry related to nonindigenous species through regul ations included in 33 CFR §151.2035 that require rinsing of anchors and anchor chains to remove organisms and sediment, and removal of fouling organisms from the hull, piping and tanks on a regular ba sis. Additionally, a lthough crude oil tankers engaged in coastwise trade are exempt from the requirements of 33 CFR §151.2035 by statute, many tank ship companies conduct voluntary hull maintenance operations, generally in conjunction with regular dry dock inspections manda ted by Merchant Class Societies such as the International Association of Cl assification Societies, Ltd (IACS ), and the U.S. Coast Guard.

2 The VGP’s zero discharge standard for TBT is consistent with the 1998 Organotin Anti-Foulant Paint Control Act, 33 U.S.C. 2403(a) which generally prohibits application of AFCs containing TBT. The zero discharge standard is also consistent with the Convention on the Control of Ha rmful Anti-Fouling Systems on Ships. The treaty, adopted by the IMO in October 2001, prohibits the use of organotin s in antifouling paints. The treaty entered into force on September 17, 2008.Underwater Ship Husbandry Discharges Section 1 - Introduction

4 These two entities typically require at least one dry dock inspecti on of a ship's hull every five years (Takata et al., 2006; USCG, 2000).

Three states have also adde d requirements related to hull cleaning and maintenance as part of their Clean Water Act (CWA) 401 certi fications to the VGP. With the exception of propeller polishing, California pr ohibits underwater cl eaning on all vessels except those using biocide-free AFCs. Biocide-free AFCs have been designated as a "best available technology", and vessels utilizing such coatings may conduc t underwater cleaning in California waters (USEPA, 2008). Maine and Massachusetts bo th prohibit underwater cleaning and fouling removal.

Table 1 provides a summary of the interna tional, United States, and individual State regulations regarding hull husbandry.

Table 1. Summary of Current Internationa l and U.S. Management Strategies for Underwater Ship Husbandry

Country or State Management Strategy Details

IMO Guidelines Develop a biofouling management plan Maintain a biofouling recordbook that details all inspections and biofouling management activities Install and maintain an antifouling systems Conduct in-water insp ections, cleaning and maintenance; Design and construct vessels to minimize biofouling.

Australia Prohibition (States/territories/ports) States and territories proh ibit underwater cleaning. Many require containment and disposal of fouling debris removed during out-of-water cleaning. Regulation (Vessels less than 25 m) Keep ancillary gear and internal seawater systems clean of marine pests and growths, and

Before departing your last port for Australia:

 Clean hull within one month before arrival
OR

 Apply antifouling paint within one year
before arrival OR

 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)

New Zealand Import Health Standard (pending) Vessels arriving from foreign countries would be required to have a ‘clean’ hull, meaning no visible aquatic organisms, other than a slime layer.Underwater Ship Husbandry Discharges Section 1 - Introduction

5 Table 1. Summary of Current Internationa l and U.S. Management Strategies for Underwater Ship Husbandry

Country or State Management Strategy Details 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 dry-docked and cleaned? 3. Do you intend to clean the hull of the vessel in
New Zealand? Voluntary Code 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 must be inspected and cleaned before departure. If otherwise inspected in NZ and if necessary, fouling must be removed so no foreign organisms
enter the marine environment.

Australia and New
Zealand Environmental

Conservation Council (ANZECC) Codes of Practice Underwater hu ll 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.

United States VGP Underwater ship husbandry must be conducted in a manner that minimizes the discharge of fouling organisms and antifouling hull coatings, and the cleaning of copper-based AFCs must not produce a visible plume of paint. Rinse anchor chains and anchors at place of origin. Remove fouling from hull, piping and tanks on a regular basis. Dispose wa stes in accordance with local, state, and federal law.

California State VGP 401 certification requirement Propeller cleaning is allowed until January 1, 2012. All other underwater hull cleaning is prohibited without special permission from the State Lands Commission (SLC) and State Water Board. Submit annual Hull Husbandry Reporting Form. Rinse anchor chains and anchors at place of origin Remove fouling from hull, piping and tanks on a regular basis. Dispose wa stes in accordance with local, state, and federal law.Underwater Ship Husbandry Discharges Section 1 - Introduction

6 Table 1. Summary of Current Internationa l and U.S. Management Strategies for Underwater Ship Husbandry

Country or State Management Strategy Details

Hawaii Information Framework Targeting High Risk Vessels (Proposed) Pro-active measures: Edu cation/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

Maine State VGP 401 certification requirement No vessel may conduct underwater hull cleaning except as part of emergency repairs

Massachusetts State VGP 401 certification requirement Hull husbandry discharges are prohibited within 3
miles of shore.

Merchant
Classification Societies Requirements (Applies to majority of merchant fleet) Dry dock requirements vary somewhat depending on classification society. Cleaning and painting is usually conducted, but is at the discretion of the company. Interim underwater cleanings are done periodicity at the discretion of the company, typically dependent on results of fuel consumption tests.
Source: Takata, 2006. IMO: International Maritime OrganizationUnderwater Ship Husbandry Discharges Section 2 - Factors Effecting Biofouling

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## SECTION 2

FACTORS EFFECTING BIOFOULING

Biofouling organisms attach to submerged ha rd surfaces of both naturally occurring and man-made structures (Railkin, 2004) . Species that foul vessel hulls are typical of natural, marine intertidal and subtidal fouling communities. Ma rine fouling communities can include arthropods (barnacles, amphipods, and crabs), mollusks (m ussels, clams, and sea slugs), sponges, bryozoans, coelenterates (hydroids and anemone s), protozoans, annelids (marine worms), and chordates (sea squirts and fish), as well as macroalgae (seaweed). If these fouling communities become highly developed they can also provide micro-habitats for mobile organisms such as fish.

Typically, there is a progressi on of attachment of marine organisms to a vessel’s hull (Floerl et al., 2010). Primary biof ouling begins as soon as the surface of a vessel is submerged in seawater, with the formation of a slime layer cons isting of bacteria and mi croscopic algae. As the vessel remains submerged in seawater, second ary biofouling occurs as organisms settle on top of the primary biofouling layer. Secondary biofouling usually incl udes hard encrusting animals such as acorn barnacles, bryozoans and se rpulid worms, but may al so include soft algal tufts and mobile amphipods. If the hull is coated w ith an AFC containing a biocide, the toxicant will act to deter the attachment of higher form s such as barnacles and tubeworms, but will usually allow primary biofouling within days or weeks of launchi ng with fresh AFC.

Although biofouling progresses in a predictable manner, it is not a uniform process. For example, biofouling is not evenly distributed on submerged portions of vessels because a vessel's hull is not a uniform surface. Certain movement patterns and environmental factors have been observed to affect the diversity (variety of sp ecies) and the quantity of biofouling observed on commercial vessels. The factors likely to affect the rate of biofouling include:

 Immobile periods;

 Vessel speed;

 Voyage duration;

 Voyage movement patterns; and

 Environmental factors (salinit y, temperature and nutrients).

These factors influence the ability of free swimming or floating or ganisms to attach to a vessel and remain affixed, or affect the ability of th e organism to survive voyages. Each of these factors is discussed in the following sections.

2.1 I MMOBILE P ERIODS

The level of fouling is related to the amount of time a vessel spends in port (Cordell et al., 2009). In general, the longer a ship stays pierside, the more likely it is to accumulate fouling. Many floating or free swimming organisms are better able to attach or “settle” on surfaces while vessels are immobile, and vessels th at spend long stationary periods have been observed to have heavier fouling communities (C outts, 1999). Because larval settlement may be prevented by speeds as slow as 2 knots (Davidson et al., 2006 ), accumulation predominantly occurs while a vessel is docked, and increases over time. This is es pecially true in protected ports with restrictedUnderwater Ship Husbandry Discharges Section 2 - Factors Effecting Biofouling

8 flow and poor flushing where pr opagules (the small, dispersi ng larval phase of marine invertebrate life cycles) may be retained in the water column for long periods of time (Takata et al., 2006).

Assuming suitable environmental conditions, bi ofouling is likely to increase with the residence time of a vessel (Floerl et al., 2005), by providing attached organisms sufficient time to become reproductively viable. However, it is wort h noting that some vessels may also visit a port or region where suboptimal environmental conditi ons prevail (e.g. low salinity, high turbidity), and in such cases, ANS release risks may be miti gated through die-off of the fouling organisms.

Typically, most commercial ships operate the majority of the time, while naval vessels may spend long periods of time pierside. For ex ample, commercial ships may be at sea 85 percent or more as they only generate revenue when delivering cargoes (Bohlander, 2009), the exception being commercial vessel inactivity due to economic downturn. In contrast, the general operating cycle for the U.S. Navy vessels is betwee n 40-60 percent pierside with the rest at sea (US Navy and USEPA, 2003). With the decline in fish catches in many parts of the world, many commercial fishing vessels are underutilized and poorly maintained, with vessels being laid up and/or sold off for other purposes . These vessels may represent a c onsiderable risk in terms of hull fouling due to the time they are pierside (Candries, 2009).

2.2 V ESSEL S PEED

Vessel speed influences the quantity and divers ity of fouling species observed on vessels. At high speeds, many organisms are unable to re main attached to vessel hulls because they cannot endure the forceful water moving past the surface. Less robust organisms may be dislodged or may be unable to surv ive. In contrast, slow speeds are less stressful, allowing many fouling organisms to remain attached or contin ue settling on the vessel surface (Takata et al., 2011). Thus, slower moving vessels have been observ ed to accumulate thicker fouling than faster vessels that travel over 18-20 knots (Michin and Gollasch, 2003).

Vessel speed can also affect th e survival of invasive spec ies. Long-distance travel is becoming easier and faster. This enables more inva sive species to survive long enough to reach a new environment (Ruiz et al., 2000). For example, Cordylophora caspia , a hydroid that lives in both freshwater and brackish wa ter, may have been transporte d successfully because of an increase in ship speeds (Johnson et al., 2007)

Boats that travel at slower speeds are also susceptible to invasions because more species can attach firmly to their hulls (Michin and Gollasch, 2003). Furthermore, some nontoxic AFCs may only be effective if the vessel travels regularly at 15 knots to 20 knots (Swain et al., 2001). Such coatings would be ineffective in preventi ng attachment of invasi ve species on hulls of vessels that seldom or never reach or exceed those speeds (Johnson et al., 2007).

2.3 V OYAGE D URATION

Shorter voyages have been observed to be more advantageous for the survival of coastal fouling organisms and communities than longe r voyages. The prolonged exposure to harsh physical conditions of the open ocean during a long voyage may be detrimental to fouling organisms, or they may be deprived of food fo r an untenable length of time (Coutts, 1999). ShipsUnderwater Ship Husbandry Discharges Section 2 - Factors Effecting Biofouling

9 with effective AFCs tend to lack fouling if the vessel has travel ed for 9.75 days or more in open waters (Johnson et al., 2007).

2.4 V ESSEL M OVEMENT P ATTERNS

The expansion of global trade has lead to signi ficantly more ballast water, fouled hulls, and associated organisms moving around the wo rld (Minchin and Golla sch, 2003). Each year there are approximately 1.7 million visits by vess els to the world’s 4,700 ports (Etkin, 2010). In the U.S., there are about 110,000 annual vessel visits to ports and other places (Miller et al., 2007).

Large estuaries with international shipping serve as sources for species that become invasive in other geographic re gions. In other words, larger ships likely accomplish most of the long-distance transport (primary introduction) wh ile commercial fishing and recreational boats likely contribute to the transpor t of invasive species along the coast (secondary introduction) (Johnson et al., 2007).

Traveling to a wide range of locations may also be an ANS risk factor because it increases the likelihood that an or ganism with a broad range of to lerances will atta ch to a vessel hull. Furthermore, a number of ANS have been in troduced far outside their places of origin, and are becoming pandemic. In these cases, the rate of new introductions is accelerating, possibly due to increasing sources for s econdary introductions, a nd the spread of physio logically tolerant ANS (Cohen and Carlton, 1998).

For example, secondary introduction poses a ri sk to Alaska from domestic and coastwise ports. Introduced species have already demonstr ated an ability to successfully colonize these Alaskan waters. A combination of factors such as fewer temperature and salinity changes and shorter voyages may mean that there is a high er risk of secondary ANS contamination of Alaskan waters from vessels traveling on co astal voyages (e.g., from Puget Sound or San Francisco Bay) than of primary contaminati on from vessels traveling from more distant locations.

Cordell et al. (2009) analyzed shipping pa tterns in Prince William Sound, Alaska. They identified two categories of vessels: those that have set routes and make numerous brief return trips to the same port, and those that return to port infrequently but stay in port for long periods of time. The first type presents a risk of repeat inoculations of ANS (potential high propagule frequency), and the second represents ANS risk ba sed on less frequent inoculations with longer “incubation” time for ANS to release propagules (potential high propagule volume). Tank ships and passenger vessels represent the high freque ncy risk category, while freight and fishing vessels represent the high volume risk categor y. Commercial fishing and commercial passenger fishing boats share some features of commercia l shipping: they travel often and some go to distant fishing grounds. They also share some f eatures of recreational boats: they may spend much time within a region and many are small cr aft, whose underwater structures are more like those of pleasure craft than commercial cargo ships, tugs and barges (Johnson et al., 2007).

Movements of military vessels also creat e pathways for ANS introduction. Invasive species have been documented on the hulls of military vessels in Hawaii. Analyses of benthic organisms and fishes of Pearl Harbor sampled in 1996 suggests two periods of relatively high introduction rates corresponding to wartime periods . Most of the introduc ed species with knownUnderwater Ship Husbandry Discharges Section 2 - Factors Effecting Biofouling

10 geographic origins have distributions extendi ng to the Indo-West Pacific. However several species are known from the Red Sea and the Caribbean Sea (Coles et al., 1999).

2.5 E NVIRONMENTAL F ACTORS (S ALINITY , T EMPERATURE AND N UTRIENTS )

The accretion of marine fouling can be highly variable, depending on geographical location, time of year, and seasona l variations in weather. In ge neral, fouling flourishes during warmer months and diminishes in cooler mont hs. Due to reproductive periodicity of fouling organisms, propagule amounts can vary by season , with summer and spring typically having higher propagule numbers than winter and fall (Davidson et al., 2006). Fouling organisms may also release viable propagules in response to new environmental cues (e.g., alte red salinity or temperature) in a recipient region and inoc ulate surrounding habitats including artificial structures (Minchin and Gollasch, 2003).

Vessels that operate in waters with rapid a nd drastic changes in sa linity and temperature, such as those that pass through both marine and fresh water or conduct transequatorial voyages, may experience reduced survivorsh ip of fouling organisms by s ubjecting them to a range of conditions outside their physiologi cal limits (Davidson et al., 2006; Takata et al., 2006). On the other hand, Coutts and Taylor (2004) found that ve ssels that travel through similar latitudes may experience increased survivorship of fouling organisms by retaining re latively consistent temperature and salinity levels.

Ocean warming due to climate change will stimulate the growth of barnacles and other biofouling organisms, potentially adding billi ons in operational costs of worldwide shipping (Williams, 2011). In laboratory tests for whic h seawater was warmed 3.5°C above current averages (a scenario that represents ocean wa ter temperatures expected in the year 2100), organisms in a typical biofouling community gr ew twice as fast as they do under current conditions, and formed a thicker layer of fou ling. In addition, increased fouling from ocean warming may increase risk of ANS transport. Ocean warming also compounds the problem of ANS by opening new routes for invasions, such as the Northwest Passage which has been icefree since 2007, and by favoring the colonization, survival, and growth of some invasive species over native species.Underwater Ship Husbandry Discharges Section 2 – Factors Effecting Biofouling Coatings

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## SECTION 3: ANTIFOULING COATINGS

AFCs are the primary mechanism for reduci ng biofouling of the underwater portions of vessels. AFCs can be categorized into: a) those that control hull biofoulin g by releasing biocides and b) non-biocidal coatings, which (most commonl y) provide surface charac teristics that inhibit the attachment and adhesion of biofouling organism s. Each of these types of AFCs are discussed in the sections below along with best management pr actices to minimize th eir release during hull husbandry activities.

3.1 AFC S C ONTAINING B IOCIDES

Virtually all vessels that are permanently kept in saltwater use AFCs , and the majority of AFCs presently in use contain biocidal chemical s to inhibit the colonizat ion of the vessel’s hull (Minchin et al., 2003). These chemicals, which are toxic to fouling organisms, are slowly released from the coated surface into the surrounding waters. The primary constituent used in most biocidal AFCs is copper, although zinc may also be used as an ingredient.

While the rate at which the metals leach from coatings is relatively slow (4 – 17 μg/cm 2 /day), these coatings can account for signifi cant accumulations of metals in receiving waters of ports where numerous vessels are pr esent (USEPA, 2010). Copper-based coatings have the potential to cause environm ental harm. For example, hi gh copper concentrations at California’s Shelter Island Yacht Basis (SIYB) of San Diego Bay threaten sediment quality and may potentially adversely impact benthic life. The State Water Resources Control Board will require a 76 percent reduction of copper disc harges from antifouling paints in SIYB by 2022 (California Regional Water Qu ality Control Board, San Dieg o Region. 2006). Ninety-three percent of the copper in the SIYB was attribut ed to the passive leaching of copper-based AFP pesticides that have been app lied to boat hulls. Copper releas ed from underwater hull cleaning contributed 5 percen t (Singhasemanon, 2010). Other parts of San Diego Bay have been listed on the California SWRCB 303(d) list of impaired water bodies for dissolved copper and actions in other southern California boat basins suggest copper-containing AFCs ma y soon be restricted elsewhere in the region (California Regional Wa ter Quality Control Board, Los Angeles Region, 2005; USEPA, 2002).

Increased biocide release rates may also occur during hull husbandry activities, particularly if hulls are cleaned within the firs t 90 days following AFC application (Schiff et al., 2003).

The predominant AFCs on the commercial market are briefly discussed below.

Insoluble Matrix / Contact Leaching / Hard Coatings

Conventional insoluble matrix or ‘contact leaching’ systems are based on hard, porous resins that are insoluble and do not erode in s eawater (Floerl et al., 2010 ). Examples of these compounds include acrylic, vinyl, epoxy and ch lorinated rubber polymers (AMOG, 2002). Modern hard-type formulations (which are us ually based on modified epoxy matrices) provide improved control over biocide release rates, particularly for copper-based coatings, with effective life expectancies of between 24 and 36 months (Floerl et al., 2010). Of the AFCs commonly used today, hard-type coatings provid e the best resistance to damage by abrasion,Underwater Ship Husbandry Discharges Section 2 – Factors Effecting Biofouling Coatings

12 affording successful protection for vessels, or areas of vessels, that are subj ect to elevated levels of wear. An advantage of this coat ing type is that the hard, insolubl e matrix is resilient to damage by oxidation, providing a longer coat ing life Almeida et al., 2007).

Controlled Depletion Polymer / Ablative Coatings

Controlled depletion polymer (CPD) syst ems are also known as ablative coatings. Ablative coatings are designed to slough off layers of matrix and biocides as water moves over the hull surface, providing a self-polishing mechan ism to maintain hull smoothness. This process also promotes self-cleaning by presenting an unsta ble, biocidal surface for biofouling organisms. CPD coatings provide effective biofouling protec tion and, since thicker layers of CDP coatings can be applied in comparison to conventional soluble matrix systems, the effective life is increased to up to 36 months in suitable conditions. However, traditional hull-cleaning techniques, such as scrubbing, can damage and remove the coating and shorten the life span. CDP coatings provide the lowest cost per meter squared of AFC and are suitable for use in low biofouling conditions or by vessels with short dr ydock intervals (Floerl et al., 2010). They are widely used by recreationa l vessels and small ships (Almeida et al., 2007).

Self-polishing Copolymer Coatings

The ban on the use of TBT as a biocide has prompted the development of alternative TBT-free self-polishing copolymer coatings (SPCs). This “new technology” of TBT-free SPCs uses copper acrylate, zinc acrylat e and silyl polymers in-place of TBT (Floerl et al., 2010). TBTfree SPCs are claimed to provide self-polishing pe rformance, controlled biocide release rates and long-term performance comparable to TBT-SPCs. New products are marketed with effective working lives similar to TBT-SPCs (up to 60 months ). Almeida et al. (2007) indicate that the maximum service life of this type of coating is usually three years, but effective life spans of up to five years have been reported.

3.2 N ON -B IOCIDAL AFC S

It has long been a goal of paint companies to produce an antifouling paint that does not contain toxic ingredients (Bohl ander, 2009). There are several benefits to such a coating, including less stringent environm ental regulation for use and disposal, no or low impact on the local marine environment from the leaching of to xic ingredients into th e water column, reduced hazards to the shipyard workers applying and removing the paints, and reduced generation of hazardous materials during application and remova l. Recent research and development efforts have therefore focused on alternative an tifouling mechanisms and non-biocidal active compounds that can provide ‘environme ntally safe’ options (AMOG, 2002).

Several biocide-free systems are in development, but currently the systems that have been developed and successfully marketed are based on “non-stick” silicone based fouling-release technology. These coating systems provide surfac e characteristics that aim to prevent the adhesion of biofouling organisms or allow biof ouling to accumulate, but prevent adhesion as organisms grow or are subjected to water movement (Floel et al., 2010). Fouling-release coatings provide an expected effective life of five years or longer (AMOG, 2002), but are more difficult and expensive to apply than other AFCs.Underwater Ship Husbandry Discharges Section 2 – Factors Effecting Biofouling Coatings

13 Antifouling success of fouling- release coatings currently relies on vessel speed and movement to dislodge any organisms that do attach. Self-cleaning of hulls has been demonstrated for vessels that frequently main tain speeds between 15 and 30 knots, depending on the biofouling community (AMOG, 2002; Chambers et al. 2006; Floerl et al., 2010). Coating manufacturers claim propulsive fuel efficiencies of 3-11 percent, which can be realized if the ships using these products cruise at speeds rang ing from 10-18 knots, and spend relatively little time pierside (Floerl et al., 2010). Therefore, this technology is currently best suited to fastmoving vessels with rapid port turn-around periods and sufficien t activity levels. The foulingrelease AFCs are establishing a market in commerci al shipping fleets, primarily with cruise ships and fast container ships, as these vessels have op erational profiles that are suitable for use of foul release paints.

There are several manufacturers of fouling re lease paints, with a variety of products on the market. All share the characteristic of gene rally allowing marine fou ling to attach to the coating while the ship is pierside, then claimi ng the biofouling will detach with ship movement. However, it is also possible that ships using f ouling release coatings could transfer ANS from one location to another if the coating does not comp letely self-clean. There is also likely to be variability in performance for th ese products, and while they are in regular commercial use, it will take additional time to get a clear indication of the benefits and operating characteristics of these materials as well as their potential for ANS transmission. Fouling-release coatings may still require hull cleaning. There is a pos sibility that the cleaning proc ess may damage these coatings, allowing increased fouling growth. The underwat er cleaning of fouli ng-release or other nonbiocidal AFCs can still pose an environmental risk via the uncontrolle d release of ANS during the cleaning operation.

3.3 B EST M ANAGEMENT P RACTICES FOR AFC L EACHATE

In the 2008 VGP, in addition to prohibiting the discharge of TBT, EPA identified two main BMPs for control of AFC leachate. The first type of BMP regards applying coatings according to the instructions on the coating’s FIFRA label when applicable. The second type of BMP addresses the need for particular coatings an d selection of the type of coating to apply. EPA noted that the vessel owner/operator must c onsider the fouling rate of the hull and other underwater areas of the vessel, the vessel’s operating speed, th e drydocking frequency, and the waters in which the vessel will be traveling when selecting the appropriate antifouling system for a particular vessel.

A third potential BMP regards matching the co ating’s abilities or strength to drydock cycles. Larger vessels, particular ly those used in trade and car go transport, must adhere to requirements for safety inspections and maintenan ce activities that dictate how frequently they must be drydocked. The major ma nufacturers of hull coatings fo r this industry guarantee the effectiveness of their products for a certain period of tim e based on ship and operational characteristics; vessel owner/ operators could match the hull co ating choice to the appropriate drydocking interval. By factoring this schedule into th e hull coating selection, vessel operators could select coatings that w ould sufficiently protect the vessel for the period of time needed while reducing unnecessary leachate or wastes.Underwater Ship Husbandry Discharges Section 4- Hull Husbandry Best Management Practices

14 

## SECTION 4

HULL HUSBANDRY BEST MANAGEMENT PRACTICES

Regulatory agencies have begun developi ng BMPs for hull husbandry practices to prevent and/or control the tr ansport and introduction of ANS by commercial shipping and to reduce the loss of AFCs to surf ace waters during hull husbandry act ivities. Table 2 summarizes vessel husbandry BMPs for various internationa l organizations, states and classification societies.

In general, BMPs for hull husbandry require that rigorous hull-cleaning activities take place while the vessel is in drydock, or another la nd-based facility where the removal of fouling organisms or spent antifouling paint can be contained and treated. In the 2008 VGP, EPA required that vessel owner/operato rs who must perform hull husbandr y while the vessel is in the water should use methods that minimize the discharge of fouling organisms and AFCs. These methods include (USEPA, 2008):

 Selection of appropriate so ft cleaning brush or sponge rigidity to minimize the release of paints and hull materials including AFCs into the water column;

 Limiting use of hard brushes and surfaces to the removal of hard growth; and

 Use of vacuum cleaning technologies (w hen available) in conjunction with mechanical scrubbing, to minimize the rel ease or dispersion of AFCs and fouling organisms into the water column.

EPA also requires vessel owne r/operators to minimize the release of copper based antifoulant paint into th e water column when they clean th e vessel. Cleaning of copper based antifoulant paints should not resu lt in any visible cloud or plume of paint in the water, and if one develops, then the person doing the cleani ng should change to a softer brush or less abrasive cleaning technique (USEPA, 2008).Underwater Ship Husbandry Discharges Section 4 - Hull Husbandry Best Management Practices15Table 2. Hull Husbandry Best Management Practices (BMPs)for International Organizations, the U.S., States andClassification SocietiesHull HusbandryBMPIMOUS EPA (VGP)CaliforniaMaineMassachusettsMerchantClassificationSocietiesOut-of-Water HullMaintenanceWhenever possible,rigorous hull-cleaningactivities should takeplace out of water,where foulingorganisms and AFCscan be contained. Usefacilities which treatwash water from highpressure washing priorto discharge.Remove fouling by physicalcleaning (e.g., hull and nichecleaning during the vesselsscheduled 5 year out-ofwater dry-docking).All hull cleaningshall occur while avessel is in drydockor at anotherlandside facility sothat wash water andhull cleaningresiduals can becollected anddisposed ofproperly.Generally requirevessels to be drydocked at least onceevery five years.None of thesocieties requiresthe hull to becleaned while drydocked, but mostcompanies do.Underwater HullCleaningFollow applicableregulations/requirements for underwatercleaning. Use cleaningtechniques that minimizerelease of biocides for hullscoated in biocidal AFCs.Remove macro-foulinggrowth in accordance withregulations. Minimizerelease of AFC debris andviable macrofoulingorganisms by soft cleaningUse cleaning techniques(e.g., select appropriatebrush, contain debriswith vacuum system)that minimize dischargeof fouling organismsand AFCs. Cleaningcopper-based AFC mustnot produce visibleplume of paint.All underwater hull cleaningis prohibited unlessconducted using the bestavailable technologieseconomically feasible (e.g.,allowed for biocide-freeAFCs, not allowed forcopper-based AFCs inimpaired waters).Prohibited except aspart of emergencyhull repairsnecessary to securethe vessel.Dischargesassociated withunder-water shiphusbandry(specifically theremoval of foulingorganisms) areprohibited in waterswithin 3 nm.Although notrequired, mostcompanies alsoconduct interimunder-watercleanings accordingto fuel performancetests, in order tomaintain costeffective fuelefficiency.Underwater Cleaningof Sea Chests andNiche AreasOutlines managementmeasures for niche areas.Propeller PolishingRecommends regularpolishing of uncoatedpropellersPropeller cleaning isallowed until January 2012.After that date, propellercleaning will be allowedonly as specified inregulations adopted by SLC.Rinse Anchors andAnchor ChainsRinse to removeorganisms/sediments attheir place of origin.Underwater Ship Husbandry Discharges Section 5 - Vessel Husbandry Debris Containment Options

16 

## SECTION 5

VESSEL HUSBANDRY DEBRIS CONTAINMENT OPTIONS

Underwater hull cleaning can be quite effective at removing marine fouling; however, the effluent stream from cleaning is difficult to c ontrol. Standard underwat er hull cleaning tools, including multi-brush and single brus h tools, typically have no inhe rent capability to contain the discharge of coatings and biofouling organi sms removed during hull cleaning. Instead, these particulate materials are commonly re leased into the water column.

The potential for water quality impairme nt and ANS release resulting from the uncontained discharge of underwat er cleaning effluent is wide ly recognized. For example, underwater hull cleaning has been banned acco rding to the ANZECC Code of Practice (ANZECC, 1997).

Due to this scrutiny, a number of underwater cleaning technologies have been developed to retain the abraded paint, rust , and biofouling organisms. At pr esent, several of these systems are becoming commercially available. Bohlander (2009) conducted a revi ew of underwater hull cleaning practices, and found four systems that were designed to contain and capture cleaning effluent and transfer this wast ewater stream to the surface for treatment. These systems include: 1) the U.S. Navy Advanced Hull Cleaning Syst em (AHCS) and Automated Hull Maintenance Vehicle (AHMV), 2) the modified SCAMP from Seaward Marine Services, 3) the HISMAR system based in the United Kingdom, and 4) the Norwegian CleanROV system.

Two of these systems are currently being used for hull cleaning: the AHCS and the CleanROV. Only one of these systems, the AHCS, includes a wastewater treatment system along with the capability to process larger calcareous fouling. The AHCS fulfilled most of the need for contained hull cleaning, although it was develo ped specifically for the Naval Sea Systems Command (NAVSEA) and is not av ailable to commercial vessels at this time. The AHCS and the CleanROV systems are discusse d in the following sections.

5.1 U.S. N AVY A DVANCED H ULL C LEANING S YSTEM (AHCS) AND A UTOMATED H ULL M AINTENANCE V EHICLE (AHMV)

The U.S. Navy developed a prototype multi-br ush hull cleaning system that captures the debris generated from hull clean ing and transports it to the pi er for processing in a mobile treatment trailer. The AHCS was developed primarily to reduce th e amount of copper discharged during hull cleaning of U.S. Navy ships. It was not specifically devel oped to process marine biofouling, although biofouling is also c ontained and processed by the system.

Floerl et al. (2010) also re ported on the development of an Automated Hull Maintenance Vehicle (AHMV), a specialized remotely ope rated vehicle (ROV) t echnology developed for automated underwater hull maintenance and inspec tion of U.S. Naval ships. The unit addresses the expense and environmental implications of tr aditional diver-operated cleaning equipment that discharge potentially toxic effluent into the ma rine environment, along with biofouling debris and potential ANS (Floerl et al., 2010). Biofoul ing is cleaned from the hull using rotating brushes incorporated into the uni t, and the debris is collected by a vacuum-sealed mantle thatUnderwater Ship Husbandry Discharges Section 5 - Vessel Husbandry Debris Containment Options

17 surrounds the AHMV. Particulate matte r is transported to the surface for treatment (filtration to remove particles > 20 microns (μm) via filtration) and disposal.

The AHCS and AHMV have the potential of saving the U.S. Navy 10 percent on fuelcosts, and may result in lower environmental im pact from the routine cleaning of navy vessels. Floerl et al. (2010) were unable to obtain detailed informa tion on test results of these units, particularly on the AHMV’s effectiveness at re moving biofouling from targeted areas and at collecting and containing biofouling and paint wa ste. Since no additional information could be found, it is difficult to assess the availability of these technologies for hull husbandry of commercial vessels.

5.2 S CAT H ARDING (N ORWAY ) C LEAN H ULL AS

The Norwegian company Scat Harding developed the CleanHull AS, a ROV for underwater hull cleaning with inte grated water filtration and wast e recovery. The CleanHull AS is designed to clean large, flat surfaces with minimum curvature and biofouling assemblages at early stages of development (e.g., algal grow th and small barnacles). Preliminary (and unpublished) test results indicate an effectiveness of close to 1 00 percent in removing biofouling from such areas (Floerl et al., 2010). CleanHull AS cannot clean niche areas such as propellers, rudders, thrusters or similar irre gular structures. Biofouling is re moved from hull surfaces using an underwater high-pressure water blast. The po wer of the water-blast varies depending on the type of AFC on the hull (e.g., silicone-based paints require ge ntler treatment).

The removed biofouling material is captured via a particulate containment system that includes a vacuum that pumps the recovered material into a filter unit. The company estimates that approximately 98 percent of the biofouling material removed during cleaning is captured and contained during this process. However, supporting documentation was not supplied and no information is available on the particle sizes th at can be captured by the system (Floerl et al., 2010). Apparently, extensive testing in collabora tion with several major AFC manufacturers has been undertaken. Results (which were also not ava ilable to Floerl et al.) indicate that the waterblasting action of CleanROV has no negative eff ect on the performance of the AFCs, including biocide-free silicon-based products. This is seen as its principal advantage over more abrasive techniques such as rotating brushes.

Scat Harding offers fleet service agreements involving multiple treatments per year. The ROV is not intended for use on heavily fouled ships, as the principal objective of the system is to preserve or reinstate the perfor mance of a ship’s AFC. The CleanHull AS services are currently offered at ports in Norway; in the Skagerak Strait; Vlissingen and Rotterdam in the Netherlands; Algeciras, Spain; Southampt on, UK; United Arab Emirates; a nd Singapore (Scat Harding, 2009).Underwater Ship Husbandry Discharges Section 6 - Hull Husbandry Costs

18 

## SECTION 6

HULL HUSBANDRY COSTS

Although hull husbandry can facil itate the release of ANS and pollutants such as copper, cleaning biofouling from the hulls and niches of commercial vessels re duces hydrodynamic drag and the associated increase in fuel consumption. Floerl et al. (2010) deve loped cost estimates for hull and niche cleaning of commer cial vessels with lengths rangi ng from 25 to 200 meters. Costs were estimated for both out-of-water (slip way and drydock) and underwater cleaning by available technologies, based on quotes obtained from facilities and professional cleaning crews in Australia and New Zealand. These cost estimates are presented in Table 3.

The cost estimates in Table 3 have been convert ed from Australian to U.S. dollars and, as noted by Floerl et al. (2010), are subject to large variations in ra tes charged by providers of these services. The costs of services such as drydocking, slipway hire , professional cleaning crews for water-blasting and painting, charges for water us age, waste removal and treatment and other associated activities vary greatly between facilities and countries. Furthermore, the cost estimates do not include the lost revenue incurred while vessels are traveling to and fr om cleaning facilities and the time out of service while waiting to be cleaned.

As indicated by Table 3, the cost for removi ng a medium-sized ship (25–60 m in length) from the water in a slipway and cleani ng via water-blast is approximately $2,800–$12,000, excluding lost operating revenue. Th e application of AFC following cl eaning is estimated to cost an additional $6,500–$24,500.

The costs for dry docking and cleaning a 25–60 m vessel using high-pressure water-blast (8,000 psi) at a New Zealand drydock range s from $8,800–$28,800 depending on vessel size. The application of additional AFC w ill add $34,900–$87,900 depending on vessel size.

Cost estimates for advanced underwater hull cleaning technologies using rotating brushes and water blast combined with a particulate co ntainment system are al so provided in Table 3. The estimated cost of underwater removal of bi ofouling from all hull a nd niche areas of a 50 m long ship range from $10,300 to $26,300, plus one to two days of lost revenue. For vessels ranging in size from 100 to 200 meters in length, these costs increase to as much as $96,000 plus three to five days of lost revenue while the vessel is being cleaned.Underwater Ship Husbandry DischargesSection 6 - Hull Husbandry Costs19Table 3. Estimated Costs of One-Time Out-of-Water and Underwater Hull HusbandryLocationTreatmentVessel Length (meters)25405060100200Slipway (out of water)(Australia)Hull Cleaning viaWater Blasting$2,800$6,300$12,000Apply new AFC*$6,500$15,200$24,500Drydock (New Zealand)Hull Cleaning viaWater Blasting$8,800$13,200$28,800Apply new AFC*$34,900$55,600$87,900Drydock (Australia)Hull Cleaning viaWater Blasting$25,900$83,800$191,400Apply new AFC*$29,500$146,300$417,200UnderwaterHull Cleaning viaDiver-OperatedRotating Brush andParticulateContainmentSystem$10,300-$19,100$20,300-$30,800$64,100-$76,400UnderwaterHull Cleaning viaROV Water Blastand ParticulateContainmentSystem$12,100-$26,300$25,500-$41,200$79,800-$96,000Source: Adapted fromFloerl et al., 2010.Note: * AFC application is a cost in addition to hull cleaning.Underwater Ship Husbandry Discharges Section 6 - Hull Husbandry Costs

20 The cost of underwater cleaning of hull and niche areas using technologies that remove biofouling organisms from a vessel hull (i.e. brushe s and water-blast) is generally lower than the cost for removing a vessel from the water for cl eaning only. However, because of variation in the rates different operators charge for the same se rvice, the relative diffe rence in cost between underwater and shore-based water cl eaning is also variable. Nevert heless, for commercial vessels of 50–200 m in length, a comprehensive underwater hull cleaning is 35–65% less expensive than biofouling removal at a slipway or drydock. This difference in cost may further increase when indirect costs such as losses in revenue are inco rporated. However, several factors offset the cost savings of underwater cleaning relative to out-o f-water cleaning. The effectiveness of underwater cleaning operations is likely to be lower than that of cleaning activities out of the water. Furthermore, all commercially-available underwat er cleaning technologies are either unable to treat niche areas (e.g., underwater jet systems) or are unable to capture and retain all of the biofouling material removed during the treatme nt process (e.g. rotating brush systems).Underwater Ship Husbandry Discharges Section 7 - References

21 

## SECTION 7

REFERENCES

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