This document includes the Draft Surface Vessel Bilgewater/Oil 

Water Separator Discharge Assessment Report for the Uniform 

National Discharge Standards Program. The reference number is: 

EPA-842-D-06-005

DRAFT 

Discharge Assessment Report 

Surface Vessel Bilgewater/Oil Water 

Separator 

June 2003 
DRAFT 

DISCHARGE ASSESSMENT REPORT

SURFACE VESSEL BILGEWATER 

Prepared by: 

Naval Sea Systems Command 

U.S. Department of the Navy 

Office of Water 

U.S. Environmental Protection Agency
DRAFT - Surface Vessel Bilgewater – DAR 

T A B L E O F C O N T E N T S 

1.0 INTRODUCTION ............................................................................................................... 1

1.1 SURFACE VESSEL BILGEWATER/OWS EFFLUENT DEFINITION................................. 2

1.2 APPLICABLE U.S. LAWS AND INTERNATIONAL STANDARDS ...................................... 2

1.2.1 Introduction....................................................................................................................2

1.2.2 Relevant International Standards ................................................................................... 2

1.2.3 Relevant U.S. Laws........................................................................................................ 3

2.0 VESSELS GENERATING SURFACE VESSEL BILGEWATER/OWS 

EFFLUENT .......................................................................................................................... 3

2.1 INTRODUCTION............................................................................................................. 3

2.2 BILGEWATER VESSEL GROUPING DOCUMENT SUMMARY ......................................... 4

3.0 OVERVIEW OF DISCHARGE ANALYSES................................................................... 6

3.1 INTRODUCTION............................................................................................................. 6

3.1.1 Potential Marine Pollution Control Device Options ...................................................... 6

3.1.2 MPCD Screening Results ............................................................................................ 10

3.1.3 Characterization ........................................................................................................... 11

3.1.4 Feasibility.................................................................................................................... 13

3.1.5 Environmental Effects Analysis...................................................................................15

3.2 VESSEL GROUPS SUBJECT TO STREAMLINED ANALYSIS.......................................... 16

3.3 NUCLEAR STEAM PROPULSTION VESSELS (CVN 68) ............................................... 17

3.3.1 CVN 68 Class Characterization ................................................................................... 17

3.3.2 CVN 68 Class Feasibility Impact................................................................................. 18

3.3.3 CVN 68 Class Environmental Effects ......................................................................... 23

3.3.4 CVN 68 Class Cost-Benefit Analysis .......................................................................... 25

3.4 CONVENTIONAL STEAM POWERED VESSELS (LHD 1) ............................................. 25

3.4.1 LHD 1 Class Characterization ..................................................................................... 26

3.4.2 LHD 1 Class Feasibility Impact................................................................................... 26

3.4.3 LHD 1 Class Environmental Effects............................................................................ 31

3.4.4 LHD 1 Class Cost-Benefit Analysis ............................................................................ 34

3.5 VESSELS WITH GAS TURBINES AND DRY BILGE (DDG 51) ...................................... 34

3.5.1 DDG 51 Class Characterization ................................................................................... 34

3.5.2 DDG 51 Class Feasibility Impact ................................................................................ 35

3.5.3 DDG 51 Class Environmental Effects ......................................................................... 39

3.5.4 DDG 51 Class Cost-Benefit Analysis .......................................................................... 42

3.6 VESSELS WITH GAS TURBINES AND WET BILGE (DD 963) ...................................... 43

3.6.1 DD 963 Class Characterization.................................................................................... 43

3.6.2 DD 963 Class Feasibility Impact ................................................................................. 44

3.6.3 DD 963 Class Environmental Effects .......................................................................... 49

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DRAFT - Surface Vessel Bilgewater – DAR 

3.6.4 DD 963 Class Cost-Benefit Analysis........................................................................... 51

3.7 DIESEL SHIPS OWS PROCESS BILGEWATER AND DIRTY BALLAST (WHEC 378)..... 52

3.7.1 WHEC 378 Class Characterization.............................................................................. 52

3.7.2 WHEC 378 Class Feasibility Impact ........................................................................... 52

3.7.3 WHEC 378 Class Environmental Effects .................................................................... 55

3.7.4 WHEC 378 Class Cost-Benefit Analysis..................................................................... 57

3.8 LARGE COMPRESSION IGNITION VESSELS (LSD 41)................................................ 57

3.8.1 LSD 41 Class Characterization .................................................................................... 58

3.8.2 LSD 41 Class Feasibility Impact ................................................................................. 58

3.8.3 LSD 41 Class Environmental Effects .......................................................................... 63

3.8.4 LSD 41 Class Cost-Benefit Analysis ........................................................................... 65

3.9 MEDIUM COMPRESSION IGNITION VESSELS (MCM 1) ............................................ 66

3.9.1 MCM 1 Class Characterization.................................................................................... 66

3.9.2 MCM 1 Class Feasibility Impact ................................................................................. 66

3.9.3 MCM 1 Class Environmental Effects .......................................................................... 69

3.9.4 MCM 1 Class Cost-Benefit Analysis........................................................................... 72

3.10 SMALL COMPRESSION IGNITION VESSELS (WPB 110) ............................................ 73

3.10.1 WPB 110 Class Characterization ................................................................................. 73

3.10.2 WPB 110 Class Feasibility Impact .............................................................................. 73

3.10.3 WPB 110 Class Environmental Effects ....................................................................... 77

3.10.4 WPB 110 Class Cost-Benefit Analysis ........................................................................ 80

4.0 SUMMARY ........................................................................................................................ 81

5.0 REFERENCES .................................................................................................................. 82

L I S T O F T A B L E S 

Table 3-1. Bilgewater MPCD Option Group Screening Summary............................................................. 10

Table 3-2. CVN 68 Summary of Practicability and Operational Impact Analysis ..................................... 19

Table 3-3. CVN 68 MPCD Total Ownership Cost Comparison ($K/vessel) ............................................. 21

Table 3-4. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric Water 

Quality Criteria in the Baseline Discharge and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (CVN 68) ...................................................................................... 23

Table 3-5. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic Pound 

Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (CVN 68) ...................................................................................... 23

Table 3-6. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Vessels with 

Nuclear Steam Propulsion (CVN 68) ...................................................................................... 24

Table 3-7. TPEs Removed for each MCPD option and Associated Costs (CVN 68)................................. 25

Table 3-8. LHD 1 Summary of Practicability and Operational Impact Analysis ....................................... 27

Table 3-9. LHD 1 MPCD Total Ownership Cost Comparison ($K/vessel)................................................ 29

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DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-10. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric Water 

Quality Criteria in the Baseline Discharge and MPCD Discharges from Vessels with 

Conventional Steam Propulsion (LHD 1) ............................................................................... 31

Table 3-11. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels 

with Nuclear Steam Propulsion (LHD 1) ............................................................................... 32

Table 3-12. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Vessels with 

Conventional Steam Propulsion (LHD 1) ............................................................................... 33

Table 3-13. TPEs Removed for each MPCD Option and Associated Costs (LHD 1) ................................ 34

Table 3-14. DDG 51 Summary of Practicability and Operational Impact Analysis................................... 36

Table 3-15. DDG 51 MPCD Total Ownership Cost Comparison ($K/Vessel) .......................................... 38

Table 3-16. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric Water 

Quality Criteria in the Baseline Discharge and MPCD Discharges from Vessels with Gas 

Turbines and Dry Bilge (DDG 51) .......................................................................................... 39

Table 3-17. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels 

with Nuclear Steam Propulsion (DDG 051)........................................................................... 40

Table 3-18. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Vessels with Gas 

Turbines and Dry Bilge (DDG 51) .......................................................................................... 42

Table 3-19. TPEs Removed for each MCPD Option and Associated Costs (DDG 51) ............................. 43

Table 3-20. DD 963 Summary of Practicability and Operational Impact Analysis.................................... 45

Table 3-21. DD 963 MPCD Total Ownership Cost Comparison ($K/Vessel) ........................................... 47

Table 3-22. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric Water 

Quality Criteria in the Baseline Discharge and MPCD Discharges from Vessels with Gas 

Turbines and Wet Bilge (DD 963) ......................................................................................... 49

Table 3-23. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels 

with Nuclear Steam Propulsion (DD 963).............................................................................. 49

Table 3-24. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Vessels with Gas 

Turbines and Wet Bilge (DD 963) .......................................................................................... 51

Table 3-25. TPEs Removed for each MCPD Option and Associated Costs (DD 963) .............................. 52

Table 3-26. WHEC 378 Summary of Practicability and Operational Impact Analysis.............................. 53

Table 3-27. WHEC 378 MPCD Total Ownership Cost Comparison ($K/Vessel) ..................................... 54

Table 3-28. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric Water 

Quality Criteria in the Baseline and MPCD Discharges from Compression Ignition Ships 

that OWS Process Bilgewater and Dirty Ballast (WHEC 378)............................................... 55

Table 3-29. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels 

with Nuclear Steam Propulsion (WHEC 378)........................................................................ 55

Table 3-30. Summary of EEA for Baseline and MPCD Discharges from Compression Ignition Ships 

that OWS Process Bilgewater and Dirty Ballast (WHEC 378)............................................... 57

Table 3-31. TPEs Removed for each MCPD Option and Associated Costs (WHEC 378) ........................ 57

Table 3-32. LSD 41 Summary of Practicability and Operational Impact Analysis .................................... 59

Table 3-33. LSD 41 MPCD Total Ownership Cost Comparison ($K/Vessel) ........................................... 61

iii 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-34. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric Water 

Quality Criteria in the Baseline and MPCD Discharges from Large Compression Ignition 

Ships (6000 tons of displacement or more) (LSD 41)............................................................. 63

Table 3-35. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels 

with Nuclear Steam Propulsion (LSD 41)............................................................................... 63

Table 3-36. Summary of EEA for Baseline and MPCD Discharges from Large Compression Ignition 

Ships (6000 tons of displacement or more) (LSD 41)............................................................. 65

Table 3-37. TPEs Removed for each MCPD Option and Associated Costs (LSD 41)............................... 66

Table 3-38. MCM 1 Summary of Practicability and Operational Impact Analysis.................................... 67

Table 3-39. MCM 1 MPCD Total Ownership Cost Comparison ($K/Vessel) ........................................... 68

Table 3-40. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric Water 

Quality Criteria in the Baseline Discharge and MPCD Discharges from Medium CI Ships 

(at or above 400 tons and under 6000 tons) (MCM 1 Based on LSD 41 Surrogate Data) ..... 69

Table 3-41. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels 

with Nuclear Steam Propulsion (MCM 1).............................................................................. 70

Table 3-42. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Medium CI Ships 

(at or above 400 tons and under 6000 tons) (MCM 1 Based on LSD 41 Surrogate Data) ...... 72

Table 3-43. TPEs Removed for each MCPD Option and Associated Costs (MCM 1) .............................. 73

Table 3-44. WPB 110 Summary of Practicability and Operational Impact Analysis................................. 74

Table 3-45. WPB 110 MPCD Total Ownership Cost Comparison ($K/Vessel) ........................................ 75

Table 3-46. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric Water 

Quality Criteria in the Baseline Discharge and MPCD Discharges from Small 

Compression Ignition Ships (65 feet or more in length and under 400 tons of 

displacement) (WPB 110 Based on LSD 41 Surrogate Data) ................................................. 77

Table 3-47. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels 

with Nuclear Steam Propulsion (WPB 110)........................................................................... 78

Table 3-48. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Small 

Compression Ignition Ships (65 feet or more in length and under 400 tons of 

displacement) (WPB 110 Based on LSD 41 Surrogate Data) ................................................ 80

Table 3-49. TPEs Removed for each MCPD Option and Associated Costs (WPB 110) ........................... 81

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DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0 INTRODUCTION 

Section 312 of the Federal Water Pollution Control Act [also known as the Clean Water Act 

(CWA)] requires that the Secretary of Defense and the Administrator of the Environmental 

Protection Agency (EPA) develop uniform national discharge standards (UNDS) for 

“...discharges, other than sewage, incidental to normal operation of a vessel of the Armed 

Forces...” [Section 312(n)(1)]. UNDS is being developed in three phases. The first phase 

determined which vessel discharges require control by marine pollution control devices 

(MPCDs). MPCDs can be equipment, alternative materials, or management practices. The 

second phase (which this report supports) characterizes each discharge and evaluates the 

environmental effects and feasibility of implementing MPCDs for each discharge that requires 

control. The final phase will determine the design, construction, installation, and use of the 

MPCDs. 

Discharge Assessment Reports (DARs) are prepared for each vessel discharge requiring control, 

as listed in Title 40 Part 1700 of the Code of Federal Regulations (CFR). A DAR is a summary 

of discharge-specific analyses conducted during the second phase of UNDS. The purpose of the 

DAR is to present key features of a discharge to allow the balancing of the seven statutory 

considerations to produce a performance standard. The seven considerations are: 

• The nature of the discharge. 

• The environmental effects of the discharge. 

• The practicability of using the MPCD. 

• The effect that installing or using the MPCD would have on the operation or the 

operational capability of the vessel. 

• Applicable U.S. law. 

• Applicable international standards. 

• The economic costs of installing and using the MPCD. 

Complete technical analyses of the surface vessel bilgewater discharge can be found among 

various documents cited throughout this summary, including: 

• Vessel Grouping and Representative Vessel Selection for Surface Vessel Bilgewater/OilWater Separator Discharge (Navy and EPA, 2001a). 

• Characterization Analysis Report: Surface Vessel Bilgewater/OWS Discharge, hereafter 

referred to as the Bilgewater Characterization Analysis Report (ChAR) (Navy and EPA, 

2003a). 

• Feasibility Impact Analysis Report: Surface Vessel Bilgewater/OWS Discharge, hereafter 

referred to as the Bilgewater Feasibility Impact Analysis Report (FIAR) (Navy and EPA, 

2003b). 

1 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

• Environmental Effects Analysis Report: Surface Vessel Bilgewater/OWS Discharge, 

hereafter referred to as the Bilgewater Environmental Effects Analysis Report (EEAR) 

(Navy and EPA, 2003c). 

• Environmental Effects Analysis Guidance for Phase II of the Uniform National 

Discharge Standards for Vessels of the Armed Forces, hereafter referred to as the EEA 

guidance manual (Navy and EPA, 2000a). 

A review of applicable U.S. laws and international standards (Section 1.2) and cost effectiveness 

information that relates the results of environmental effects to feasibility analyses are also topics 

in this report. 

1.1 SURFACE VESSEL BILGEWATER/OWS EFFLUENT DEFINITION 

The bilge of a surface ship is the lowest inner part of the interior hull where liquid drains from 

the interior spaces and the upper areas of the vessel (EPA and DoD, 1999). All vessels generate 

bilgewater and most commissioned Armed Forces vessels are fitted with oil water separator 

(OWS) systems to reduce the discharge of oil, in accordance with OPNAVINST 5090.1B). 

1.2 APPLICABLE U.S. LAWS AND INTERNATIONAL STANDARDS 

1.2.1 Introduction 

The UNDS regulatory development process was designed to consider the seven rulemaking 

factors discussed in the main introduction. Two of the seven factors relate to applicable or 

relevant U.S. laws and international standards to provide a basis for comparison while 

developing UNDS performance standards. Accordingly, consideration was given to existing 

laws and standards relevant to the development of surface vessel bilgewater performance 

standards. Listed below are short descriptions of those laws and standards. 

0.0.0 Relevant International Standards 

The International Maritime Organization (IMO) held the International Conference on Marine 

Pollution in 1973, which adopted the International Convention for the Prevention of Pollution 

from Ships. This Convention was subsequently modified by the Protocol of 1978, and is known 

in short form as MARPOL 73/78. Standards covering the various sources of ship-generated 

pollution are contained in the five Annexes of the Convention. 

Annex I applies to the prevention of pollution by oil and contains separate regulations for oil 

tankers, non-tankers 400 gross tons1

 and above, and non-tankers below that limit. 

MARPOL 73/78 exempts warships and naval auxiliaries from compliance but does require 

appropriate measures to be adopted (without affecting operational capability) to comply with the 

1

 Vessel size is often expressed in terms of gross tonnage and net tonnage. Counter to the way it sounds, this term is 

an expression of the volume within the vessel – not the mass of water the vessel displaces. In this case, 1 ton = 

100 ft3

. Gross tonnage is essentially the volume within the hull and superstructure. 

2 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Convention in so far as reasonable and practicable. The international standard, following the 

1992 amendments, is summarized below. (IMO, 1978 and 1992) 

• For non-tanker vessels ≥400 gross tons: Regulation 9 (I)(b) allows for the discharge of 

oil if the following conditions are met: the effluent without dilution does not exceed 15 

ppm, the ship has a discharge monitoring and control system, the ship is underway, and 

the ship is not in a special area (as defined in Regulation 10). 

• For non-tanker vessels <400 gross tons: Regulation 9(II) allows for the discharge of oil 

if all the conditions listed for non-tanker vessels > 400 tons are met, otherwise the vessel 

must be equipped (as far as practicable and reasonable) with installations to ensure the 

storage of oil residues on board and their discharge to reception facilities. 

• For an oil tanker: Regulation 9(I)(a) allows for the discharge of oil if all the conditions 

listed for non-tanker vessels ≥ 400 tons are met except for oil from cargo pump rooms or 

oil from machinery room bilges that are contaminated with cargo fuel. MARPOL 

provides separate conditions that must be met in the case of these two exceptions. 

0.0.0 Relevant U.S. Laws 

The CWA § 311(b)(3) prohibits discharges of oil or hazardous substances in harmful quantities 

into the navigable waters of the United States and the contiguous zone. The Act to Prevent 

Pollution from Ships (APPS) (Title 33, United States Code, Sections 1901-1911) implements 

MARPOL 73/78, and thus has the same exemption for military vessels (i.e., reasonable and 

practicable compliance). 

In addition to Federal laws, State numeric and narrative water quality standards are set under the 

authority of the CWA § 303(c). These standards normally apply to specific water bodies and 

vary by designated use. States use their standards to regulate both point source and non-point 

source discharges. 

Under 33 U.S.C. 1322(n)(6), States and their political subdivisions are prohibited from adopting 

or enforcing any State or local statute or regulation with respect to the discharges identified in 

Phase I as not requiring control. In addition, once performance standards are promulgated 

(Phase II) and requirements for designing, constructing, installing, and using the MPCDs are 

established (Phase III), the UNDS statute expressly preempts States and political subdivisions of 

States from adopting or enforcing any State or local statutes or regulations regarding discharges 

identified as requiring control. The State’s only recourse is to apply to EPA to establish nodischarge zones for specific discharges of concern in their waters. 

0.0 VESSELS GENERATING SURFACE VESSEL BILGEWATER/OWS 

EFFLUENT 

0.0 INTRODUCTION 

To facilitate the feasibility and environmental effects analyses (EEA), and due to the large 

number of vessel classes and designs, Armed Forces vessels were sorted into vessel groups 

3 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

according to similarities in engineering and discharge characteristics. Vessels that produce 

bilgewater/OWS discharge were sorted into vessel groups using a tiered process. The 

discriminating factors in this tiered process included the following: surface vessels that produce 

bilgewater/OWS discharge, vessel operational status, type of propulsion system, bilgewater and 

dirty ballast processing, vessel size, type of bilge, engine placement, and new designs. A 

representative vessel class was selected for each vessel group based on how accurately it depicts 

the group’s characteristics. 

0.0 BILGEWATER VESSEL GROUPING DOCUMENT SUMMARY 

Figure 1 shows how the tiered process described above resulted in the 13 vessel groups and 

representative vessel groups chosen for this discharge. 

4 
Non Operational

LKA 113

Nuclear steam propulsion

CVN 68

Steam Ships

LHD 1

Dry Bilge

DDG 51 

W et Bilge

DD 963 

OW S Processes Bilgewater

and Dirty Ballast

WHEC 378

Large CI Ship

Displacement > 6000 Tons

LSD 41

Medium CI Ships

> 400 ft and < 6000 Tons

MCM 1

Small CI Ships

> 65 ft and < 400 Tons

WPB 110

CI Boats

L < 65 ft

UTB 41

SI Inboard Boats

QST- 35

SI Outboard Boats

CB-M

Lighter

YC 1607

New Design

Nuclear Steam

Propulsion

New Design

Steam Ships

New Design

Large CI Ship

New Design

Medium CI Ship

New Design

Small CI Ship

OWS Process

Dirty Ballast

Process only

Bilgewater

Nuclear

Powered

Conventional

Steam

Gas Turbine

Compression

Ignition

Spark Ignition

Non-Powered

Non

Operational

Operational

and New

Vessels

Surface 

Vessels with

Bilgewater/ 

OWS

DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Figure 1. Bilgewater Vessel Groupings 

i l 

l i

i

il

il

il

i ll

Di l

i i

ll i

i

l

i

i

i

i

ip 

i

i ip 

i

ll ip 

ll

ly 

Bil

l

i

Igni

i

i l 

i l 

ls 

ls wi

Bil / 

Non Operat ona

LKA 113 

Nuc ear steam propuls on 

CVN 68 

Steam Sh ps 

LHD 1 

Dry B ge 

DDG 51 

Wet B ge 

DD 963 

OW S Processes B gewater 

and D rty Ba ast 

WHEC 378 

Large CI Ship 

sp acement > 6000 Tons 

LSD 41 

Med um CI Sh ps 

> 400 ft and < 6000 Tons 

MCM 1 

Sma CI Sh ps 

> 65 ft and < 400 Tons 

W PB 110 

CI Boats 

L < 65 ft 

UTB 41 

SI Inboard Boats 

QST- 35 

SI Outboard Boats 

CB-M 

Lighter 

YC 1607 

New Des gn 

Nuc ear Steam 

Propuls on 

New Des gn 

Steam Sh ps 

New Des gn 

Large CI Sh

New Des gn 

Med um CI Sh

New Des gn 

Sma CI Sh

OW S Process 

Dirty Ba ast 

Process on

gewater 

Nuc ear 

Powered 

Conventional 

Steam 

Gas Turb ne 

Compression 

tion 

Spark Ign tion 

Non-Powered 

Non 

Operat ona

Operat ona

and New 

Vesse

Surface 

Vesse th 

gewater

OW S 

For complete details of bilgewater vessel grouping and representative vessel group selection, see 

the Vessel Grouping and Representative Vessel Selection for Surface Vessel Bilgewater/OilWater Separator Discharge (Navy and EPA, 2001a). 

5 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0 OVERVIEW OF DISCHARGE ANALYSES 

0.0 INTRODUCTION 

Technical analyses developed for the UNDS program are divided into three general areas: 

characterization, environmental effects, and feasibility. The discharge analyses began after 

potential MPCDs were identified and the vessels that produce the discharge were grouped. 

Characterization of the discharge was performed to support the subsequent environmental effects 

and feasibility analyses. The discharge characterization for each vessel group for each MPCD 

option and the baseline discharge is referred to as the “discharge profile.” 

The three primary treatment MPCD options (gravity coalescence, hydrocyclone, and centrifuge) 

that were subject to full analysis for this discharge can each be combined with one of the two 

secondary treatments that passed MPCD screening (filter media and membrane filtration). As 

noted in the Bilgewater ChAR (Navy and EPA, 2003a), the gravity coalescence, hydrocyclone, 

and centrifuge options are assumed to have sufficiently similar oil-water and particulate 

separating performance potential to allow all three OWS options to be represented by gravity 

coalescence (Navy and EPA, 2003c). Therefore, the characterization and environmental effects 

analyses address only: 

• Primary treatment (as represented by existing gravity coalescence equipment). 

• Primary treatment plus filter media. 

• Primary treatment plus membrane filtration. 

• Collection, holding, and transfer (CHT). 

It is important to note that the baseline discharge profile for each vessel group (i.e., untreated 

bilgewater) was intended for comparison purposes only. Armed Forces vessels do not discharge 

untreated bilgewater directly overboard. 

0.0.0 Potential Marine Pollution Control Device Options 

The process to determine the achievable performance levels of discharge treatment for each 

vessel group (which later would be used to drive performance standards) resulted in the 

identification of 15 candidate technologies, referred to as MPCD option groups. Summary 

information is provided below for each of these options. This section also provides a table 

summarizing the screening results and pass/fail determination rationale. MPCD options that 

passed screening, as described in the MPCD Screening Guidance Document (Navy and EPA, 

2000b), were subject to subsequent environmental and feasibility analyses. 

The MPCDs listed below include primary (e.g., gravity coalescence) and secondary treatment 

options. Secondary MPCDs are treatment options that are used in addition to primary MPCDs to 

further enhance discharge water quality. These options (e.g., filter media and membrane 

filtration) are installed in series with primary options to form a treatment train configuration. 

6 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0.0 Centrifuge 

A centrifuge is a mechanical separating device that consists of a bowl or cylinder rotating at high 

speeds, generating a centrifugal force. In a disk-type separator, centrifugal force is exerted on 

the waste stream to be processed (process fluid). The force imposed on the process fluid by the 

centrifuge causes the immiscible liquids (and/or solids) to separate. Typically, disk-type 

centrifuges are used in the marine environment. In a disk-type centrifuge, a stack of disks is 

encased in a bowl-like rotating container. The process fluid enters the top of the rotating bowl 

through a regulating tube. The waste stream then passes down the inside of the regulating tube 

shaft and out the bottom of the stack of disks. As the process fluid fills the bowl containing the 

disk stack, the fluid is pushed up through the distribution holes in the disks. As the process fluid 

flows up through the distribution holes in the disks, the revolving bowl creates a high centrifugal 

force that is imparted upon the process fluid. The centrifugal force causes the dirt, sludge, and 

heavier immiscible fluids (generally water) to move outward to the periphery of the bowl where 

it can be drained to a sludge tank. The lighter fluid (e.g., oil) flows from the top of the disk stack 

to a holding tank. 

0.0.0.0 Dissolved Air Flotation 

Dissolved air flotation (DAF) is a physical/chemical clarification process used for the removal of 

suspended solids and/or insoluble liquids from wastewaters. In a DAF clarifier, the wastewater 

influent stream is saturated with air under pressure. Just before entering the clarifier tank, the 

influent is released to atmospheric pressure, and the dissolved air in the influent comes out as 

extremely fine bubbles. The bubbles attach themselves to the suspended solids/insoluble liquid 

droplets in the water and rise to the top of the clarifier, carrying with them the solids and other 

contaminants in the these droplets. Precipitating and coagulating chemicals are added to the 

waste stream in the DAF clarifier tanks to enhance system effectiveness. When the 

bubbles/solids/droplets aggregate reaches the surface, a floating blanket of sludge develops. The 

floating sludge is removed from the surface by mechanical skimming. Sludge is also formed at 

the bottom of the tank as heavier solids settle to the bottom. A sediment sump, a lower rake arm, 

or some similar device collects and transfers this sludge. Clarified effluent can be recycled, sent 

for further treatment, or directly discharged overboard. 

0.0.0.0 Evaporation 

Evaporation is the process of changing a solid or liquid into a vapor. In the context of processing 

bilgewater/OWS effluent, evaporation requires heating the bilgewater until the water, and 

various other volatiles it contains, undergo a phase change from liquid phase to vapor phase. 

The primary components of the only known commercial bilgewater evaporation system include 

an insulated steel tank of approximately 50-gallon capacity with a lid, a thermostat, a flat floor 

with a drain, an under-floor or immersed heater, an exhaust fan, and vent stack. 

0.0.0.0 Ex Situ Biological Treatment 

An ex situ biological treatment system uses a process in which the waste stream is pumped into a 

reaction vessel containing microorganisms which provide waste treatment. These 

microorganisms digest the organic content of the waste stream. The digestion process converts 

7 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

the organic material into new cell mass, cell by-products, gas, and water. The cell mass forms 

aggregates, or floc, the density of which is sufficient to separate the flocs from the treated 

effluent leaving the reaction vessel. Operational parameters such as waste flow rate, air/nutrient 

additions, and contact time of the biomass are controlled to create the optimum environment for 

treating a specific waste stream. 

0.0.0.0 Flocculation through Electrocoagulation 

Electrocoagulation is a physiochemical operation commonly used for wastewater treatment. 

This process results in the destabilization and aggregation of smaller particles into larger 

particles. The resulting larger particles precipitate from solution or become large enough to be 

filtered out of solution. Electrocoagulation is based on the principle of passing an electrical 

current through water to induce a chemical reaction, creating dense flocculation precipitates that 

can be settled or floated. Because the floc (which forms a sludge) is physically and chemically 

stable, it can be easily separated from the water by a number of secondary separation techniques, 

including skimming or accumulation in a sludge buffer tank (55-gallon drum). This option 

group typically requires the addition of iron or aluminum pellets, or the use of sacrificial anodes 

to facilitate the separation/flocculation process. 

0.0.0.0 Flocculation by Separating Agents 

Separating agents are added to a waste stream to facilitate the coagulation/ flocculation process. 

Coagulation is achieved by a reduction of electrostatic surface forces, and flocculation is 

achieved by the use of bridging materials to combine smaller particles into larger agglomerates. 

Although achieved through different means, both coagulation and flocculation are processes 

where suspended material present in water in a colloidal form are brought together into larger 

agglomerates. These agglomerates are then removed during wastewater processing by skimming 

and filtration. This technology can remove metals, phosphates, suspended solids, oil and grease 

from wastewater. 

0.0.0.0 Gravity Coalescence 

Gravity coalescing type OWSs operate on the principle that due to the different specific gravities 

of oil and water and their immiscibility with each other, the oil will separate from the water and 

coalesce into a separate fluid layer. Oily wastewater is pumped from the oily waste holding tank 

through the OWS, which contains coalescing material. Coalescing material is typically 

polypropylene, an oleophilic polymer that may be in the form of parallel plates or loose packed 

media. As the oil droplets, entrained in the influent, flow through the OWS, they will come into 

contact with the coalescing material and adhere to it. As more droplets attach to the polymer, 

they will come in contact with each other and form larger droplets (coalesce). These droplets 

will break free from the plates or media and rise to the surface of the OWS tank where they 

typically collect in an oil tower. The OWS contains sensors that detect the presence of oil in the 

oil tower and trigger the OWS to automatically pump the collected oil to a waste oil tank. The 

treated effluent is scanned for oil content by an oil content monitor. If the effluent appears to 

contain higher than desired oil content, it is returned to the oily waste holding tank for further 

processing. If the effluent concentration is acceptable, the effluent is discharged overboard. 

8 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0.0 Hydrocyclone 

A hydrocyclone (or cyclone separator) is a simple device, consisting of a cylindrical upper 

section and a conical lower section that utilizes centrifugal forces to separate fluids of differing 

density. The fluid and the contaminants, coupled with an applied force to pressurize the fluid, 

drive the entire process. Oily water is pumped under pressure into the top of the hydrocyclone, 

where it enters the cylinder tangentially, causing a vortex to form. This vortex creates 

centrifugal force that pushes denser liquids, such as water, outward toward the walls of the 

conical section. At the same time, a pressure drop occurs in the center of the vortex where the 

lower density fluid (oil) is drawn. As the vortex moves down the tapered portion of the 

hydrocyclone, it accelerates, generating very large centrifugal forces (on the order of 1,000 times 

the force of gravity). The centrifugal force further separates the two phases: forcing the water to 

the outside walls while the oil flows toward the center of the vortex. The separated oil flows 

back up through the center of the vortex and out the center of the cylindrical inlet head section, 

while the water continues to flow down and out the open end of the conical tail section. The oil 

stream is directed to a waste oil collection tank. The processed water may be discharged 

overboard if below regulatory standards or directed to a secondary treatment device for 

additional processing. 

0.0.0.0 In Situ Biological Treatment 

Biological treatment works by bringing bacteria into contact with organic compounds, an 

electron acceptor, and other necessary nutrients for microbial growth. Once in contact, the 

microbes break down and consume the organic waste, converting it into either gas, water, cell 

by-products, or microbial cell mass. In situ biological treatments are systems in which microbes 

are introduced directly into a waste stream, such as bilgewater, and allowed to react with its 

constituents. In situ biological treatment is a relatively uncontrolled process since the only 

controllable parameter is the amount of microbes added to the contaminated area. 

0.0.0.0 Oil Absorbing Socks 

Oil-absorbing socks (OAS) utilize both oil absorbent and water repellent properties of meltblown 

(not woven) polypropylene fibers to absorb liquid hydrocarbons from oily wastewater. 

Meltblown polypropylene fibers have inherent hydrophobic properties and are designed to 

absorb oil and repel water when placed on (or in) oil water mixtures (i.e., vessel or small boat 

bilges) (Oil Dri Corp, 2000). 

0.0.0.0 Supercritical Water Oxidation 

This potential MPCD option involves using a supercritical water oxidation (SCWO) unit to 

control aqueous organic materials by converting them to carbon dioxide and water. The SCWO 

unit destroys the aqueous organic matter using the properties of water at supercritical conditions. 

0.0.0.0 Collection Holding and Transfer (CHT) 

CHT involves the on-board collection, containment, and subsequent transfer of bilgewater to 

shore facilities or ship waste offload barges (SWOBs). CHT does not involve any treatment of 

9 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

raw bilgewater on-board the generating vessel. CHT may require the installation of some 

shipboard equipment, such as piping or tanks, to provide additional holding capacity. 

0.0.0.0 Filter Media 

Filter media are substances that selectively remove constituents (e.g., organics and metals) from 

a wastewater. The media have an affinity for a particular suite of constituents. When allowed to 

come into contact, the constituent is bound to the filter media, typically through adsorption 

and/or absorption. The types of media studied for this MPCD option group include activated 

carbon, polypropylene, resin bonded glass fiber, cellulose, humic acid, and synthetic polymers. 

0.0.0.0 Membrane Filtration 

Semi-permeable membranes are filtration systems that allow the passage of water, ions, or small 

molecules, but prohibit the passage of larger molecules (e.g., oil). Membrane filtration devices 

separate high molecular weight constituents from fluids by forcing the fluid through very small 

pores of a polymeric or inorganic membrane. The membrane filtration MPCD option group 

consists of various types of membranes including reverse osmosis (RO), nanofiltration (NF), 

ultrafiltration (UF), and microfiltration (MF). Membrane filtration systems in use by Armed 

Forces vessels use UF units designed to remove oil to meet performance levels. 

0.0.0 MPCD Screening Results 

The following table summarizes the screen conclusions and associated rationale for each MPCD 

option group. 

Table 0-1. Bilgewater MPCD Option Group Screening Summary 

Option Group Pass/Fail Rationale 

Centrifuge PASS: Centrifuges have been successfully used aboard Armed Forces surface 

vessels and commercial vessels for treating surface vessel bilgewater. 

Dissolved Air Filtration FAIL: DAF technology has been used successfully for land-based wastewater 

treatment applications. However, there are no DAF clarifiers in use on-board 

waterborne vessels, nor is DAF available commercially for application in the marine 

environment. 

Evaporation PASS: Although not widely used, this MPCD has been used to treat bilgewater on 

some commercial inland watercraft. These craft range in size from 100 to 250 feet 

and generate bilgewater at a rate of less than 50 gallons per day. 

Ex Situ Biological 

Treatment 

FAIL: Ex situ biological treatment devices are currently the subjects of private and 

public sector research. At this time, there are no existing data to demonstrate that 

this MPCD is sufficiently proven to treat surface vessel bilgewater on waterborne 

vessels. 

Filter Media PASS: Filter media has been successfully used aboard Armed Forces surface 

vessels to treat surface vessel bilgewater. 

Flocculation through 

Electrocoagulation 

FAIL: Flocculation through electrocoagulation has been used for many shoreside 

wastewater treatment applications and is reportedly capable of treating complex 

waste streams, including bilgewater. However, to date, this technology has not been 

used to treat surface vessel bilgewater on waterborne vessels. 

10 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Option Group Pass/Fail Rationale 

Flocculation by 

Separating Agents 

FAIL: Flocculation by separating agents has been used for many shoreside 

wastewater treatment applications. However, to date, this technology has not been 

used to treat surface vessel bilgewater on waterborne vessels. 

Gravity Coalescence PASS: Gravity coalescers have been used successfully aboard Armed Forces 

surface vessels to treat surface vessel bilgewater. 

Hydrocyclone PASS: Hydrocyclones have been successfully used aboard Canadian Navy surface 

vessels to treat surface vessel bilgewater. 

In Situ Biological 

Treatment 

PASS: In situ devices have demonstrated the ability to degrade oil in the bilgewater 

of recreational boats and USCG cutters. However, the rate at which the degradation 

occurs and the relative effectiveness has not been quantified fully. In situ biological 

treatment is a process that has not been proven to consistently produce an effluent 

with oil content suitable for overboard discharge. 

Membrane Filtration PASS: Membrane filtration is successfully used on-board Armed Forces surface 

vessels to treat surface vessel bilgewater. 

Oil Absorbing Socks PASS: OASs are successfully used in bilge areas on small recreational boats to 

prevent oil from being released during unintentional bilgewater discharges. 

Supercritical Water 

Oxidation 

FAIL: SCWO technology is available for commercial use (Freeman, 1989), but has 

not been used on a waterborne vessel or in the marine environment to treat surface 

vessel bilgewater. 

CHT PASS: Armed Forces vessels successfully practice CHT. 

0.0.0 Characterization 

Characterization information collected on surface vessel bilgewater is organized among the 

following topics: physical parameters, chemical data, field testing, descriptive information, and 

discharge generation rates. 

0.0.0.0 Physical Parameters 

Characterization of the physical parameters of the discharge refers to the information gathered on 

how the discharge is released to the environment. This information is needed to support dilution 

modeling as part of the EEA (described in Section 3.1.5). This information includes vessel 

dimensions, discharge port measurements, flow rate and duration, and discharge density 

(determined by salinity values). The primary sources of these data are technical literature 

reviews and the engineering information gathered on the representative vessel, particularly ship 

drawings and equipment specifications. 

0.0.0.0 Chemical Data 

To support the requirements of the EEA, potentially toxic constituents of the discharge were 

identified and quantified (by concentration). The primary source of this information was sample 

analysis. In Phase I, sampling was performed on USS JOHN C. STENNIS (CVN 74). 

Additional sampling was performed for Phase II on USS MAHAN (DDG 72), USS OAK HILL 

(LSD 51), USCGC MORGENTHAU (WHEC 722), USS DAVID R. RAY (DD 971), USS 

BONHOMME RICHARD (LHD 6), USS CARNEY (DDG 64), and USS RUSHMORE 

(LSD 47). The selection of analytes and analysis methods are detailed in the Specified Sampling 

and Analysis Plans (SSAPs), which are listed in the Reference section. 

11 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Process knowledge was used to develop discharge profiles for instances where sampling was not 

practical (e.g., the evaluation of MPCD options on vessels which do not have the option 

installed). In these cases, constituent concentrations were estimated using empirical formulas 

developed by Putnam and Singerman (2001). Specifically, secondary treatment profiles (i.e., 

those used as part of a treatment train) were developed by applying these formulas to primary 

treatment results. In other cases, baseline and primary treatment results were derived from 

surrogate data and supplemented by process knowledge from equipment experts and vessel 

drawings. In particular, due to similarities in machinery, propulsion systems, and ancillary 

equipment, the LSD 41 vessel group discharge information is used to represent the MCM and 

WPB vessel groups. 

0.0.0.0 Field Testing 

Field testing was performed to obtain values for parameters that can not be measured in 

preserved samples. Parameters measured in the field included pH, temperature, salinity, specific 

conductance, and total- and free-chlorine. Additional characterization information on colloidal 

matter, color, floating materials, nuisance species, odor, settleable materials, total dissolved 

gases, transparency, and turbidity were collected for narrative water quality criteria (WQC) 

evaluations as part of the EEA. 

0.0.0.0 Descriptive Information 

Descriptive information on the discharge was also required to compare discharge characteristics 

to narrative criteria endpoints. This information was generally collected through observation of 

discharge samples. Categories of narrative criteria directly related to descriptive information 

include color, floating materials, odor, settleable materials, and turbidity/colloidal matter. 

0.0.0.0 Discharge Generation Rates 

A determination of annual discharge generation rates was necessary to support feasibility and 

environmental effects analyses. The determination of discharge generation volume was not 

made by using a selected vessel class to represent each vessel group. Instead, generation rates 

were determined for each vessel class that produces the discharge. Information on the dischargeprocessing rate (i.e., the rate that bilgewater is pumped out when sent through the OWS) was 

assembled, along with the number of hulls within a class and vessel movement data, to calculate 

the annual discharge volumes. Vessel movement data include details regarding the time each 

representative vessel spends in fresh and saltwater and the number of days spent in port vice 

operating within and outside of 12 nm. 

Data quality was considered for all analyses conducted. To ensure adequate data quality, after 

reviewing documented matrix spike failures and process information discrepancies, a 

confirmation analysis was conducted for pesticides. This confirmation analysis revealed that 

there were no pesticides present in the reanalyzed samples. As a result, pesticides are not 

included in bilgewater discharge profiles (Navy and EPA, 2003d). 

12 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Constituent concentrations and other characterization data for each discharge profile are located 

in the Bilgewater ChAR appendices (Navy and EPA, 2003a). 

0.0.0 Feasibility 

The feasibility analysis is organized by vessel group and analyzes criteria for each MPCD option 

group relative to each representative vessel. Feasibility criteria were considered for both existing 

vessels and new design vessels, and for each MPCD option group that passed the MPCD 

screening process. MPCD option groups can be management plans, practices, alternative 

materials, or control devices. The specific criteria considered in the feasibility analyses are 

detailed in the Feasibility Impact Analysis Guidance Document (Navy and EPA, 2000c). 

Feasibility information used in this report belongs to either of two general categories: 1) general 

data developed for the UNDS program that are subject to uncertainty analysis and the rules of 

significant figures, and 2) information collected from other sources (e.g., vendor claims) that are 

treated as constants for calculation purposes. The Navy’s Alteration and Installation Team (AIT) 

and Total Ship System Directorate of the Naval Surface Warfare Center, Carderock Division, 

(NSWCCD Code 20) supported the development of these analyses. Their estimates and 

conclusions are referenced throughout this report. 

Within each personnel impact section, the maintenance activities for each MPCD are presented 

as either time-based or condition-based. Time-based maintenance includes those activities 

performed according to a preset calendar schedule (e.g., annual, semi-annual, quarterly) and is 

independent of the number of hours the MPCD is operated. Condition-based maintenance 

includes all maintenance activities that are dependent upon the number of hours the MPCD is 

operated (e.g., every 500 hours). Hours of MPCD operation were estimated based on the amount 

of time it takes to process the volume of bilgewater generated annually. 

0.0.0.0 Economic Cost Analysis 

Cost analyses developed herein are for purposes of MPCD comparison as part of performance 

standard development in Phase II of UNDS. The following cost analyses are not intended for 

preparation of actual implementation costs. To the extent possible, the analyses divide cost 

estimates between vessel operations within 12 nm of shore and vessel operations beyond 12 nm. 

Economic costs were estimated using Automated Cost Estimating Integrated Tool (ACEIT) 

software. ACEIT software is widely used within the DoD cost analysis community (ACEIT, 

1999). All costs are presented in 1999 dollars. Summary tables that present how costs were 

converted to 1999 dollars are shown in the Bilgewater FIAR Appendix A. Cost data for 

individual initial and recurring cost items that were obtained subsequent to fiscal year 1999 were 

converted to 1999 dollars using the Consumer Price Index (CPI). The CPI is a general inflation 

rate published by the Bureau of Labor Statistics. More specialized inflation rates exist for 

specific costs (e.g., labor rates, machinery procurement cost, oily wastewater disposal cost); 

however, because costs were adjusted over a very short time period, using specialized inflation 

rates would not significantly affect the outcome of the calculations. 

13 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Initial Cost 

The initial cost estimates developed for each MPCD option group include acquisition, 

installation, and technical data (e.g., manuals, drawings, training guides) development costs. The 

estimated initial costs are the incremental costs, or additional costs, to install the MPCD. If the 

MPCD is already installed, there are no incremental costs. Acquisition costs indicate the total 

cost to purchase the number of MPCDs required to achieve the designated processing rate per 

representative vessel. Acquisition costs were provided by vendors or equipment experts with 

acquisition cost knowledge. These costs may vary between manufacturers; however, that 

difference is not expected to be significant. The development of acquisition, installation, and 

technical data development cost estimates required the use of assumptions based upon Navy 

experience. 

Recurring Cost 

The recurring costs considered in the feasibility analyses include labor costs for operating and 

maintenance, consumable costs, and waste material disposal costs. These individual costs, 

associated assumptions, and calculations are reported in the respective Personnel Impact 

sections. The recurring costs are incurred on an annual basis. The individual recurring cost 

items are described under the recurring cost sections and totaled under the Total Ownership 

Costs (TOC) sections. The annual labor cost was estimated by adding the personnel labor 

requirement for operating equipment and transferring waste oil to shore to the routine 

maintenance labor requirement. 

Total Ownership Costs 

The TOC is a sum of the total initial and the total recurring costs. The ACEIT model estimated 

the TOC of each MPCD option group over a 15-year lifecycle. This model assumes that 

acquisition and installation occur during year one of the 15-year lifecycle, and MPCD operation 

begins the following year. Therefore, the first year reflects initial costs only, and years two 

through 15 reflect recurring costs only. The ACEIT model presents the cost-estimate results as 

total initial, total recurring, and overall total cost expressed in 1999 dollars. ACEIT discounted 

future costs (i.e., recurring cost) using a discounted cash flow methodology to account for the 

time value of money. The cost analysis used a discount rate of 3.2% that was based on the real 

interest rates on 15-year Treasury Notes and Bonds (OMB, 1992). 

Annualized Cost 

Annualized costs were calculated using standard annualization methods. This process facilitated 

the cost analysis by representing each year in the 15-year life cycle by a single value. 

Annualized costs are presented for comparing costs of MPCD option groups. 

0.0.0.0 New Design Vessels 

Vessels in the design stage (“new design vessels”) are vessels authorized by Congress and for 

which the Department of Defense or the Coast Guard has established a program office to oversee 

their design. Assessments reported in the FIAR were developed using the assumption that new 

14 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

design vessels will have similar discharge characteristics (e.g., bilgewater constituent 

composition) as a representative existing vessel and will have additional flexibility as compared 

to existing vessels. 

New design analyses parallel existing representative vessel classes and follow new design 

analysis guidelines (Navy and EPA, 2002a). A new design vessel's ability to collect bilgewater 

may also be improved by designing systems that reduce the amount of bilgewater generated. As 

discussed in Shipboard Compliance and Pollution Prevention Program (Navy and EPA, 2002b), 

the Navy is implementing several pollution prevention initiatives to reduce bilgewater generation 

volumes. These include incorporating non-oily machinery wastewater collection systems, or "dry 

bilge", into the ship design, installing mechanical seals on pumps, and developing improved 

shaft seals. 

MPCD feasibility for new design vessels was analyzed using existing vessels as a baseline, as 

described below: 

• At a minimum, new design vessels were assumed to be able to accommodate MPCDs 

that are in-place or were determined to be viable for installation on corresponding 

existing vessels. Therefore, these “in-place” MPCDs were not analyzed for new design 

vessels because the discharges were expected to have similar characteristics as those on 

existing vessels. 

• Only MPCDs that could provide an additional environmental benefit over the in-place 

MPCDs were analyzed. 

• Professional judgment was used to compare the feasibility (i.e., practicability, economic 

costs, and operational impacts) of installing and using an MPCD on a new design vessel 

to that of an in-place MPCD. Installation cost for an MPCD aboard a new design vessel 

was assumed to be 67% of the cost for retrofitting the device aboard an existing vessel 

(Navy and EPA, 2002a). 

0.0.0 Environmental Effects Analysis 

UNDS program managers designed the environmental effects analysis of discharges to have two 

components. The first component is the analysis of immediate impacts from vessel discharges. 

That analysis included an evaluation of the acute toxicity to aquatic life, an identification of 

bioaccumulators, and an evaluation of other environmental impacts (e.g., nutrient loading, 

pathogen inputs, and thermal effects). The second component of the environmental effects 

analysis, the cumulative impact analysis (CIA), is intended to consider environmental impacts 

that arise due to multiple discharges from multiple vessels and to evaluate certain environmental 

impacts not addressed in the EEA, which are more complex than simple toxicological effects. 

The EEA of bilgewater impacts presented in this report are in accordance with the methodology 

contained in the EEA guidance manual (Navy and EPA, 2000a), with a few exceptions wherein a 

streamlined analysis was determined to be suitable (presented in Section 3.2). In these cases, 

collection of the entire discharge within 12 nm of shore was determined to be a feasible option. 

15 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

As a result, there is no discharge to the receiving waters inside 12 nm and the need for further 

characterization or environmental effects analysis was considered to be superfluous. 

In short, the analysis has several steps. After the discharge has been characterized (as described 

in the previous section), constituent concentrations are compared to a collection of State water 

quality standards and Federal guidance values. Bioaccumulative contaminants of concern 

(BCCs) are identified in the discharge based on lists of elimination and reduction BCCs provided 

by EPA and other sources. Mass loading calculations, along with toxic weighting factors 

(TWFs) provided by EPA, are used to derive toxic pounds equivalents (TPEs) that allow for 

cumulative toxic loading to be estimated. 

Net acute aquatic-life toxicity is estimated using a hazard index (HI) approach. End-of-pipe 

(EOP) and edge of a mixing zone (EOMZ) constituent concentration values are divided by 

toxicological endpoint concentrations (TECs). The constituent-specific result of these 

calculations is the hazard quotient (HQ); the summation is the HI. An HI of 1.0 or less is the 

level considered to be protective of aquatic life from acute toxic effects of the discharge. This 

level is equivalent to the EPA WQC for aquatic life [i.e., Criterion Maximum Concentration 

(CMC)]. The CMC is intended to protect most species most of the time (EPA, 1991). This level 

of protection is set near the concentration resulting in no observable effect on the most sensitive 

aquatic species, which EPA has determined will adequately protect aquatic communities. 

As discussed in the EEA guidance manual (Navy and EPA, 2000a), the mixing zone used by the 

UNDS program is the volume of water within a distance 35m from the discharge point. The 

dilution at EOMZ is an important variable in the determination of the environmental impact a 

discharge has on the receiving waters. The analysis of bilgewater followed the pierside 

modeling approach described in the Technical Approach for Pierside Modeling to Support 

UNDS EEA Phase II (Navy and EPA, 2001b). 

The EEA process also assesses the potential for non-indigenous species (NIS) transport and other 

environmental considerations unique to the discharge (e.g., impacts to air quality). In the case of 

bilgewater, the potential for the baseline discharge to introduce NIS is expected to be low 

because “there is only minor seawater access to bilge compartments, and bilgewater is generally 

processed before it is transported over long distances” (EPA and DoD, 1999). The other 

potential environmental concern identified for this discharge is due to the indirect impacts to the 

environment that could occur as a result of shoreside treatment. Offloaded bilgewater is treated 

at properly-permitted facilities and is subject to applicable Federal, State, and local disposal 

regulations. 

Discharge profiles were not created for every combination of MPCD option and vessel group. In 

some cases, MPCDs were eliminated from evaluation as a result of the feasibility analysis (see 

the Bilgewater FIAR). 

0.0 VESSEL GROUPS SUBJECT TO STREAMLINED ANALYSIS 

For five of the 13 vessel groups, collection of the entire discharge within 12 nm of shore was 

determined to be a feasible option. The use of this option results in no direct discharge to the 

16 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

receiving waters; therefore, the need for formal characterization or environmental effects 

analysis was considered to be superfluous. The five vessel groups include: 

• Non-operational vessels: LKA 113. 

• Compression ignition (CI) boats under 65 ft: UTB 41. 

• Spark ignition (SI) inboard vessels: QST 35. 

• SI outboard vessels: CB-M. 

• Non-powered vessels: YC 1607. 

Further information on the feasibility analysis of these vessel groups can be found in their 

respective chapters in the Bilgewater FIAR (Navy and EPA, 2003b). 

0.0 NUCLEAR STEAM PROPULSTION VESSELS (CVN 68) 

The only nuclear-powered surface vessels in service with the Armed Forces are the Navy aircraft 

carriers ENTERPRISE (CVN 65) and NIMITZ (CVN 68) Classes. The CVN 65 is a class with 

only one vessel, while the CVN 68 Class has 10 vessels. These vessels measure over 1,000 ft in 

length, displace more than 70,000 tons (Polmar, 1997), and operate outside 12 nm from shore 

except when transiting to and from port. These vessels have nuclear reactors that supply heat to 

steam generators. The steam from the generators drives the main propulsion turbines. The 

steam generators require blowdowns, however the resulting wastewater is not directed to the 

bilge. 

0.0.0 CVN 68 Class Characterization 

Characterization information was gathered on surface vessel bilgewater to support subsequent 

environmental effects and feasibility analyses. This information primarily included engineering 

data on ship systems and details regarding discharge composition. 

During UNDS Phase I, sampling was conducted aboard one vessel of the CVN 68 Class, USS 

JOHN C. STENNIS (CVN 74), from 5 March 1997 to 7 March 1997 to supplement process 

knowledge on the composition of the discharge. This sampling episode serves as the primary 

source of chemical data, as well as field and descriptive data, for this vessel group. The samples 

were analyzed by ETS Analytical Services and Pacific Analytical, Inc. The subsequent results 

were reviewed by the EPA and DoD to determine the quality of the analytical data; however, 

some sample data were excluded in the final calculations, as documented in the Sampling 

Episode Report - Volume II -USS JOHN C. STENNIS (Navy, 1998) based upon Sample Control 

Center (SCC) review. As discussed in Section 3.1.3, pesticide results were not included in 

bilgewater discharge profiles (Navy and EPA, 2003d). 

The characterization of the bilgewater discharge after secondary treatment by filter media could 

not be performed based on sample analysis because this operation is not in everyday practice 

aboard this vessel class. Discharge composition properties were estimated using Putnam and 

Singerman (2001) calculations as well as comparisons to the performance achieved by filter 

media on DDG 51 Class vessels. Further information on the characterization of this discharge 

can be found in the respective chapter of the Bilgewater ChAR (Navy and EPA, 2003a). 

17 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 CVN 68 Class Feasibility Impact 

The feasibility impact analysis of surface vessel bilgewater for this vessel group is summarized 

below in Table 3-2. 

18 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-2. CVN 68 Summary of Practicability and Operational Impact Analysis 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

Co

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Current MPCD* (Gravity Coalescer) 

163 ft3 

4,800 lbs. (dry) 9,000 lbs (flooded) No impact – current MPCD 

No impact No impact 245 hrs 386 hrs None Electrical power— 

440VAC, 60Hz Potable water— needed as a primer Sea water—25 

AutopaneleveOCM 

psi Gravity drain 

Centrifuge 766 ft3 

6,300 lbs (dry) 7,000 lbs (flooded) Existing OWS would be removed and 

No impact No impact 113 hrs 386 hrs Minimal 

consumables required. Special tools available from vendor 

Electrical power— 440VAC, 80-130kW  Compressed Air--0.0045-0.022 cfm @ 50 psig Potable water— 

Autopanerecooperdurinintegtherm

replaced with unit 

50 gpd, 45 psi Gravity drain 

heatequi

CHT—operating from port with shoreside facilities 

No impact— within current holding capacity; can 

No impact No impact 750 hrs NA None None Non

support an approximate 6 hours of transit time 

CHT—operating Significant Significant Significant Significant impact NA None None Nonfrom port without impact after impact after impact after after two days shoreside two days two days two days facilities Evaporation NF – excessive 

power requirements 

19 
DRAFT - Surface Vessel Bilgewater – DAR 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

Co

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Hydrocyclone 168 ft3 No impact No impact 79 hrs 386 hrs Consumables and Electrical power— Auto

900 lbs (dry) 1,000 lbs 

repair parts (e.g., “O” rings, gaskets 

460VAC, 60 Hz pane

switc

(flooded) for cyclone equiExisting OWSs would be 

vessel, cyclone liners, and pump 

removed components) 

required 

In Situ Biological Treatment NF – excessive bilgewater volume Oil-Absorbing Socks NF – potential safety (e.g., fire and flooding) hazard; solid waste handling impacts Filter Media 87 ft3 

3,650 lbs (dry) 8,375 lbs (flooded) Existing workbench and storage locker may have to be removed; 

No impact No impact 11 hrs NA Requires 

replacement of filter media canisters 

None Auto

operrespOWS 

deballasting tanks and piping may have to be relocated. 

Membrane Filtration 

440 ft3 

9,200 lbs (dry) 12,000 lbs (flooded) Significant impacts on older vessels; extent of impacts on other vessels 

No impact No impact 42 hrs NA Requires 

replacement of membranes (performed shoreside) 

Electrical power— 440VAC, 60 HZ Compressed Air – 5 scfm at 80 to 100 psi Potable water – 10 gpm at 30 psi Gravity drain 

AutooperrespOWS 

will vary 

20 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-3. CVN 68 MPCD Total Ownership Cost Comparison ($K/vessel) 

MPCD Option 

Total Initial 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Total 15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Annualized 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Total Owner

Inside 12 n

Inside+Beyond 

Gravity Coalescence 0/0 62/180 5.3/15.3 62/180 Centrifuge 1170/1170 28.4/97 102/108 1200/127CHT (within current holding capacity) 0/0 2440/2440 207/207 2440/244Hydrocyclone 224/224 20/91.4 20.7/27.3 244/321 Filter Media 208/208 869/869 91.5/91.5 1080/108Membrane Filtration 968/968 11/11 83.2/83.2 979/979 

21 

3

DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 CVN 68 Class Environmental Effects 

The environmental effects analysis of surface vessel bilgewater for this vessel group is 

summarized below in Table 3-4 and Table 3-5. 

Table 3-4. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric Water 

Quality Criteria in the Baseline Discharge and MPCD Discharges from Vessels with Nuclear Steam 

Propulsion (CVN 68) 

Discharge 

Constituent 

Strictest 

WQC Baseline 

Primary 

Treatment 

Primary 

Treatment Plus 

Filter Media1 

Primary Treatment 

Plus Membrane 

Filtration1 CHT2 

Cadmium 5.0E+00 5.4E+00 5.1E+00 5.1E+00 1.0E+003 0 

Copper 2.4E+00 2.6E+02 1.6E+02 1.6E+02 1.6E+02 0 

Iron 3.0E+02 5.2E+02 4.7E+02 1.9E+023 9.4E+013 0 

Mercury 2.5E-02 9.2E-02 5.2E-02 5.2E-02 5.2E-02 0 

Nickel 8.3E+00 3.0E+02 1.7E+02 1.3E+02 1.8E+02 0 

Selenium 1.0E+00 1.2E+01 ND ND ND 0 

Zinc 5.0E+01 1.6E+03 8.8E+02 5.3E+02 8.6E+02 0 

Number of 

Constituents 

exceeding strictest 

WQC 

- 7 6 5 4 0 

Total Exceeded 

Numeric Criteria - 78 77 76 74 0 

1

 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters 

 This concentration does not exceed water quality criteria. 

ND = Not Detected 

Table 3-5. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (CVN 68) 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Bis (2-Ethylhexyl) 

Phthalate 

TPE: 

5.5E+00 

3 

ND ND ND 0 

Cadmium 1.3E+00 1.3E+00 1.3E+00 2.5E-01 

0 

TPE: 8.8E-01 8.4E-01 8.4E-01 1.7E-01 

Copper 1.4E+02 8.4E+01 4.2E+01 4.8E+01 

0 

TPE: 2.5E+02 1.5E+02 7.6E+01 8.8E+01 

Iron 1.3E+02 1.1E+02 

ND ND 0 

TPE: 2.2E+-01 1.9E-01 

23 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Mercury 2.2E-02 1.3E-02 1.3E-02 1.3E-02 

0 

TPE: 2.6E+00 1.5E+00 1.5E+00 1.5E+00 

Nickel 7.4E+01 4.1E+01 3.1E+01 4.3E+01 

0 

TPE: 5.1E+01 2.8E+01 2.1E+01 2.9E+01 

Nitrate/Nitrite 1.3E+02 6.6E+01 4.0E+01 6.6E+01 

0 

TPE: 1.2E+01 6.1E+00 3.7E+00 6.1E+00 

Oil and Grease 

(HEM4

) 

TPE: 

1.3E+04 5.7E+03 1.7E+03 2.1E+03 

0 

Selenium 2.8E+00 

ND ND ND 0 

TPE: 2.3E-01 

Sulfate 1.2E+05 2.2E+05 2.2E+05 2.2E+05 

0 

TPE: 6.7E-01 1.2E+00 1.2E+00 1.2E+00 

Total Sulfide 2.0E+03 1.2E+03 2.5E+02 

ND 0 

TPE: 5.7E+03 3.4E+03 6.9E+02 

Zinc 4.0E+02 2.1E+02 1.3E+02 2.1E+02 

0 

TPE: 2.8E+01 1.5E+01 8.9E+00 1.5E+01 

Total TPE Load 6.1E+03 3.7E+03 8.8E+02 2.1E+02 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 3 No TPE value is calculated for this constituent. As discussed in the EEA Guidance Manual (Navy and EPA, 2000a), 

the use of a proxy value indicated that the contribution of this constituent to the total TPE value is relatively small. 4 HEM TEC value was based on the fuel/lube TEC. For more information, see Development of TECs for Categories 

of Oily Substances Derived from Petroleum and Foods (Navy and EPA, 2001c). 

ND = Not Detected 

Table 3-6. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Vessels with 

Nuclear Steam Propulsion (CVN 68) 

Baseline 

Primary 

Treatment 

Primary 

Treatment Plus 

Filter Media1 

Primary Treatment 

Plus Membrane 

Filtration1

 CHT2 

Number of Constituents 

exceeding strictest WQC 7 6 5 4 0 

Total Number of Exceeded 

Numeric WQC 78 77 76 74 0 

Number of Exceeded Narrative 

Categories 5 5 3 3 0 

Discharge HI at EOMZ 7.8E+01 4.7E+01 1.6E+01 1.1E+01 0 

Potential for NIS Release Low Low Low Low None 

Number of BCCs Identified 6 4 4 4 0 

Discharge TPE 6.1E+03 3.7E+03 8.8E+02 2.1E+02 0 

1

 Constituent concentrations were calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 

24 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

In summary, the application of CHT to bilgewater has the least environmental impact because 

there is no direct discharge to the receiving water within 12 nm. The secondary treatment 

options provide bilgewater treatment performance that is equal or superior, for each of the 

analysis methods (e.g., criteria exceedance, HI, and TPE), to primary treatment alone. Given the 

uncertainty associated with sample data, the environmental effects analysis could only 

distinguish between the two secondary treatment options by TPE ranking. Primary treatment is 

expected to result in fewer deleterious environmental effects than the baseline discharge. 

MPCD ranking by overall environmental effect: 

1. CHT 

2. Primary treatment plus membrane filtration 

3. Primary treatment plus filter media 

4. Primary treatment only 

Further information on the environmental effects analysis for this vessel group can be found in 

the respective chapter of the Bilgewater EEAR (Navy and EPA, 2003c). 

0.0.0 CVN 68 Class Cost-Benefit Analysis 

Cost benefit analysis for this vessel group is summarized below in Table 3-7. 

Table 3-7. TPEs Removed for each MCPD option and Associated Costs (CVN 68) 

Parameter (values per vessel group) Filter Media Membrane Filtration CHT 

TPE removed from primary discharge by 

listed treatment 2.80E+03 3.49E+03 3.90E+03 

Cost per TPE removed over primary treatment 

for existing vessels ($/yr) $359 $262 $584 

Cost per TPE removed after replacing existing 

group of vessels with new design vessels $329 $204 $519 

($/yr) 

Cost per pound of oil removed over primary 

treatment for existing vessels ($/yr) $526 $410 $620 

Cost per pound of oil removed after replacing 

existing group of vessels with new design $480 $320 $509 

vessels ($/yr) 

0.0 CONVENTIONAL STEAM POWERED VESSELS (LHD 1) 

This group consists of 62 vessels distributed among 19 vessel classes. Vessels in this group 

include three aircraft carriers, various large amphibious ships, auxiliaries, and Military Sealift 

Command (MSC) ships. These large ships range from 520 ft to over 1000 ft in length and from 

8,200 to over 60,000 displacement tons. These vessels use from two to eight boilers to generate 

steam for propulsion power, with approximately 72 % of the vessels using two boilers. These 

vessels operate outside 12 nm from shore except when on training exercises or transiting to and 

25 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

from port. Required daily boiler blowdowns result in larger volumes of bilgewater than in 

comparably sized ships powered by nuclear, gas turbine, or compression ignition engines. 

3.4.1 LHD 1 Class Characterization 

Characterization information was gathered on surface vessel bilgewater to support subsequent 

environmental effects and feasibility analyses. This information primarily included ship systems 

specifications and details regarding discharge composition. Ship systems data was acquired 

through process knowledge acquired from equipment experts. 

During Phase II, sampling was conducted aboard one vessel of the LHD 1 Class, USS 

BONHOMME RICHARD (LHD 6), on 16-17 December 1999. This sampling episode serves as 

the primary source of chemical data for this vessel group. The samples were analyzed by 

Columbia Analytical, Ecology and Environment, Pacific Analytical, and Q Biochem 

laboratories. The results were reviewed by EPA and DoD to determine the quality of the 

analytical data. Some sample data were excluded in the final calculations, as documented in the 

Draft Uniform National Discharge Standards Surface Vessel Bilgewater/ Oil-Water Separator 

(OWS) Discharge Sampling Episode Report -USS BONHOMME RICHARD (LHD 6) (Navy, 

2000a), based upon Sample Control Center (SCC) review. As discussed in Section 3.1.3, 

pesticide results were not included in bilgewater discharge profiles (Navy and EPA, 2003d). 

The characterization of the bilgewater discharge after secondary treatment could not be 

performed based on sample analysis because this operation is not in everyday practice aboard 

this vessel class. Discharge composition properties were estimated using Putnam and Singerman 

(2001) calculations as well as comparisons to the performance achieved by secondary treatment 

technology on other vessels. Further information on the characterization of this discharge can be 

found in the respective chapter of the Bilgewater ChAR (Navy and EPA, 2003a). 

3.4.2 LHD 1 Class Feasibility Impact 

The feasibility impact analysis of surface vessel bilgewater for this vessel group is summarized 

below in Table 3-8. 

26 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-8. LHD 1 Summary of Practicability and Operational Impact Analysis 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

Con

Re

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Current MPCD * (Gravity Coalescer) 

162 ft3 

4,800 lbs. (dry) 9,000 lbs 

No impact No impact 212 hrs 132 hrs None Electrical 

power—440VAC, 60Hz Potable water— 

Autocontremoswitc

(flooded) No impact 

primer, 25 psi max Sea water— 25 

OCM 

psi Gravity drain 

Centrifuge 787 ft3 

6,300 lbs (dry) 

No impact No impact 81 hrs 132 hrs Minimal 

consumables 

Electrical power— 440VAC 

Autocont

7,000 lbs required; special Compressed Air (ven(flooded) Existing OWS 

tools required, but included in the 

– 0.0058-0.029 scfm @ 50 psig 

recooper

would be initial purchase Potable water— durinremoved and replaced with 

50 gpd, 45 psi Gravity drain 

integtherm

unit Seawater- 25 psi cont

can with 

CHT—operating No impact— No impact No impact 710 hrs NA None None Nonfrom port with within current shoreside holding facilities capacity CHT—operating Significant Significant Significant Significant impact NA None None Nonfrom port without impact after impact after impact after one after one day shoreside one day one day day facilities Evaporation NF – excessive power requirements 

27 
DRAFT - Surface Vessel Bilgewater – DAR 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

Con

Re

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Hydrocyclone 168 ft3 

900 lbs (dry) 1,000 lbs (flooded) OWSs may have to be 

No impact No impact 46 hrs 132 hrs Minimal 

consumables and repair parts required 

Electrical power— 460VAC, 60 Hz 

Autoconttank switcequiOCM 

removed and replaced with a single unit. 

In Situ Biological NF – excessive bilgewater volume Treatment Oil Absorbing NF – potential safety (e.g., fire and flooding) hazard; solid waste handling impacts Socks Filter Media 85 ft3 

3,650 lbs (dry) 8,375 lbs (flooded) Existing workbench and storage locker may have to be removed; 

No impact No impact 5.3 hrs NA Requires 

replacement of filter media canisters 

None Auto

operrespprim

deballasting tanks and piping may have to be relocated. 

28 
DRAFT - Surface Vessel Bilgewater – DAR 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

Con

Re

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Membrane Filtration 

441 ft3 

9,200 lbs (dry) 12,000 lbs (flooded) Significant impacts on older vessels; extent of impacts on other vessels 

No impact No impact 28 hrs NA Requires 

replacement of membranes (performed shoreside) 

Electrical power— 440VAC, 60 HZ Compressed Air – 5 scfm at 80 to 100 psi Potable water – 10 gpm at 30 psi Gravity drain 

Autooperrespprim

will vary 

Table 3-9. LHD 1 MPCD Total Ownership Cost Comparison ($K/vessel) 

MPCD Option 

Initial 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Annualized 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Total Ownership 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Gravity Coalescence 0/0 53.5/86.7 4.5/7.4 53.5/86.7 Centrifuge 1161/1161 20/53 100/103 1181/1214 CHT (within current holding capacity) 

0/0 1249/1249 106/106 1249/1249 

Hydrocyclone 203/203 11/44 18/21 214/247 Filter Media 245/245 412/412 56/56 660/660 Membrane Filtration 943/943 7/7 81/81 950/950 

29 

DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 LHD 1 Class Environmental Effects 

The environmental effects analysis of surface vessel bilgewater for this vessel group is 

summarized below in Table 3-10 and Table 3-11. 

Table 3-10. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric 

Water Quality Criteria in the Baseline Discharge and MPCD Discharges from Vessels with 

Conventional Steam Propulsion (LHD 1) 

Strictest 

WQC Baseline 

Primary 

Primary 

Filter Media1 Filtration1 CHT2 

l 3 3 0 

0 

Bis (2-Ethylhexyl) 3 ND ND ND 0 

3 3

 ND 0 

0 

Iron 0 

3

 0 

0 

3 3 3 3

 0 

Nickel 0 

0 

Silver 1.0E-01 ND ND ND 0 

ND 0 

0 

0 

0 

Number of 

Constituents 

WQC 

- 13 12 11 10 0 

- 87 67 66 65 0 

Discharge Constituent Treatment 

Treatment Plus 

Primary Treatment 

Plus Membrane 

2,4-Dimethylpheno 2.7E+02 2.5E+02 5.9E+02 2.4E+02 5.9E+02 

Ammonia as Nitrogen 2.3E+02 5.6E+03 5.5E+03 5.5E+03 5.5E+03 

Phthalate 4.5E+03 1.8E+01

Cadmium 5.0E+00 5.3E+00 5.0E+00 5.0E+00

Copper 2.4E+00 4.0E+01 1.3E+01 1.3E+01 1.3E+01 

3.0E+02 2.2E+03 2.1E+03 8.6E+02 1.7E+03 

Lead 5.6E+00 1.0E+01 1.1E+01 1.1E+01 4.0E+00

Manganese 1.0E+02 1.3E+02 1.2E+02 1.2E+02 1.2E+02 

Naphthalene 1.4E+02 5.2E+01 5.2E+01 2.1E+01 5.2E+01

8.3E+00 5.1E+02 4.7E+02 3.5E+02 3.9E+02 

Selenium 1.0E+01 2.1E+01 2.1E+01 2.1E+01 2.1E+01 

6.1E+00 

Thallium 6.3E+00 1.2E+01 1.1E+01 1.1E+01 

Total Aqueous 

Hydrocarbons 1.5E+01 1.1E+02 9.5E+01 9.5E+01 9.5E+01 

Total Aromatic 

Hydrocarbons 1.0E+01 5.2E+01 5.2E+01 2.1E+01 5.2E+01 

Zinc 5.0E+01 2.0E+03 1.8E+03 1.1E+03 4.1E+02 

exceeding strictest 

Total Exceeded 

Numeric Criteria 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters within 12 nm. 3

 Does not exceed criteria. 

ND = Not detected 

31 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-11. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (LHD 1) 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

2,4-Dimethylphenol ND 4.6E+02 

ND 

4.6E+02 

0 

TPE: 2.5E+00 2.5E+00 

Ammonia as 

Nitrogen 4.3E+03 4.2E+03 4.2E+03 4.2E+03 

0 

TPE: 3.5E+01 3.5E+01 3.5E+01 3.5E+01 

Bis (2-Ethylhexyl) 

Phthalate 

TPE: 

1.4E+01 

3 

9.2E+00 

3 

ND ND 0 

Cadmium 4.0E+00 3.8E+00 3.8E+00 

ND 0 

TPE: 2.7E+00 3.8E+00 2.6E+00 

Copper 9.7E+02 8.7E+02 4.3E+02 1.8E+02 

0 

TPE: 1.8E+03 1.5E+03 8.0E+02 3.3E+02 

Iron 1.7E+03 1.6E+03 6.6E+02 1.3E+03 

0 

TPE: 2.9E+00 2.7E+00 1.1E+00 2.3E+00 

Lead 8.1E+00 8.2E+00 8.2E+00 3.1E+00 

0 

TPE: 5.3E+00 5.9E+00 5.9E+00 2.1E+00 

Manganese 1.0E+02 9.3E+01 9.3E+01 9.2E+01 

0 

TPE: 6.2E+01 5.6E+01 5.6E+01 5.6E+01 

Naphthalene 4.0E+01 4.0E+01 1.6E+01 4.0E+01 

0 

TPE: 1.9E+00 1.9E+00 7.6E-01 1.9E+00 

Nickel 3.9E+02 3.6E+02 2.7E+02 3.0E+02 

0 

TPE: 2.7E+02 2.5E+02 1.9E+02 2.0E+02 

Oil and Grease 

(HEM4

) 

TPE: 

4.1E+04 2.7E+04 

ND ND 0 

Selenium 1.6E+01 1.6E+01 1.6E+01 1.6E+01 

0 

TPE: 1.3E+00 1.3E+00 1.3E+00 1.3E+00 

Silver 4.7E+00 

ND ND ND 0 

TPE: 1.4E+02 

Sulfate 2.9E+05 3.3E+05 3.3E+05 3.3E+05 

0 

TPE: 1.6E+00 1.8E+00 1.8E+00 1.8E+00 

Thallium 9.1E+00 8.3E+00 8.3E+00 

ND 0 

TPE: 8.2E+00 7.5E+00 7.5E+00 

Total Sulfide 2.5E+03 2.0E+03 

ND ND 0 

TPE: 6.9E+03 5.6E+03 

Zinc 1.5E+03 1.4E+03 8.4E+02 3.2E+02 

0 

TPE: 1.0E+02 9.4E+01 5.9E+01 2.2E+01 

32 
1

DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Total TPE Load 9.4E+03 7.8E+03 1.3E+03 8.0E+02 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 3 No TPE value is calculated for this constituent. As discussed in the EEA Guidance Manual (Navy and EPA, 2000a), 

the use of a proxy value indicated that the contribution of this constituent to the total TPE value is relatively small. 4 HEM TEC value was based on the fuel/lube TEC. For more information, see Development of TECs for Categories 

of Oily Substances Derived from Petroleum and Foods (Navy and EPA, 2001c). 

ND = Not Detected 

Table 3-12. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Vessels with 

Conventional Steam Propulsion (LHD 1) 

Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 

Primary Treatment 

Plus Membrane 

Filtration1

 CHT 

Number of Constituents 

exceeding strictest WQC 13 12 11 10 0 

Total Number of 

Exceeded Numeric WQC 87 67 66 65 0 

Number of Exceeded 

Narrative Categories 8 8 2 4 0 

Discharge HI at EOMZ 6.5E+01 5.6E+01 1.9E+01 1.0E+01 0 

Potential for NIS Release Low Low Low Low None 

Number of BCCs 

Identified 7 7 6 5 0 

Discharge TPE 9.4E+03 7.8E+03 1.3E+03 8.0E+02 0 

 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 

In summary, the application of CHT to bilgewater has the least environmental impact because 

there is no direct discharge to the receiving water within 12 nm. The secondary treatment 

options provide bilgewater treatment performance that is superior for each of the analysis 

methods (e.g., criteria exceedance, HI, and TPE), to primary treatment alone. Primary treatment 

is expected to result in fewer deleterious environmental effects than the baseline discharge. 

MPCD ranking by overall environmental effect: 

1. CHT 

2. Primary treatment plus membrane filtration 

3. Primary treatment plus filter media 

4. Primary treatment only 

Further information on the environmental effects analysis for this vessel group can be found in 

the respective chapter of the Bilgewater EEAR (Navy and EPA, 2003c). 

33 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 LHD 1 Class Cost-Benefit Analysis 

Cost benefit analysis for this vessel group is summarized below in Table 3-13. 

Table 3-13. TPEs Removed for each MPCD Option and Associated Costs (LHD 1) 

Filter Media Membrane Filtration CHT 

TPE removed from primary 

discharge by listed treatment 7.60E+03 8.00E+03 9.40E+03 

Cost per TPE removed over 

primary treatment ($/yr) $413 $567 $631 

Each new vessel $7 $9 $61 

0.0 VESSELS WITH GAS TURBINES AND DRY BILGE (DDG 51) 

The only surface vessel class built with a dry bilge design is the Navy's latest class of guided 

missile destroyers, the USS ARLEIGH BURKE Class (DDG 51) which is the representative 

vessel class for the group. This vessel class has 33 active ships, and 18 ships in construction. 

The DDG 51 Class is powered by four GE LM 2500 gas turbines. In these vessels oily and nonoily machinery drain to segregated collection systems. Non-oily machinery drains are then 

pumped directly overboard and oily drains are pumped via the oily waste transfer system to the 

oily waste holding tank for processing by the oil/water separator. 

0.0.0 DDG 51 Class Characterization 

Characterization information was gathered on surface vessel bilgewater to support subsequent 

environmental effects and feasibility analyses. This information primarily included ship systems 

specifications and details regarding discharge composition. Ship systems data was acquired 

through process knowledge acquired from equipment experts. 

During Phase II of UNDS, sampling was conducted on two vessels of the DDG 51 Class, USS 

CARNEY (DDG 64) and USS MAHAN (DDG 72), and serves as the primary source of 

chemical data for this vessel group. Sampling was conducted twice on DDG 64 because the first 

sampling collection process was determined to be flawed due to sample collection methods. 

Therefore, CARNEY was resampled and only the second set of data was used. DDG-72 was 

sampled 18 September 2000 through 23 October 2000; The DDG-64 was sampled 15-17 June 

1999 and 29-30 June 1999. The samples were analyzed by Q Biochem (formally ETS Analytical 

Services), Pacific Analytical, Inc., and Columbia Analytical through Pacific Analytical, Inc. The 

results were reviewed by EPA and DoD to determine the quality of the analytical data; however 

some sample data were excluded in the final calculations, as documented in the Draft Sampling 

Episode Report-USS CARNEY (Navy, 2001a) and Draft Sampling Episode Report- USS MAHAN 

(Navy, 2000b), based upon Sample Control Center (SCC) review. As discussed in Section 3.1.3, 

pesticide results were not included in bilgewater discharge profiles (Navy and EPA, 2003d). 

The characterization of the bilgewater discharge after secondary treatment by ultrafiltration 

could not be performed based on sample analysis because this operation is not in everyday 

34 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

practice aboard this vessel class. Discharge composition properties were estimated using Putnam 

and Singerman (2001) calculations as well as comparisons to the performance achieved by 

ultrafiltration on CVN 68 Class vessels. Further information on the characterization of this 

discharge can be found in the respective chapter of the Bilgewater ChAR (Navy and EPA, 

2003a). 

3.5.2 DDG 51 Class Feasibility Impact 

The feasibility impact analysis of surface vessel bilgewater for this vessel group is summarized 

below in Table 3-14. 

35 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-14. DDG 51 Summary of Practicability and Operational Impact Analysis 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Current MPCD* (Gravity Coalescer) 

62.5 ft3 

1,250 lbs (dry) 2,710 lbs 

No impact No impact 18 hrs 77 hrs None Electrical power— 

440 VAC, 60Hz Potable water— 

Acore

(flooded) potential primer leNo impact Sea water—primer 

Gravity drain 

an

Centrifuge 134 ft3 

2,650 lbs (dry) 2,700 lbs (flooded) Existing OWS would be removed and replaced with unit 

No impact No impact 29 hrs 45 hrs Minimal 

consumables required; special tools required, but included in the initial purchase 

Electrical power— 440 VAC Compressed Air – 0.0058-0.029 cfm at 50 psig Potable water—20 gpd at 45 psi Sea water—25 psi Gravity drain 

Aco(vreopovduinthcocaeqO

CHT—operating No impact— No impact No impact 56 hrs NA None None Nfrom port with within current shoreside holding facilities capacity CHT—operating Significant Significant Significant Significant impact NA None None Nfrom port without impact after impact after impact after five after five days shoreside five days five days days facilities Evaporation NF – excessive power requirements 

36 
DRAFT - Surface Vessel Bilgewater – DAR 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Hydrocyclone 17 ft3 No impact No impact 10.5 hrs 51 hrs Consumables Compressed Air – A

132 lbs (dry) 150 lbs 

and repair parts required 

18 scfm at 65 psi co

ta

(flooded) (e.g., “O” rings, swExisting OWS would be 

gaskets for cyclone, 

be w

removed and cyclone liners, replaced with unit 

and pump components) 

In Situ Biological Treatment NF – excessive bilgewater volume Oil-Absorbing Socks NF – potential safety (e.g., fire and flooding) hazard; solid waste handling impacts Filter Media 16.9 ft3 

730 lbs (dry) 1675 lbs (flooded) Relocation of piping, furniture, and equipment would be 

No impact No impact 0.23 hrs NA Requires 

replacement of filter media canisters 

None A

oprepr

required 

Membrane Filtration 

227.5 ft3 

2,700 lbs (dry) 

No impact No impact 9.85 hrs NA Requires 

replacement of 

Electrical power— 440VAC, 60Hz 

Aop

3,000 lbs (flooded) 

membranes (performed 

Compressed Air— 80-100 psi, 5 scfm 

repr

Some space shoreside) Potable water—10 and weight impacts 

No consumables 

gpm at 30 psi Gravity drain 

or special tools required 

37 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-15. DDG 51 MPCD Total Ownership Cost Comparison ($K/Vessel) 

MPCD Option 

Initial 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Annualized 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Total Ownership 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Gravity Coalescence 0/0 4.6/19 .4/1.6 4.6/19 Centrifuge 210/210 6.9/11 18.4/18.8 217/221 CHT (within current holding capacity) 

0/0 61/61 5.2/5.2 61/61 

Hydrocyclone 62.6/62.6 2.8/13.4 5.6/6.5 65.4/76 Filter Media 84/84 18/18 8.8/8.8 104/104 Membrane Filtration 280/280 2.4/2.4 24/24 282/282 

38 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 DDG 51 Class Environmental Effects 

The environmental effects analysis of surface vessel bilgewater for this vessel group is 

summarized below in Table 3-16 and Table 3-17. 

Table 3-16. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric 

Water Quality Criteria in the Baseline Discharge and MPCD Discharges from Vessels with Gas 

Turbines and Dry Bilge (DDG 51) 

Strictest 

WQC Baseline 

Primary 

Primary 

Media1 

Primary 

plus 

Membrane 

Filtration1 CHT2 

0 

3 3 3 ND 0 

ND 0 

Iron 3 3 0 

ND 0 

3 0 

2.5E-02 2.1E-01 2.0E-01 2.1E-01 ND 0 

3 3 3 0 

Nickel 0 

ND 0 

3 3 3 0 

Silver 1.0E-01 ND ND 0 

3 3

 ND 0 

0 

0 

2.0E-03 ND ND 2.1E-02 0 

3 0 

Number of Constituents - 13 13 10 7 0 

Criteria - 84 93 56 28 0 

Discharge Constituent Treatment 

Treatment 

plus Filter 

Treatment 

Ammonia as Nitrogen 2.3E+02 9.7E+03 9.7E+03 8.5E+03 4.8E+03 

Cadmium 5.0E+00 4.3E+00 2.7E+00 1.3E+00

Copper 2.4E+00 2.8E+01 2.2E+01 1.3E+01 

3.0E+02 2.0E+03 1.1E+03 1.6E+02 7.8E+01

Lead 5.6E+00 3.4E+01 1.7E+01 6.1E+00 

Manganese 1.0E+02 1.7E+02 1.7E+02 9.4E+01 2.8E+02 

Mercury 

Naphthalene 1.4E+02 1.4E+02 7.2E+01 2.0E+01 4.4E+01

8.3E+00 8.0E+02 4.7E+02 1.4E+02 1.2E+02 

Phenanthrene 5.0E+00 4.6E+01 1.9E+01 1.2E+01 

Selenium 1.0E+01 4.4E+00 9.2E+00 1.4E+01 4.3E+00

7.6E+00 6.2E+00 

Thallium 6.3E+00 4.5E+00 5.7+00 1.2E+01 

Total Aqueous 

Hydrocarbons 1.5E+01 1.6E+02 1.1E+02 6.1E+01 3.0E+01 

Total Aromatic 

Hydrocarbons 1.0E+01 2.4E+02 1.2E+02 4.2E+01 5.5E+01 

Tributyltin 4.8E-02 

Zinc 5.0E+01 2.0E+03 1.2E+03 4.7E+02 1.5E+01

exceeding strictest WQC 

Total Exceeded Numeric 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 

2 CHT does not release constituents to the receiving waters within 12 nm. 

3 This concentration does not exceed water quality criteria.

ND = Not Detected 

39 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-17. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (DDG 051) 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

2-Methylnapthalene 

TPE: 

9.7E+00 

1.6E+00 

ND ND ND 0 

4-Chloro-3-

Methylphenol 

TPE: 

ND ND ND 

5.5E-01 

2.4E-03 

0 

Acenaphthene

TPE: 

 1.1E+00 

1.1E-02 

7.2E-01 

7.2E-03 

ND ND 0 

Ammonia as Nitrogen 5.0E+02 5.0E+02 4.4E+02 2.5E+02 

0 

TPE: 4.1E+00 4.1E+00 3.6E+00 2.0E+00 

Beryllium 

TPE: 

8.0E-02 

8.5E-02 

6.7E-02 

7.1E-02 

ND 

8.1E-02 

8.6E-02 

0 

Bis (2-Ethylhexyl) 

Phthalate 

TPE: 

1.2E+00 

3 

7.6E-01 

3 

ND ND 0 

Cadmium 2.2E-01 1.4E-01 6.6E-02 

ND 0 

TPE: 1.5E-01 9.4E-02 4.4E-02 

Chlorobenzene 5.5E-01 

ND ND ND 0 

TPE: 3.1E-03 

Copper 

TPE: 

1.3E+02 

2.4E+02 

6.6E+01 

1.2E+02 

1.6E+01 

2.8E+01 

ND 0 

Dibenzofuran 1.2E+00 1.0E+00 

ND ND 0 

TPE: 2.5E-01 2.2E-01 

Fluorene 1.8E+00 8.1E-01 5.5E-01 5.3E-01 

0 

TPE: 9.9E-02 4.5E-02 3.1E-02 3.0E-02 

Iron 1.0E+02 5.6E+01 

ND ND 0 

TPE: 1.8E-01 9.5E-02 

Lead 1.7E+00 8.6E-01 3.2E-01 

ND 0 

TPE: 1.2E+00 6.1E-01 2.2E-01 

Manganese 

TPE: 

9.0E+00 

5.6E+00 

8.8E+00 

5.3E+00 

ND 

1.4E+01 

8.8E+00 

0 

Mercury 

TPE: 

1.1E-02 

1.3E+00 

1.0E-02 

1.2E+00 

1.1E-02 

1.3E+00 

ND 0 

Naphthalene 7.0E+00 3.7E+00 1.0E+00 2.3E+00 

0 

TPE: 3.3E-01 1.7E-01 4.8E-02 1.1E-01 

Nickel 4.1E+01 2.5E+01 7.5E+00 6.1E+00 

0 

TPE: 2.8E+01 1.7E+01 5.1E+00 4.2E+00 

Nitrate/Nitrite 

TPE: 

1.0E+01 

9.5E-01 

8.1E+00 

7.5E-01 

ND ND 0 

40 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Oil and Grease 

(HEM4

) 

TPE: 

8.8E+03 2.4E+03 7.2E+02 4.9E+02 

0 

Phenanthrene 2.4E+00 1.0E+00 6.2E-01 

ND 0 

TPE: 1.2E+00 5.1E-01 3.1E-01 

Selenium 2.3E-01 4.8E-01 7.2E-01 2.2E-01 

0 

TPE: 1.8E-02 3.8E-02 5.7E-02 1.8E-02 

Silver 3.9E-01 3.2E-01 

ND ND 0 

TPE: 1.2E+01 9.5E+00 

Sulfate 5.1E+03 5.2E+03 4.2E+03 7.9E+03 

0 

TPE: 2.8E-02 2.9E-02 2.3E-02 4.4E-02 

Thallium 6.0E-01 

ND ND ND 0 

TPE: 5.3E-01 

Total Sulfide 1.8E+02 2.3E+02 1.8E+02 5.1E+02 

0 

TPE: 5.0E+02 6.5E+02 4.9E+02 1.4E+03 

Tributyltin 

TPE: 

ND 

2.5E-03 

1.4E+00 

ND 

1.1E-03 

6.2E-01 

0 

Zinc 1.0E+02 6.0E+01 2.4E+01 7.5E-01 

0 

TPE: 7.1E+00 4.1E+00 1.7E+00 5.2E-02 

Total TPE Load 8.3E+02 8.4E+02 5.5E+02 1.5E+03 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 3 No TPE value is calculated for this constituent. As discussed in the EEA Guidance Manual (Navy and EPA, 2000a), 

the use of a proxy value indicated that the contribution of this constituent to the total TPE value is relatively small. 4 HEM TEC value was based on the fuel/lube TEC. For more information, see Development of TECs for Categories 

of Oily Substances Derived from Petroleum and Foods (Navy and EPA, 2001c). 

ND = Not Detected 

41 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-18. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Vessels with Gas 

Turbines and Dry Bilge (DDG 51) 

Number of Constituents 

exceeding strictest WQC 

Total Number of Exceeded 

Numeric WQC 

Number of Exceeded 

Narrative Categories 

Discharge HI at EOMZ 

Potential for NIS Release 

Number of BCCs Identified 

Discharge TPE 

Baseline 

Bilgewater 

13 

83 

10 

1.6E+01 

Low 

13 

8.3E+02 

Primary 

Treatment 

13 

93 

10 

9.8E+00 

Low 

12 

8.4E+02 

Primary 

Treatment Plus 

Primary Treatment 

Plus Membrane 

Filter Media1 Filtration1 CHT 

10 7 0 

56 28 0 

3 5 0 

4.4E+00 9.0E+00 0 

Low Low None 

9 4 0 

5.5E+02 1.5E+03 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 

In summary, the application of CHT to bilgewater has the least environmental impact because 

there is no direct discharge to the receiving water within 12 nm. The secondary treatment 

options provide bilgewater treatment performance that is superior for most of the analysis 

methods (e.g., criteria exceedance and HI), to primary treatment alone with the exception of total 

discharge TPE. 

Due to high measured values of sulfides in membrane filtration samples, the discharge TPE 

value for membrane filter analysis is unexpectedly higher than for primary treatment alone. This 

may be due to sulfate reduction by anaerobic bacteria (anaerobic conditions are known to occur 

in bilges and oily water holding tanks of vessels.) A determination of the cause of these high 

sulfide levels is beyond the scope of the UNDS sampling and analysis effort. Because the 

weighting of analysis methods would be subjective, and each of the three treatment options is 

better in some ways than others, the three options rank equally. 

MPCD ranking by overall environmental effect: 

1. CHT 

2. Primary treatment plus membrane filtration, primary treatment plus filter media, primary 

treatment only 

Further information on the environmental effects analysis for this vessel group can be found in 

the respective chapter of the Bilgewater EEAR (Navy and EPA, 2003c). 

0.0.0 DDG 51 Class Cost-Benefit Analysis 

Cost benefit analysis for this vessel group is summarized below in Table 3-19. Values would not 

be applicable for membrane filtration analysis because, as discussed in the previous section 

(Section 3.5.3), the total discharge TPE value actually increased between primary and secondary 

treatment in this case. 

42 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-19. TPEs Removed for each MCPD Option and Associated Costs (DDG 51) 

Filter Media CHT 

li

TPE removed from primary 

discharge by sted treatment 2.00E+02 8.80E+02 

Cost per TPE removed over 

primary treatment ($/yr) $2,156 $290 

0.0 VESSELS WITH GAS TURBINES AND WET BILGE (DD 963) 

The Navy is the only branch of the Armed Forces that owns vessels powered exclusively by gas 

turbines. These vessels include guided missile cruisers, destroyers, frigates, and fast combat 

support ships. Amphibious landing craft air cushion (LCACs) are also powered by gas turbines. 

However, amphibious vehicles are not regulated by UNDS and are therefore not included in the 

vessel grouping (40 CFR 1700.1). Two Coast Guard vessel classes (WHEC 378 and WAGB 

399) and one Navy research vessel class (UB 165) are powered by combined CI and gas turbine 

(CODOG) systems. These CODOG vessels rely on their CI engines for routine operations at 

cruise speed, and occasionally use gas turbine for high speeds for certain situations (e.g., rescues) 

(Volpe, 2000). Therefore, these vessels were grouped with other vessel groups rather than the 

gas turbine vessel group.

2 All of the vessels included in the group range from 445 ft to 950 ft in 

length and from 2769 tons to 2900 tons in displacement. Vessels in this group operate beyond 12 

nm from shore except when transiting to and from port and training. These vessels use GE LM 

2500 gas turbines for propulsion. Three vessel classes, DD 963, CG 47, and AOE 6, which 

collectively account for 56 % of the hulls in the group, use four gas turbines. The other vessel 

classes (i.e., the FFG 7 and T-AKR 310) use two gas turbines. 

0.0.0 DD 963 Class Characterization 

Characterization information was gathered on surface vessel bilgewater to support subsequent 

environmental effects and feasibility analyses. This information primarily included ship systems 

specifications and details regarding discharge composition. Ship systems data was acquired 

through process knowledge acquired from equipment experts. 

During Phase II, sampling was conducted aboard one vessel of the DD 963 Class, the USS 

DAVID R. RAY (DD 971), on January 10-18 and February 7-11, 2000. These sampling 

episodes serve as the primary source of chemical data for this vessel group. Three bilgewater/ 

OWS discharge samples were collected during the first underway period and a fourth sample was 

collected during the second underway period. The samples were analyzed by Ecology and 

Environment, Inc., Pacific Analytical, Inc., and Q Biochem (formally ETS Analytical Services, 

Inc.). The results were reviewed by EPA and DoD to determine the quality of the analytical 

data; however some sample data were excluded in the final calculations, as documented in the 

Draft Sampling Episode Report -USS DAVID R. RAY (Navy, 2000c), based upon SCC review. 

2 The Coast Guard WHEC 378 and WAGB 399 were grouped with vessels that process both bilgewater and dirty 

ballast water through their OWS. The Navy vessel class UB 165 (ex PG 84) was placed in the small CI ship vessel 

group. 

43 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

As discussed in Section 3.1.3, pesticide results were not included in bilgewater discharge profiles 

(Navy and EPA, 2003d). 

The characterization of the bilgewater discharge after secondary treatment could not be 

performed based on sample analysis because this operation is not in everyday practice aboard 

this vessel class. Discharge composition properties were estimated using Putnam and Singerman 

(2001) calculations as well as comparisons to the performance achieved by secondary treatment 

technology on other vessels. Further information on the characterization of this discharge can be 

found in the respective chapter of the Bilgewater ChAR (Navy and EPA, 2003a). 

3.6.2 DD 963 Class Feasibility Impact 

The feasibility impact analysis of surface vessel bilgewater for this vessel group is summarized 

below in Table 3-20. 

44 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-20. DD 963 Summary of Practicability and Operational Impact Analysis 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Current MPCD * (Gravity Coalescer) 

63 ft3 1,250 lbs (dry) 2,710 lbs 

No impact No impact 122 hrs 456 hrs None Electrical power— 

440VAC, 60Hz Potable water— 

Acore

(flooded) potential primer leNo impact Sea water—primer 

Gravity drain 

an

Centrifuge 136.5 ft3 

2,650 lbs (dry) 2,700 lbs (flooded) Existing OWS would be removed and replaced with unit 

No impact No impact 91 hrs 260 hrs Minimal 

consumables required. Special tools required, but included in the initial purchase. 

Electrical power— 440VAC, 60-100kW Compressed Air--0.0058-0.029 scfm @ 50 psig Potable water—20 gpd, 45 psi Sea water—25 psi Gravity drain 

Aco(vreopovduinthcocaeqO

CHT—operating No impact— No impact No impact 270 hrs NA None None Nfrom port with within current shoreside holding facilities capacity CHT—operating Significant Significant Significant Significant impact NA None None Nfrom port without impact after impact after impact after after one day shoreside one day one day one day facilities Evaporation NF – excessive power requirements 

45 
DRAFT - Surface Vessel Bilgewater – DAR 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Hydrocyclone 17 ft3 

132 lbs (dry) 150 lbs (flooded) Existing OWS would be 

No impact No impact 81.5 hrs 300 hrs Minimal 

consumables required. 

Compressed Air: 18 scfm at 65 psi 

Acotaswbe w

removed and replaced with unit 

In-Situ Biological Treatment NF – excessive bilgewater volume Oil-Absorbing Socks NF – potential safety (e.g., fire and flooding) hazard; solid waste handling impacts Filter Media 16.9 ft3 

730 lbs (dry) 1675 lbs (flooded) Relocation of existing furniture required 

No impact No impact 2 hrs NA Requires 

replacement of filter media canisters 

None A

oprepr

Membrane Filtration 

227.5 ft3 

2,700 lbs (dry) 

No impact No impact 35 hrs NA Requires 

replacement of 

Electrical power— 440VAC, 60Hz 

Aop

3,000 lbs (flooded) 

membranes (performed 

CompressedAir— 80-100 psi, 5 scfm 

repr

No impact shoreside) Potable water—10 

gpm, 30 psi Gravity drain 

46 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-21. DD 963 MPCD Total Ownership Cost Comparison ($K/Vessel) 

MPCD Option 

Initial 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Annualized 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Total Ownership 

Inside 12 nm/ 

Inside+Beyond 12 nm 

Gravity Coalescence 0/0 31/150 2.7/13 31/150 Centrifuge 247/247 23/90 22.9/28.6 270/337 CHT (within current holding capacity) 

0/0 473/473 40.2/40.2 473/473 

Hydrocyclone 102.5/102.5 21/97 11/17 123/200 Filter Media 85/85 160/160 21/21 250/250 Membrane Filtration 300/300 8.8/8.8 26/26 310/310 

47 

DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 DD 963 Class Environmental Effects 

The environmental effects analysis of surface vessel bilgewater for this vessel group is 

summarized below in Table 3-22 and Table 3-23. 

Table 3-22. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric 

Water Quality Criteria in the Baseline Discharge and MPCD Discharges from Vessels with Gas 

Turbines and Wet Bilge (DD 963) 

Discharge 

Constituent 

Strictest 

WQC Baseline 

Primary 

Treatment 

Primary 

Treatment Plus 

Filter Media1 

Primary Treatment 

Plus Membrane 

Filtration1 CHT2 

Ammonia as Nitrogen 2.3E+02 4.1E+03 4.2E+03 4.2E+03 4.2E+03 0 

Copper 2.4E+00 1.6E+01 1.3E+01 1.3E+01 1.3E+01 0 

Iron 3.0E+02 3.5E+03 3.3E+02 1.3E+03 1.6E+03 0 

Manganese 1.0E+02 2.1E+02 2.2E+02 2.2E+02 2.1E+02 0 

Naphthalene 1.4E+02 2.5E+013 1.4E+013 ND ND 0 

Nickel 8.3E+00 2.5E+02 2.4E+02 1.8E+02 1.8E+02 0 

Phenanthrene 5.0E+00 1.3E+01 1.0E+01 ND ND 0 

Selenium 1.0E+01 2.3E+01 ND ND ND 0 

Total Aqueous 

Hydrocarbons 1.5E+01 1.1E+02 9.8E+01 9.8E+01 9.5E+01 0 

Total Aromatic 

Hydrocarbons 1.0E+01 5.0E+01 2.4E+01 ND ND 0 

Zinc 5.0E+01 1.8E+03 1.8E+03 1.1E+03 4.1E+02 0 

Number of 

Constituents 

Exceeding Strictest 

WQC 

- 10 9 7 7 0 

Total Exceeded 

Numeric Criteria - 65 64 60 60 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters within 12 nm. 3 This concentration does not exceed water quality criteria. 

ND = Not detected 

Table 3-23. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (DD 963) 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Ammonia as 

Nitrogen 1.8E+03 1.8E+03 1.8E+03 1.8E+03 

0 

TPE: 1.4E+01 1.5E+01 1.5E+01 1.5E+01 

Bis (2-Ethylhexyl) 

Phthalate 

TPE: 

ND 

4.8E+00 

3 

ND ND 0 

49 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Cadmium 6.9E-01 6.5E-01 6.5E-01 

ND 0 

TPE: 4.6E-01 4.3E-01 4.3E-01 

Copper 2.4E+02 2.3E+02 1.1E+02 5.0E+01 

0 

TPE: 4.3E+02 4.1E+02 2.1E+02 9.1E+01 

Fluorene 5.2E+00 

ND ND ND 0 

TPE: 2.9E-01 

Iron 1.5E+03 1.5E+03 5.8E+02 7.2E+02 

0 

TPE: 2.6E+00 2.5E+00 9.9E-01 1.2E+00 

Lead 8.7E-01 8.3E-01 8.3E-01 6.2E-01 

0 

TPE: 6.0E-01 5.8E-01 5.8E-01 4.3E-01 

Manganese 9.3E+01 9.5E+01 9.5E+01 9.3E+01 

0 

TPE: 5.7E+01 5.8E+01 5.8E+01 5.7E+01 

Naphthalene 

TPE: 

1.1E+01 

5.1E-01 

6.2E+00 

2.9E-01 

ND ND 0 

Nickel 1.1E+02 1.1E+02 7.9E+01 8.0E+01 

0 

TPE: 7.5E+01 7.2E+01 5.4E+01 5.4E+01 

Oil and Grease 

(HEM4

) 

TPE: 

1.4E+04 6.1E+03 

ND ND 0 

Phenanthrene 5.8E+00 4.4E+00 

ND ND 0 

TPE: 3.0E+00 2.2E+00 

Selenium 9.9E+00 

ND ND ND 0 

TPE: 7.9E-01 

Sulfate 5.0E+05 4.7E+05 4.7E+05 4.7E+05 

0 

TPE: 2.8E+00 2.7E+00 2.7E+00 2.7E+00 

Total Sulfide 1.2E+03 8.2E+02 

ND ND 0 

TPE: 3.5E+03 2.3E+03 

Zinc 7.7E+02 7.9E+02 4.7E+02 1.8E+02 

0 

TPE: 5.3E+01 5.5E+01 3.3E+01 1.2E+01 

Total TPE Load 4.3E+03 3.1E+03 5.5E+02 4.1E+02 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 3 No TPE value is calculated for this constituent. As discussed in the EEA Guidance Manual (Navy and EPA, 2000a), 

the use of a proxy value indicated that the contribution of this constituent to the total TPE value is relatively small. 4 HEM TEC value was based on the fuel/lube TEC. For more information, see Development of TECs for Categories 

of Oily Substances Derived from Petroleum and Foods (Navy and EPA, 2001c). 

ND = Not Detected 

50 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-24. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Vessels with Gas 

Turbines and Wet Bilge (DD 963) 

Baseline 

Bilgewater 

Primary 

Treatment 

Primary 

Treatment Plus 

Filter Media1 

Primary Treatment 

Plus Membrane 

Filtration1

 CHT 

Number of Constituents 

exceeding strictest WQC 10 9 7 7 0 

Total Number of 

Exceeded Numeric WQC 65 64 60 60 0 

Number of Exceeded 

Narrative Categories 7 7 2 3 0 

Discharge HI at EOMZ 7.6E+00 6.0E+00 2.3E+00 1.5E+00 0 

Potential for NIS Release Low Low Low Low None 

Number of BCCs 

Identified 8 7 4 3 0 

Discharge TPE 4.3E+03 3.1E+03 5.5E+02 4.1E+02 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 

In summary, the application of CHT to bilgewater has the least environmental impact because 

there is no direct discharge to the receiving water within 12 nm. The secondary treatment 

options provide bilgewater treatment performance that is superior for each of the analysis 

methods (e.g., criteria exceedance, HI, and TPE), to primary treatment alone. For most analysis 

methods, membrane filtration technology provided superior performance in terms of the 

environmental effects analysis methods used in this report. However, uncertainty due to 

potential inaccuracies of filter media performance because of channeling suggests that the filter 

media may not provide the environmental performance evidenced by these results. Primary 

treatment is expected to result in fewer deleterious environmental effects than the baseline 

discharge. 

MPCD ranking by overall environmental effect: 

1. CHT 

2. Primary treatment plus membrane filtration 

3. Primary treatment plus filter media 

3. Primary treatment only 

Further information on the environmental effects analysis for this vessel group can be found in 

the respective chapter of the Bilgewater EEAR (Navy and EPA, 2003c). 

0.0.0 DD 963 Class Cost-Benefit Analysis 

Cost benefit analysis for this vessel group is summarized below in Table 3-25. 

51 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-25. TPEs Removed for each MCPD Option and Associated Costs (DD 963) 

Filter Media Membrane Filtration CHT 

TPE removed from primary discharge 

by listed treatment 2.50E+03 2.63E+03 3.30E+03 

Cost per TPE removed over primary 

treatment ($/yr) $731 $860 $1,060 

3.7 DIESEL SHIPS OWS PROCESS BILGEWATER AND DIRTY BALLAST (WHEC 378) 

This group consists of 28 Coast Guard cutters distributed among three vessel classes: medium 

endurance cutters WMEC 210 (14 hulls), high endurance cutters WHEC 378 (12 hulls), and ice 

breakers WAGB 399 (2 hulls). The first class has CI propulsion while the latter two classes have 

both CI and gas turbine (CODOG) propulsion. However, CODOG vessels use their CI engines 

for routine operations at cruise speed, and occasionally use gas turbine for high-speed situations 

(e.g., rescues). Vessels in this group process their dirty ballast water through the same OWS 

used to process bilgewater. Therefore, they are equipped with an OWS four to ten times larger 

than comparably sized vessels that only process bilgewater. These vessels operate both inside 

and outside 12 nm from shore. 

3.7.1 WHEC 378 Class Characterization 

Characterization information was gathered on surface vessel bilgewater to support subsequent 

environmental effects and feasibility analyses. This information primarily included ship systems 

specifications and details regarding discharge composition. Ship systems data was acquired 

through process knowledge acquired from equipment experts. 

During UNDS Phase II, sampling was conducted aboard one vessel of the WHEC 378 Class, 

USCGC MORGENTHAU (WHEC 722) from 30 August 1999 to 7 September 1999 and 13-19 

November 1999. These sampling episodes serve as the primary source of chemical data for this 

vessel group. Two bilgewater/ OWS discharge samples were collected during each of the 

underway periods. The samples were analyzed by Ecology and Environment, Inc., Pacific 

Analytical, Inc., and Q Biochem (formally ETS Analytical Services, Inc.). The results were 

reviewed by EPA and DoD to determine the quality of the analytical data. However, some 

sample data were excluded in the final calculations as documented in the Draft Sampling 

Episode Report–USCGC MORGENTHAU (Navy, 2000d), based on Sample Control Center 

(SCC) review. As discussed in Section 3.1.3, pesticide results were not included in bilgewater 

discharge profiles (Navy and EPA, 2003d). 

Further information on the characterization of this discharge can be found in the respective 

chapter of the Bilgewater ChAR (Navy and EPA, 2003a). 

3.7.2 WHEC 378 Class Feasibility Impact 

The feasibility impact analysis of surface vessel bilgewater for this vessel group is summarized 

below in Table 3-26. 

52 
DRAFT -Surface Vessel Bilgewater – DAR 

Table 3-26. WHEC 378 Summary of Practicability and Operational Impact Analysis 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Current MPCD* (Gravity Coalescer) 

130 ft3 1,400 lbs (dry) 4,300 

No impact No impact 19.3 hrs 1.8 hrs None Electrical power— 

440VAC, 60Hz, motor – 1.5 HP 

(flooded) No impact 

Sea water—primer Gravity drain 

Centrifuge 393 ft3 

6,610 lbs (dry) 7,385 lbs (flooded) Existing OWS would be removed and replaced with unit 

No impact No impact 21.1 hrs 1.6 hrs Minimal 

consumables required. Special tools required, but included in the initial purchase. 

Electrical power.— 440VAC, 80-130kW Compressed Air--.0058-.029 scfm @ 50 psig Potable water—50 gpd, 45 psi Gravity drain 

CHT—operating No impact— No impact No impact 2.9 hrs NA None None from port with within current shoreside facilities holding 

capacity 

CHT—operating Significant Significant Significant Significant impact NA None None from port without impact after impact after impact after five after five days shoreside facilities five days five days days Evaporation NF – excessive power requirements Hydrocyclone 168 ft3 

900 lbs (dry) 1,000 lbs (flooded) Existing OWS would be 

No impact No impact 6.3 hrs 1.6 hrs Minimal 

consumables and repair parts required 

Electrical power— 440VAC, 60Hz 

removed and replaced with unit 

53 
DRAFT -Surface Vessel Bilgewater – DAR 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

In-Situ Biological Treatment NF – excessive bilgewater volume Oil-Absorbing Socks NF – potential safety (e.g., fire and flooding) hazard; solid waste handling impacts Filter Media NF – adequate space is not available Membrane Filtration NF – adequate space is not available 

Table 3-27. WHEC 378 MPCD Total Ownership Cost Comparison ($K/Vessel) 

MPCD Option 

Initial 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

Annualized 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

Total Ownership 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

Gravity Coalescence 0/0 5.46/3.25 0.464/0.277 5.46/3.25 Centrifuge 632/632 5.65/3.02 54/53.9 637/635 CHT (within current holding capacity) 

0/0 59.89/59.89 5.09/5.09 59.89/59.89 

Hydrocyclone 220/220 2.18/3.20 18.9/19.0 222/223 

54 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 WHEC 378 Class Environmental Effects 

The environmental effects analysis of surface vessel bilgewater for this vessel group is 

summarized below in Table 3-28. 

Table 3-28. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric 

Water Quality Criteria in the Baseline and MPCD Discharges from Compression Ignition Ships that 

OWS Process Bilgewater and Dirty Ballast (WHEC 378) 

Discharge Constituent Strictest WQC Baseline Primary Treatment CHT1 

Ammonia as Nitrogen 2.3E+02 5.8E+02 5.4E+02 0 

Boron 8.1E+03 5.6E+032 5.4E+032 0 

Cadmium 5.0E+00 6.3E+00 6.7E+00 0 

Chlorinated Naphthalenes 7.5E+00 2.8E+01 ND 0 

Copper 2.4E+00 1.4E+01 1.7E+01 0 

Iron 3.0E+02 3.5E+03 4.0E+03 0 

Lead 5.6E+00 2.7E+01 3.0E+01 0 

Manganese 1.0E+02 3.6E+02 3.6E+02 0 

Naphthalene 1.4E+02 3.3E+012 1.4E+02 0 

Nickel 8.3E+00 2.2E+02 2.3E+02 0 

Phenanthrene 5.0E+00 3.0E+01 2.8E+01 0 

Thallium 6.3E+00 9.9E+00 8.2E+00 0 

Total Aqueous Hydrocarbons 1.5E+01 2.3E+02 2.7E+02 0 

Total Aromatic Hydrocarbons 1.0E+01 9.5E+01 2.0E+02 0 

Zinc 5.0E+01 2.5E+03 2.9E+03 0 

Number Of Constituents Exceeding Strictest WQC - 13 13 0 

Total Exceeded Numeric Criteria - 85 86 0 

1 CHT does not release constituents to the receiving waters. 2 Does not exceed criteria

ND = Not detected

Table 3-29. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (WHEC 378) 

Discharge Constituent Baseline Primary Treatment CHT1 

2-Chloronaphthalene 

TPE: 

1.1E-01 

1.7E-02 

ND 0 

2-Methylnaphthalene 

TPE: 

ND 

1.0E+00 

1.6E-01 

0 

Ammonia as Nitrogen 

TPE: 

2.3E+00 

1.8E-02 

2.1E+00 

1.7E-02 

0 

Boron 2.2E+01 2.1E+01 

0 

TPE: 3.9E+00 3.8E+00 

55 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Discharge Constituent Baseline Primary Treatment CHT1 

Cadmium 2.5E-02 2.6E-02 

0 

TPE: 1.7E-02 1.8E-02 

Chlorobenzene 4.8E-02 5.1E-02 

0 

TPE: 2.7E-04 2.9E-04 

Copper 

TPE: 

1.8E+00 

3.2E+00 

2.2E+00 

4.0E+00 

0 

Fluorene 1.2E-01 1.1E-01 

0 

TPE: 7.0E-03 6.0E-03 

Iron 1.4E+01 1.6E+01 

0 

TPE: 2.3E-02 2.7E-02 

Lead 1.1E-01 1.2E-01 

0 

TPE: 7.3E-02 8.1E-02 

Manganese 

TPE: 

1.4E+00 

8.6E-01 

1.4E+00 

8.6E-01 

0 

Naphthalene 

TPE: 

1.3E-01 

6.0E-03 

5.6E-01 

2.6E-02 

0 

Nickel 8.5E-01 9.1E-01 

0 

TPE: 5.8E-01 6.2E-01 

Oil and Grease (HEM3) 

TPE: 

6.3E+02 5.1E+02 

0 

Phenanthrene 1.2E-01 1.1E-01 

0 

TPE: 6.0E-02 5.6E-02 

Sulfate 8.9E+02 8.6E+02 

0 

TPE: 5.0E-03 4.8E-03 

Thallium 3.9E-02 3.2E-02 

0 

TPE: 3.4E-02 2.9E-02 

Total Sulfide 1.5E+01 7.5E+00 

0 

TPE: 4.3E+01 2.1E+01 

Zinc 9.8E+00 1.1E+01 

0 

TPE: 6.8E-01 7.8E-01 

Total TPE Load 5.3E+01 3.2E+01 0 

1 CHT does not release constituents to the receiving waters. 2 No TPE value is calculated for this constituent. As discussed in the 

EEA Guidance Manual (Navy and EPA, 2000a), the use of a proxy 

value indicated that the contribution of this constituent to the total TPE 

value is relatively small. 3 HEM TEC value was based on the fuel/lube TEC. For more 

information, see Development of TECs for Categories of Oily

Substances Derived from Petroleum and Foods (Navy and EPA, 

2001c). 

ND = Not Detected 

56 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-30. Summary of EEA for Baseline and MPCD Discharges from Compression Ignition Ships 

that OWS Process Bilgewater and Dirty Ballast (WHEC 378) 

Baseline Bilgewater Primary Treatment CHT 

Number of Constituents exceeding strictest WQC 13 13 0 

Total Number of Exceeded Numeric WQC 85 86 0 

Number of Exceeded Narrative Categories 7 7 0 

Discharge HI at EOMZ 1.6E+00 1.1E+00 0 

Potential for NIS Release Low Low None 

Number of BCCs Identified 9 8 0 

Discharge TPE 5.3E+01 3.2E+01 0 

In summary, the application of CHT to bilgewater has the least environmental impact because 

there is no discharge to the receiving water. Primary treatment is expected to result in fewer 

deleterious environmental effects than the baseline discharge. 

MPCD ranking by overall environmental effect: 

1. CHT 

2. Primary treatment 

Further information on the environmental effects analysis for this vessel group can be found in 

the respective chapter of the Bilgewater EEAR (Navy and EPA, 2003c). 

0.0.0 WHEC 378 Class Cost-Benefit Analysis 

Cost benefit analysis for this vessel group is summarized below in Table 3-31. 

Table 3-31. TPEs Removed for each MCPD Option and Associated Costs (WHEC 378) 

CHT 

TPE removed from primary 

discharge by listed treatment 3.90E+03 

Cost per TPE removed over 

primary treatment ($/yr) $39 

0.0 LARGE COMPRESSION IGNITION VESSELS (LSD 41) 

This group consists of large CI ships of the Navy, MSC, and Coast Guard with displacements at 

or above 6000 tons. Vessels in this group include amphibious transport dock ships, combat 

stores ships, oilers, cable repairing ships, research and surveillance ships, surveying ships, ocean 

tugs, and logistic support ships. These large size vessels range from 420 ft to 950 ft in length 

and from 8,300 to 36,000 tons of displacement. Because of the large size of these ships, they 

57 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

primarily operate in ocean waters outside 12 nm from shore, except when on training exercises 

or transiting to and from port. Ships in this vessel group have between 1 to 5 propulsion engines, 

with approximately 50 % using four engines. All vessels in the group have substantial auxiliary 

machinery and equipment, and the vast majority have multiple propeller shafts. 

3.8.1 LSD 41 Class Characterization 

Characterization information was gathered on surface vessel bilgewater to support subsequent 

environmental effects and feasibility analyses. This information primarily included ship systems 

specifications and details regarding discharge composition. Ship systems data was acquired 

through process knowledge acquired from equipment experts. 

During UNDS Phase II, sampling was conducted aboard two vessels of the LSD 41 Class, USS 

OAK HILL (16-17 November), and USS RUSHMORE (26 September 2000, 17 October 2000, 

17 November 2000, and 13 December 2000). These two sampling episodes serve as the primary 

sources of chemical data for this vessel group. The samples were analyzed by Ecology and 

Environment, Inc., Pacific Analytical, Inc., Columbia Analytical Services (through Pacific 

Analytical, Inc.) and Q Biochem laboratories (formally ETS Analytical Services, Inc.). The 

results were reviewed by EPA and DoD to determine the quality of the analytical data; however 

some sample data were excluded from the final calculations, as documented in the Draft 

Sampling Episode Report – USS RUSHMORE (Navy, 2001b) and Draft Sampling Episode 

Report – USS OAK HILL (Navy, 2000e), based upon Sample Control Center (SCC) review. As 

discussed in Section 3.1.3, pesticide results were not included in bilgewater discharge profiles 

(Navy and EPA, 2003d). 

The characterization of the bilgewater discharge after secondary treatment by filter media could 

not be performed based on sample analysis because this operation is not in everyday practice 

aboard this vessel class. Discharge composition properties were estimated using Putnam and 

Singerman (2001) calculations as well as comparisons to the performance achieved by filter 

media on DDG 51 Class vessels. Further information on the characterization of this discharge 

can be found in the respective chapter of the Bilgewater ChAR (Navy and EPA, 2003a). 

3.8.2 LSD 41 Class Feasibility Impact 

The feasibility impact analysis of surface vessel bilgewater for this vessel group is summarized 

below in Table 3-32. 

58 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-32. LSD 41 Summary of Practicability and Operational Impact Analysis 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Current MPCD* (Gravity Coalescer) 

126 ft3 

2,500 lbs (dry) 5,420 lbs 

No impact No impact 79 hrs 286 hrs None Electrical power – 

440 VAC, 60 Hz Potable water – 

Acore

(flooded) potential primer leNo impact Sea water – primer 

Gravity drain 

an

Centrifuge 137 ft3 

2,650 lbs (flooded) 2,700 lbs (flooded) Existing OWS would be removed and replaced with unit 

No impact No impact 91.75 hrs 280 hrs Minimal 

consumables required. Special tools required, but included in the initial purchase. 

Electrical power— 440VAC, 60-100kW Compressed Air--0.0058-0.029 cfm @ 50 psig Potable water—20 gpd, 45 psi Sea water – 25 psi Gravity drain 

Aco(vreopovduinthcocaeqO

CHT—operating No impact – No impact No impact 480 hrs NA None None Nfrom port with within current shoreside holding facilities capacity CHT—operating Significant Significant Significant Significant impact NA None None Nfrom port without impact after impact after impact after after two days. shoreside two days. two days. two days. facilities Evaporation NF – excessive power requirements 

59 
DRAFT - Surface Vessel Bilgewater – DAR 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Hydrocyclone 17 ft3 

132 lbs (dry) 150 lbs (flooded) OWS would be removed 

No impact No impact 55.5 hrs 217 hrs Minimal 

consumables and repair parts required 

Compressed Air 27scfm @ 65 psi 

Acotaswbe w

and replaced with unit 

In -Situ Biological NF – excessive bilgewater volume Treatment Oil-Absorbing NF – potential safety (e.g., fire and flooding) hazard; solid waste handling impacts Socks Filter Media 16.9 ft3 

730 lbs (dry) 1,675 lbs (flooded) Relocation of workbench 

No impact No impact 2.0 hrs NA Requires 

replacement of filter media canisters 

None A

oprepr

and phone required 

Membrane Filtration 

227.5 ft3 

2,700 lbs (dry) 

No impact No impact 18.4 hrs NA Requires 

replacement of 

Electrical power— 440VAC, 60Hz 

Aop

3,000 lbs membranes Compressed Air - re(flooded) Some space 

(performed shoreside) 

80-100 psi, 5 scfm Potable water—10 

pr

and weight gpm, 30 psi impacts Gravity drain 

60 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-33. LSD 41 MPCD Total Ownership Cost Comparison ($K/Vessel) 

MPCD Option 

Total Initial 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

USCG Total 

15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

USCG 

Annualized 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

USCG 

Total Ownership 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

Other Military Services 

Total 15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

Other Military 

Services 

Annualized 

Inside 12 nm/ 

Inside+Beyond 12 

Gravity Coalescence 0/0 68/333 5.8/28.3 68/333 20/92 1.7/7.8 Centrifuge 301/301 71.3/335 31.6/54.0 372/636 23.4/94.7 27.5/33.6 CHT (within current holding capacity) 

0/0 4940/4940 420/420 4940/4940 520/520 44/44 

Hydrocyclone 123/123 62.4/310 15.8/36.8 185/433 14.5/69 11.7/16.3 Filter Media 145/145 160/160 25.6/25.6 301/301 160/160 25.6/25.6 Membrane Filtration 330/330 52.34/52.34 32.2/32.2 380/380 4.65/4.65 28.1/28.1 

61 

DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 LSD 41 Class Environmental Effects 

The environmental effects analysis of surface vessel bilgewater for this vessel group is 

summarized below in Table 3-34 and Table 3-35. 

Table 3-34. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric 

Water Quality Criteria in the Baseline and MPCD Discharges from Large Compression Ignition 

Ships (6000 tons of displacement or more) (LSD 41) 

Discharge Constituent 

Strictest 

WQC Baseline 

Primary 

Treatment 

Primary 

Treatment Plus 

Filter Media1 

Primary Treatment 

Plus Membrane 

Filtration1 CHT2 

Ammonia as Nitrogen 2.3E+02 1.2E+03 1.3E+00 1.3E+03 5.4E+02 0 

Copper 2.4E+00 1.3E+01 1.5E+01 1.5E+01 8.1E+00 0 

Iron 3.0E+02 3.4E+02 3.3E+02 1.3E+023 5.8E+013 0 

Lead 5.6E+00 8.9E+00 9.8E+00 9.8E+00 ND 0 

Manganese 1.0E+02 1.1E+02 1.1E+02 1.1E+02 1.2E+02 0 

Mercury 2.5E-02 ND ND ND 2.0E-01 0 

Nickel 8.3E+00 1.1E+02 1.1E+02 8.4E+01 3.4E+01 0 

Zinc 5.0E+01 4.1E+02 4.5E+02 2.7E+02 1.9E+013 0 

Phenanthrene 5.0E+00 1.1E+01 1.1E+01 ND ND 0 

Thallium 6.3E+00 1.5E+01 1.2E+01 1.2E+01 1.2E+01 0 

Total Aqueous 

Hydrocarbons 1.5E+01 7.4E+01 7.7E+01 7.7E+01 6.9E+01 0 

Total Aromatic 

Hydrocarbons 1.0E+01 2.4E+01 2.5E+01 ND 2.0E+01 0 

Number Of 

Constituents Exceeding 

Strictest WQC 

- 11 11 8 8 0 

Total Exceeded 

Numeric Criteria - 76 73 68 32 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 3 Does not exceed criteria. 

ND = Not detected 

Table 3-35. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (LSD 41) 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Ammonia as 

Nitrogen 4.8E+02 5.0E+02 5.0E+02 2.1E+02 

0 

TPE: 3.9E+00 4.0E+00 4.0E+00 1.7E+00 

63 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Cadmium 9.0E-01 9.2E-01 9.2E-01 

ND 0 

TPE: 6.0E-01 6.1E-01 6.1E-01 

Copper 7.7E+01 7.1E+01 3.6E+01 3.6E+00 

0 

TPE: 1.4E+02 1.3E+02 6.5E+01 6.6E+00 

Iron 1.3E+02 1.3E+02 

ND ND 0 

TPE: 2.2E-01 2.2E-01 

Lead 3.4E+00 3.8E+00 3.8E+00 

ND 0 

TPE: 2.4E+00 2.6E+00 2.6E+00 

Manganese 4.1E+01 4.2E+01 4.2E+01 4.6E+01 

0 

TPE: 2.5E+01 2.6E+01 2.6E+01 2.8E+01 

Mercury 

TPE: 

ND ND ND 

7.9E-02 

9.2E+00 

0 

Naphthalene 

TPE: 

5.1E+00 

2.4E-01 

5.6E+00 

2.6E-01 

ND 

7.7E+00 

3.6E-01 

0 

Nickel 4.3E+01 4.3E+01 3.3E+01 1.3E+01 

0 

TPE: 3.0E+01 3.0E+01 2.2E+01 9.0E+00 

Nitrate/Nitrite 

TPE: 

1.1E+03 

1.1E+02 

1.3E+03 

1.2E+02 

7.8E+02 

7.3E+01 

ND 0 

Oil and Grease 

(HEM4

) 

TPE: 

1.1E+04 8.6E+03 2.5E+03 5.1E+03 

0 

Phenanthrene 4.4E+00 4.2E+00 

ND ND 0 

TPE: 2.2E+00 2.1E+00 

Selenium 2.8E+00 2.7E+00 2.7E+00 1.4E+00 

0 

TPE: 2.2E-01 2.2E-01 2.2E-01 1.1E-01 

Sulfate 1.9E+05 1.9E+05 1.9E+05 1.7E+05 

0 

TPE: 1.1E+00 1.1E+00 1.1E+00 9.6E-01 

Thallium 6.0E+00 4.6E+00 4.6E+00 4.6E+00 

0 

TPE: 5.3E+00 4.1E+00 4.1E+00 4.1E+00 

Total Sulfide 1.2E+03 1.0E+03 8.4E+02 

ND 0 

TPE: 3.3E+03 2.9E+03 2.3E+03 

Zinc 1.6E+02 1.7E+02 1.0E+02 7.2E+00 

0 

TPE: 1.1E+01 1.2E+01 7.2E+00 5.0E-01 

Total TPE Load 3.7E+03 3.3E+03 3.4E+02 2.5E+03 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 

3 No TPE value is calculated for this constituent. As discussed in the EEA Guidance Manual (Navy and EPA, 

2000a), the use of a proxy value indicated that the contribution of this constituent to the total TPE value is relatively 

small. 4 HEM TEC value was based on the fuel/lube TEC. For more information, see Development of TECs for Categories 

of Oily Substances Derived from Petroleum and Foods (Navy and EPA, 2001c). 

ND=Not Detected 

64 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-36. Summary of EEA for Baseline and MPCD Discharges from Large Compression Ignition 

Ships (6000 tons of displacement or more) (LSD 41) 

Number of Constituents 

exceeding strictest WQC 

Total Number of 

Exceeded Numeric WQC 

Number of Exceeded 

Narrative Categories 

Discharge HI at EOMZ 

Potential for NIS Release 

Number of BCCs 

Identified 

Discharge TPE 

Baseline 

Bilgewater 

11 

76 

6 

1.6E+01 

Low 

7 

3.7E+03 

Primary 

Treatment 

11 

73 

6 

1.5E+01 

Low 

7 

3.3E+03 

Primary 

Treatment Plus 

Primary Treatment 

Plus Membrane 

Filter Media1 Filtration1

 CHT 

8 8 0 

68 32 0 

3 5 0 

4.2E+00 8.0E+00 0 

Low Low None 

5 5 0 

3.4E+02 2.5E+03 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 

In summary, the application of CHT to bilgewater has the least environmental impact because 

there is no direct discharge to the receiving water within 12 nm. The secondary treatment 

options provide bilgewater treatment performance that is superior for each of the analysis 

methods (e.g., criteria exceedance, HI, and TPE), to primary treatment alone. Primary treatment 

plus membrane filtration ranked ahead of filter media in regard to criteria exceedances, but 

resulted in higher HI and TPE values. However, uncertainty due to potential inaccuracies of 

filter media performance because of channeling suggests that the filter media may not provide 

the environmental performance evidenced by these results. Primary treatment is expected to 

result in fewer deleterious environmental effects than the baseline discharge. 

MPCD ranking by overall environmental effect: 

1. CHT 

2. Primary treatment plus membrane filtration, primary treatment plus filter media 

3. Primary treatment only 

Further information on the environmental effects analysis for this vessel group can be found in 

the respective chapter of the Bilgewater EEAR (Navy and EPA, 2003c). 

0.0.0 LSD 41 Class Cost-Benefit Analysis 

Cost benefit analysis for this vessel group is summarized below in Table 3-37. 

65 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-37. TPEs Removed for each MCPD Option and Associated Costs (LSD 41) 

TPE removed from primary discharge 

by listed treatment 

Cost for non-USCG vessels per TPE 

removed over primary treatment ($/yr) 

Each new vessel 

Cost for USCG vessels per TPE 

removed over primary treatment ($/yr) 

Each new vessel 

Filter Media Membrane Filtration CHT 

3.32E+03 1.60E+03 4.30E+03 

$393 $896 $522 

$7 $16 $25 

$8 $20 $98 

$7 $18 $112 

3.9 MEDIUM COMPRESSION IGNITION VESSELS (MCM 1) 

Medium ships are defined as vessels with displacements at or above 400 tons but below 6000 

tons. This group consists of medium sized CI ships of the Navy, MSC, Coast Guard, and Army, 

including tank landing ships, salvage ships, mine countermeasures, buoy tenders, research and 

surveillance ships, surveying ships, ocean tugs, and logistic support ships. Vessels in this group 

range from 128 ft to 522 ft in length, and from 534 tons to 4975 tons of displacement. Vessels in 

this group operate in both coastal and ocean waters outside 12 nm from shore. They have 

multiple propulsion engines and shafts, and substantial auxiliary machinery and equipment. The 

exception to this group was the inclusion of Navy floating dry docks (i.e., AFDL 1, AFDM 3, 

ARDM 1, ARDM 4, and IX 525 classes) and two USCG 120 ft barges (Barge 120), which do not 

have self propulsion, but that are equipped with multiple CI engines used for operation of pumps 

and as generators for auxiliary power. It is expected that these non-self propel vessels will 

generate bilgewater at rates and with oily constituents more similar to a medium diesel ship than 

to a barge that lacks engines or has minimal auxiliary machinery. An important consideration for 

the creation of this vessel group is that the smaller size of these vessels when compared with 

larger vessels (above 6000 tons) could place space limitations on the MPCDs considered. 

3.9.1 MCM 1 Class Characterization 

Characterization information was gathered on surface vessel bilgewater to support subsequent 

environmental effects and feasibility analyses. This information primarily included ship systems 

specifications and details regarding discharge composition. Ship systems data was acquired 

through process knowledge acquired from equipment experts. 

Due to similarities in machinery, propulsion systems, and ancillary equipment, the LSD 41 

vessel group discharge information is used to represent the MCM 1 vessel group. 

Further information on the characterization of this discharge can be found in the respective 

chapter of the Bilgewater ChAR (Navy and EPA, 2003a). 

3.9.2 MCM 1 Class Feasibility Impact 

The feasibility impact analysis of surface vessel bilgewater for this vessel group is summarized 

below in Table 3-38. 

66 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-38. MCM 1 Summary of Practicability and Operational Impact Analysis 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Current MPCD* (Gravity Coalescer) 

15 ft3 300 lbs (dry) 455 lbs 

No impact No impact 40.5 hrs 36 hrs None Electrical power.— 

115/230VAC 60Hz Fresh, salt, or 

Acore

(flooded) brackish water – leNo impact pressure regulated 

to 15 psi 

an

Centrifuge 6.9 ft3 

132 lbs (dry) 

No impact No impact 35.75 hrs 53 hrs Minimal 

consumables 

440 VAC Potable water- 1 

MO

OWS would and repair parts gpd be removed and replaced 

required 

with unit 

CHT—operating No impact— No impact No impact 75.6 hr NA None None Nfrom port with within current shoreside holding facilities capacity CHT—operating Significant Significant Significant Significant impact NA None None Nfrom port without impact after 3 impact after 3 impact after 3 after 3 days shoreside days days days facilities Evaporation NF – adequate space not available; excessive power requirements Hydrocyclone 8 ft3 

88 lbs (dry) 100 lbs (flooded) OWS would 

No impact No impact 16.5 hrs 27 hrs Minimal 

consumables and repair parts required 

Compressed Air – 65 psi, 12 scfm 

Acotasw

be removed and replaced with unit 

In-Situ Biological Treatment NF – excessive bilgewater volume Oil-Absorbing Socks NF – potential safety (e.g., fire and flooding) hazard; solid waste handling impacts 

67 
DRAFT - Surface Vessel Bilgewater – DAR 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

R

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Filter Media 36 ft3 

1320 lbs (dry) 1900 lbs 

No impact No impact 0.11 hrs 0 hrs Requires filter 

media canisters, which need to be 

None N

(flooded)1 

Relocation of 

replaced every 400 hours of 

piping, furniture and equipment required 

operation 

Membrane 227.5 ft3 No impact No impact 10.56 hrs .51 hrs Minimal 440 VAC, 60 hz NFiltration 2500 lbs 

(dry)1 

consumables and repair parts required 

Compressed Air – 80-100 psi, 5 scfm Potable Water – 10 gpm at 30 psi 

Table 3-39. MCM 1 MPCD Total Ownership Cost Comparison ($K/Vessel) 

MPCD Option 

Total Initial 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

USCG Total 

15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

USCG 

Annualized 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

USCG 

Total Ownership 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

Other Military Services 

Total 15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

Other Military 

Services 

Annualized 

Inside 12 nm/ 

Inside+Beyond 12 

Gravity Coalescence 0/0 12.9/26.8 1.10/2.279 12.9/26.8 10.1/19 .861/1.62 Centrifuge 96/96 11.5/29.4 9.12/10.7 107/125 8.78/22.1 8.88/10 CHT (within current holding capacity) 

0/0 294.9/294.9 25/06/25.06 294.9/294.9 41.8/41.8 3.55/3.55 

Hydrocyclone 93/93 6.9/18.7 8.49/9.49 99.9/112 4.15/11 8.3/8.83 Filter Media 94/94 9.25/9.25 8.77/8.77 103/103 9.25/9.25 8.77/8.77 Membrane Filtration 410/410 2.65/2.65 35.1/35.1 413/413 2.65/2.65 35.1/35.1 

68 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 MCM 1 Class Environmental Effects 

The environmental effects analysis of surface vessel bilgewater for this vessel group is 

summarized below in Table 3-40 and Table 3-41. 

Table 3-40. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric 

Water Quality Criteria in the Baseline Discharge and MPCD Discharges from Medium CI Ships 

(at or above 400 tons and under 6000 tons) 

(MCM 1 Based on LSD 41 Surrogate Data) 

Discharge Constituent 

Strictest 

WQC Baseline 

Primary 

Treatment 

Primary 

Treatment Plus 

Filter Media1 

Primary Treatment 

Plus Membrane 

Filtration1 CHT2 

Saltwater: 

Ammonia as Nitrogen 2.3E+02 1.2E+03 1.3E+03 1.3E+03 5.4E+02 0 

Cadmium 5.0E+00 2.3E+003 2.4E+003 2.4E+003 ND 0 

Copper 2.4E+00 1.3E+01 1.5E+01 1.5E+01 8.1E+00 0 

Iron 3.0E+02 3.4E+02 3.3E+02 1.3E+023 5.8E+013 0 

Lead 5.6E+00 8.9E+00 9.8E+00 9.8E+00 ND 0 

Manganese 1.0E+02 1.1E+02 1.1E+02 1.1E+02 1.2E+02 0 

Mercury 2.5E-02 ND ND ND 2.0E-01 0 

Nickel 8.3E+00 1.1E+02 1.1E+02 8.4E+01 3.4E+01 0 

Phenanthrene 5.0E+00 1.1E+01 1.1E+01 ND ND 0 

Thallium 6.3E+00 1.5E+01 1.2E+01 1.2E+01 1.2E+01 0 

Total Aqueous 

Hydrocarbons 1.5E+01 7.4E+01 7.7E+01 7.7E+01 6.9E+01 0 

Total Aromatic 

Hydrocarbons 1.0E+01 2.4E+01 2.5E+01 ND 2.0E+01 0 

Zinc 5.0E+01 4.1E+02 4.5E+02 2.7E+02 1.9E+013 0 

Freshwater: 

Cadmium 1.1E+00 2.3E+00 2.4E+00 2.4E+00 ND 0 

Copper 8.8E+00 1.3E+01 1.5E+01 1.5E+01 9.4E+003 0 

Zinc 6.4E+01 9.8E+01 9.1E+01 9.1E+01 1.9E+013 0 

Number Of 

Constituents Exceeding 

Strictest WQC 

- 14 14 11 8 0 

Total Exceeded 

Numeric Criteria - 96 93 88 32 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 3 Value does not exceed criteria. 

ND = Not detected 

69 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-41. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (MCM 1) 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Saltwater: 

Ammonia as 

Nitrogen 5.9E+01 6.1E+01 6.1E+01 2.5E+01 

0 

TPE: 4.8E-01 5.0E-01 5.0E-01 2.1E-01 

Cadmium 1.1E-01 1.1E-01 1.1E-01 

ND 0 

TPE: 7.4E-02 7.5E-02 7.5E-02 

Copper 9.5E+00 8.8E+00 4.4E+00 4.5E-01 

0 

TPE: 1.7E+01 1.6E+01 8.0E+00 8.1E-01 

Iron 1.6E+01 1.6E+01 

ND ND 0 

TPE: 2.7E-02 2.7E-02 

Lead 4.2E-01 4.7E-01 4.7E-01 

ND 0 

TPE: 2.9E-01 3.2E-01 3.2E-01 

Manganese 5.1E+00 5.1E+00 5.1E+00 5.7E+00 

0 

TPE: 3.1E+00 3.2E+00 3.2E+00 3.5E+00 

Mercury 

TPE: 

ND ND ND 

9.7E-03 

1.1E+00 

0 

Naphthalene 

TPE: 

6.3E-01 

2.9E-02 

6.9E-01 

3.3E-02 

ND 

9.5E-01 

4.5E-02 

0 

Nickel 5.3E+00 5.3E+00 4.0E+00 1.6E+00 

0 

TPE: 3.7E+00 3.7E+00 2.7E+00 1.1E+00 

Nitrate/Nitrite 

TPE: 

1.4E+02 

1.3E+01 

1.6E+02 

1.5E+01 

9.6E+01 

8.9E+00 

ND 0 

Oil and Grease 

(HEM4

) 

TPE: 

1.3E+03 1.0E+03 3.1E+02 6.1E+02 

0 

Phenanthrene 5.4E-01 5.1E-01 

ND ND 0 

TPE: 2.7E-01 2.6E-01 

Selenium 3.4E-01 3.4E-01 3.4E-01 1.7E-01 

0 

TPE: 2.7E-02 2.7E-02 2.7E-02 1.4E-02 

Sulfate 2.4E+04 2.3E+04 2.3E+04 2.1E+04 

0 

TPE: 1.3E-01 1.3E-01 1.3E-01 1.2E-01 

Thallium 7.3E-01 5.7E-01 5.7E-01 5.6E-01 

0 

TPE: 6.5E-01 5.1E-01 5.1E-01 5.0E-01 

Total Sulfide 1.4E+02 1.3E+02 1.0E+02 

ND 0 

TPE: 4.0E+02 3.5E+02 2.9E+02 

Zinc 2.0E+01 2.1E+01 1.3E+01 8.8E-01 

0 

TPE: 1.4E+00 1.5E+00 8.8E-01 6.1E-02 

Total TPE Load 4.6E+02 4.1E+02 4.1E+01 3.1E+02 0 

70 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Discharge 

Constituent Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 Primary Treatment Plus Membrane Filtration1 CHT2 

Freshwater: 

Cadmium 1.5E-02 1.5E-02 1.5E-02 

ND 0 

TPE: 3.9E-02 3.9E-02 3.9E-02 

Copper 1.3E+00 1.2E+00 5.9E-01 6.0E-02 

0 

TPE: 7.9E-01 7.3E-01 3.7E-01 3.7E-02 

Iron 2.2E+00 2.1E+00 

ND ND 0 

TPE: 1.2E-02 1.2E-02 

Lead 5.6E-02 6.2E-02 6.2E-02 

ND 0 

TPE: 1.3E-01 1.4E-01 1.4E-01 

Manganese 6.8E-01 6.8E-01 6.8E-01 7.5E-01 

0 

TPE: 4.8E-02 4.8E-02 4.8E-02 5.3E-02 

Mercury ND ND ND 1.3E-03 

1.5E-01 

0 

TPE: 

Naphthalene 

TPE: 

8.3E-02 

1.3E-03 

9.2E-02 

1.4E-03 

ND 

1.3E-01 

1.9E-03 

0 

Nickel 7.1E-01 7.1E-01 5.3E-01 

ND 0 

TPE: 7.8E-02 7.7E-02 5.8E-02 

Nitrate/Nitrite 

TPE: 

1.9E+01 

1.7E+00 

2.1E+01 

2.0E+00 

1.3E+01 

1.2E+00 

ND 0 

Oil and Grease 

(HEM4

) 

TPE: 

1.7E+02 1.4E+02 4.1E+01 8.2E+01 

0 

Phenanthrene 7.2E-02 6.8E-02 

ND ND 0 

TPE: 2.1E-02 2.0E-02 

Selenium 4.6E-02 4.5E-02 4.5E-02 2.3E-02 

0 

TPE: 5.1E-02 5.0E-02 5.0E-02 2.6E-02 

Sulfate 3.2E+03 3.1E+03 3.1E+03 2.8E+03 

0 

TPE: 1.8E-02 1.7E-02 1.7E-02 1.6E-02 

Thallium 9.8E-02 7.6E-02 7.6E-02 7.5E-02 

0 

TPE: 9.8E-02 7.6E-02 7.6E-02 7.5E-02 

Total Sulfide 1.9E+01 1.7E+01 1.4E+01 

ND 0 

TPE: 5.4E+01 4.7E+01 3.8E+01 

Zinc 2.6E+00 2.8E+00 1.7E+00 1.2E-01 

0 

TPE: 1.2E-01 1.3E-01 7.9E-02 5.5E-03 

Total TPE Load 5.9E+01 5.3E+01 4.2E+00 4.1E+01 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 3 No TPE value is calculated for this constituent. As discussed in the EEA Guidance Manual (Navy and EPA, 2000a), 

the use of a proxy value indicated that the contribution of this constituent to the total TPE value is relatively small. 4 HEM TEC value was based on the fuel/lube TEC. For more information, see Development of TECs for Categories 

of Oily Substances Derived from Petroleum and Foods (Navy and EPA, 2001c). 

ND = Not Detected 

71 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-42. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Medium CI Ships 

(at or above 400 tons and under 6000 tons) (MCM 1 Based on LSD 41 Surrogate Data) 

Baseline 

Bilgewater 

Primary 

Treatment 

Primary 

Treatment Plus 

Filter Media1 

Primary Treatment 

Plus Membrane 

Filtration1 CHT 

Number of Constituents 

exceeding strictest 

WQC 

14 14 11 8 0 

Total Number of 

Exceeded Numeric 

WQC 

96 93 88 32 0 

Number of Exceeded 

Narrative Categories 8 8 4 7 0 

Discharge HI at EOMZ 3.9E-01 3.6E-01 1.0E-01 1.9E-01 0 

Potential for NIS 

Release Low Low Low Low None 

Number of BCCs 

Identified 7 7 5 5 0 

Discharge TPE 

(Saltwater) 4.6E+02 4.1E+02 4.1E+01 3.1E+02 0 

Discharge TPE 

(Freshwater) 5.9E+01 5.3E+01 4.2E+00 4.1E+01 0 

1

 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 

In summary, the application of CHT to bilgewater has the least environmental impact because 

there is no direct discharge to the receiving water. The secondary treatment options provide 

bilgewater treatment performance that is superior for each of the analysis methods (e.g., criteria 

exceedance, HI, and TPE), to primary treatment alone. In addition, uncertainty due to potential 

variation in filter media performance because of channeling suggests that the filter media may 

not provide the environmental performance evidenced by these results. Primary treatment is 

expected to result in fewer deleterious environmental effects than the baseline discharge. 

MPCD ranking by overall environmental effect: 

1. CHT 

2. Primary treatment plus membrane filtration, or primary treatment plus filter media 

3. Primary treatment only 

Further information on the environmental effects analysis for this vessel group can be found in 

the respective chapter of the Bilgewater EEAR (Navy and EPA, 2003c). 

0.0.0 MCM 1 Class Cost-Benefit Analysis 

Cost benefit analysis for this vessel group is summarized below in Table 3-43. 

72 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-43. TPEs Removed for each MCPD Option and Associated Costs (MCM 1) 

Filter Media Membrane Filtration CHT 

TPE removed from primary discharge 

by listed treatment 3.90E+02 1.60E+02 5.30E+02 

Cost to non-USCG per TPE removed 

over primary treatment ($/yr) $2,811 $27,422 $837 

Each new vessel $17 $181 $12 

Cost to USCG per TPE removed over 

primary treatment ($/yr) $1,484 $14,561 $3,121 

Each new vessel $17 $188 $52 

3.10 SMALL COMPRESSION IGNITION VESSELS (WPB 110) 

Small ships are defined as vessels under 400 tons of displacement, and 65 ft or more in length. 

This group consists of more than 60 vessel classes including landing craft, patrol ships, torpedo 

trial craft, harbor tugs, and small buoy tenders. These ships have no more than four main 

propulsion CI engines. While smaller ships have auxiliary machinery, the size and amount of the 

equipment are substantially less than in ships over 400 tons. These vessels routinely operate 

within 12 nm from shore and in inland waters. However, some of the larger vessels in this group 

are designed as oceangoing vessels. 

Ships in this vessel group receive fluids in the bilge mainly from condensation that forms on the 

interior hull and on piping, and from leaking pump packing glands, piping, valves, and flanges. 

The bilgewater of these ships may have oily constituents from DFM used for main engines and 

generators and lubricants such as 9250 lube oil (main engines and generators), 2190TEP lube oil 

(auxiliary equipment), hydraulic oil (elevators, cranes, and winches), and various grades of 

grease lubricants, used on pulleys, cables, valves, and other components. 

3.10.1 WPB 110 Class Characterization 

Characterization information was gathered on surface vessel bilgewater to support subsequent 

environmental effects and feasibility analyses. This information primarily included ship systems 

specifications and details regarding discharge composition. Ship systems data was acquired 

through process knowledge acquired from equipment experts. 

Due to similarities in machinery, propulsion systems, and ancillary equipment, the LSD 41 

vessel group discharge information is used to represent the WPB 110 vessel group. 

Further information on the characterization of this discharge can be found in the respective 

chapter of the Bilgewater ChAR (Navy and EPA, 2003a). 

3.10.2 WPB 110 Class Feasibility Impact 

The feasibility impact analysis of surface vessel bilgewater for this vessel group is summarized 

below in Table 3-44. 

73 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-44. WPB 110 Summary of Practicability and Operational Impact Analysis 

MPCD Option 

PRACTICABILITY AND OPERATIONAL IMPACT STUDY 

Space and 

Weight 

Personnel/ 

Equipment 

Safety 

Mission 

Capabilities 

Personnel Impact 

(operator labor hrs/year) Consumables, 

Repair Parts, 

and Tools 

Interface 

Requirements 

Within 12 nm 

(inc. maintenance) 

Beyond 

12 nm 

Current MPCD* 12.5 ft3 No impact No impact 4.1 hrs 0.39 hrs None Electrical power.— A(Gravity 132 lbs (dry) 110/220VAC, cCoalescer) 190 lbs 50/60Hz, 1 Phase r

(flooded) lNo impact a

Centrifuge 7 ft3 No impact No impact 9.85 hrs 0.39 hrs Minimal 440 VAC M

132 lbs (dry) OWS would 

consumables and repair parts 

Potable water- 1 gpd 

O

be removed required and replaced with unit 

CHT—operating No impact— No impact No impact 1.2 hr NA None None Nfrom port with within current shoreside holding facilities capacity CHT—operating No impact— No impact No impact No impact NA None None Nfrom port without within current shoreside holding facilities capacity Evaporation NF – adequate space not available; excessive power requirements Hydrocyclone NF – compressed air not available In Situ Biological Treatment NF – cannot support batch treatment process Oil Absorbing Socks NF – potential safety (e.g., fire and flooding) hazard; solid waste handling impacts Filter Media NF – adequate space not available Membrane Filtration NF – adequate space not available 

74 
DRAFT - Surface Vessel Bilgewater – DAR 

Table 3-45. WPB 110 MPCD Total Ownership Cost Comparison ($K/Vessel) 

MPCD Option 

Total Initial 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

USCG Total 

15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

USCG 

Annualized 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

USCG 

Total Ownership 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

Other Military Services 

Total 15-Yr Recurring 

Inside 12 nm/ 

Inside+Beyond 

12 nm 

Other Military 

Services 

Annualized 

Inside 12 nm/ 

Inside+Beyond 12 

Gravity Coalescence 0/0 1.3/1.5 .11/.13 1.3/1.5 1.0/1.1 0.09/0.09 Centrifuge 63.6/63.6 2.8/2.9 5.6/5.7 66.4/66.5 2.5/2.6 5.6/5.6 CHT (within current holding capacity) 

0/0 28.66/28.66 2.436/2.436 28.66/28.66 2.63/2.63 .223/.223 

75 

DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0.0 WPB 110 Class Environmental Effects 

The environmental effects analysis of surface vessel bilgewater for this vessel group is 

summarized below in Table 3-46 and Table 3-47. 

Table 3-46. Comparison of Discharge Constituent Concentrations (μg/L) that Exceed Numeric 

Water Quality Criteria in the Baseline Discharge and MPCD Discharges from Small Compression 

Ignition Ships (65 feet or more in length and under 400 tons of displacement) (WPB 110 Based on 

LSD 41 Surrogate Data) 

Discharge Constituent 

Strictest 

WQC Baseline 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 CHT2 

Saltwater: 

Ammonia as Nitrogen 2.3E+02 1.2E+03 1.3E+03 1.3E+03 0 

Copper 2.4E+00 1.3E+01 1.5E+01 1.5E+01 0 

Iron 3.0E+02 3.4E+02 3.3E+02 1.3E+023 0 

Lead 5.6E+00 8.9E+00 9.8E+00 9.8E+00 0 

Manganese 1.0E+02 1.1E+02 1.1E+02 1.1E+02 0 

Nickel 8.3E+00 1.1E+02 1.1E+02 8.4E+01 0 

Phenanthrene 5.0E+00 1.1E+01 1.1E+01 ND 0 

Thallium 6.3E+00 1.5E+01 1.2E+01 1.2E+01 0 

Total Aqueous Hydrocarbons 1.5E+01 7.4E+01 7.7E+01 7.7E+01 0 

Total Aromatic Hydrocarbons 1.0E+01 2.4E+01 2.5E+01 ND 0 

Zinc 5.0E+01 4.1E+02 4.5E+02 2.7E+02 0 

Freshwater: 

Cadmium 1.1E+00 2.3E+00 2.4E+00 2.4E+00 0 

Copper 8.8E+00 1.3E+01 1.5E+01 1.5E+01 0 

Zinc 6.4E+01 9.8E+01 9.1E+01 9.1E+01 0 

Number of Constituents 

exceeding strictest WQC - 14 14 11 0 

Total Exceeded Numeric 

Criteria - 96 93 88 0 

1 For new design consideration only. Constituent concentrations are calculated using methodology described 

in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 3

 Value does not exceed criteria. 

ND = Not detected 

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Table 3-47. Comparison of Discharge Constituents of Concern Mass Loading (lbs/yr) and Toxic 

Pound Equivalent Loading (TPE lbs/yr) in Baseline and MPCD Discharges from Vessels with 

Nuclear Steam Propulsion (WPB 110) 

Discharge Constituent Baseline 

Primary 

Treatment 

Primary 

Treatment Plus 

Filter Media1 CHT2 

Saltwater: 

Ammonia as Nitrogen 1.9E+01 2.0E+01 2.0E+01 

0 

TPE: 1.6E-01 1.6E-01 1.6E-01 

Cadmium 3.6E-02 3.7E-02 3.7E-02 

0 

TPE: 2.4E-02 2.5E-02 2.5E-02 

Copper 3.1E+00 2.9E+00 1.4E+00 

0 

TPE: 5.6E+00 5.2E+00 2.6E+00 

Iron 5.3E+00 5.1E+00 

ND 0 

TPE: 9.0E-03 8.7E-03 

Lead 1.4E-01 1.5E-01 1.5E-01 

0 

TPE: 9.6E-02 1.1E-01 1.1E-01 

Manganese 1.7E+00 1.7E+00 1.7E+00 

0 

TPE: 1.0E+00 1.0E+00 1.0E+00 

Naphthalene 

TPE: 

2.1E-01 

9.6E-03 

2.3E-01 

1.1E-02 

ND 0 

Nickel 1.8E+00 1.8E+00 1.3E+00 

0 

TPE: 1.2E+00 1.2E+00 9.0E-01 

Nitrate/Nitrite 4.6E+01 5.3E+01 3.2E+01 

0 

TPE: 4.3E+00 4.9E+00 2.9E+00 

Oil and Grease (HEM4) 

TPE: 

4.2E+02 3.4E+02 1.0E+02 

0 

Phenanthrene 1.8E-01 1.7E-01 

ND 0 

TPE: 9.0E-02 8.6E-02 

Selenium 1.1E-01 1.1E-01 1.1E-01 

0 

TPE: 8.9E-03 8.8E-03 8.8E-03 

Sulfate 7.8E+03 7.7E+03 7.7E+03 

0 

TPE: 4.4E-02 4.3E-02 4.3E-02 

Thallium 2.4E-01 1.9E-01 1.9E-01 

0 

TPE: 2.1E-01 1.7E-01 1.7E-01 

Total Sulfide 4.7E+01 4.1E+01 

ND 0 

TPE: 1.3E+02 1.2E+02 

Zinc 6.4E+00 7.0E+00 4.2E+00 

0 

TPE: 4.4E-01 4.9E-01 2.9E-01 

Total TPE Load 1.5E+02 1.3E+02 1.4E+01 0 

Freshwater: 

Cadmium 3.6E-03 3.6E-03 3.6E-03 

0 

TPE: 9.4E-03 9.5E-03 9.5E-03 

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DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Discharge Constituent Baseline 

Primary 

Treatment 

Primary 

Treatment Plus 

Filter Media1 CHT2 

Copper 3.1E-01 2.8E-01 1.4E-01 

0 

TPE: 1.9E-01 1.8E-01 8.9E-02 

Iron 5.2E-01 5.0E-01 

ND 0 

TPE: 2.9E-03 2.8E-03 

Lead 1.4E-02 1.5E-02 1.5E-02 

0 

TPE: 3.1E-02 3.4E-02 3.4E-02 

Manganese 1.7E-01 1.7E-01 1.7E-01 

0 

TPE: 1.2E-02 1.2E-02 1.2E-02 

Naphthalene 

TPE: 

2.0E-02 

3.1E-04 

2.2E-02 

3.4E-04 

ND 0 

Nickel 1.7E-01 1.7E-01 1.3E-01 

0 

TPE: 1.9E-02 1.9E-02 1.4E-02 

Nitrate/Nitrite 4.5E+00 5.2E+00 3.1E+00 

0 

TPE: 4.2E-01 4.8E-01 2.9E-01 

Oil and Grease (HEM4) 

TPE: 

4.1E+01 3.3E+01 9.8E+00 

0 

Phenanthrene 1.7E-02 1.7E-02 

ND 0 

TPE: 5.1E-03 4.9E-03 

Selenium 1.1E-02 1.1E-02 1.1E-02 

0 

TPE: 1.2E-02 1.2E-02 1.2E-02 

Sulfate 7.7E+02 7.6E+02 7.6E+02 

0 

TPE: 4.3E-03 4.2E-03 4.2E-03 

Thallium 2.4E-02 1.8E-02 1.8E-02 

0 

TPE: 2.4E-02 1.8E-02 1.8E-02 

Total Sulfide 4.6E+00 4.1E+00 

ND 0 

TPE: 1.3E+01 1.1E+01 

Zinc 6.3E-01 6.9E-01 4.1E-01 

0 

TPE: 3.0E-02 3.2E-02 1.9E-02 

Total TPE Load 1.4E+01 1.3E+01 1.0E+01 0 

1 Constituent concentrations are calculated using methodology described in Putnam and Singerman (2001). 2 CHT does not release constituents to the receiving waters. 3 No TPE value is calculated for this constituent. As discussed in the EEA Guidance Manual (Navy and EPA, 2000a), 

the use of a proxy value indicated that the contribution of this constituent to the total TPE value is relatively small. 4 HEM TEC value was based on the fuel/lube TEC. For more information, see Development of TECs for Categories 

of Oily Substances Derived from Petroleum and Foods (Navy and EPA, 2001c). 

ND = Not Detected 

79 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-48. Summary of EEA for Baseline and MPCD Bilgewater Discharges from Small 

Compression Ignition Ships (65 feet or more in length and under 400 tons of displacement) 

(WPB 110 Based on LSD 41 Surrogate Data) 

Baseline 

Bilgewater 

Primary 

Treatment 

Primary Treatment 

Plus Filter Media1 CHT 

Number of Constituents exceeding 

strictest WQC 14 14 11 0 

Total Number of Exceeded Numeric 

WQC 96 93 88 0 

Number of Exceeded Narrative 

Categories 8 7 4 0 

Discharge HI at EOMZ 6.3E-02 5.8E-02 1.7E-02 0 

Potential for NIS Release Low Low Low None 

Number of BCCs Identified 7 7 5 0 

Discharge TPE (Saltwater) 1.5E+02 1.3E+02 1.4E+01 0 

Discharge TPE (Freshwater) 1.4E+01 1.3E+01 1.0E+01 0 

1 For new design consideration only. Constituent concentrations are calculated using methodology described in 

Putnam and Singerman (2001). 

In summary, the application of CHT to bilgewater has the least environmental impact because 

there is no direct discharge to the receiving water. Primary treatment is expected to result in 

fewer deleterious environmental effects than the baseline discharge. 

MPCD ranking by overall environmental effect: 

1. CHT 

2. Primary treatment plus filter media (for new design consideration only) 

3. Primary treatment only 

Further information on the environmental effects analysis for this vessel group can be found in 

the respective chapter of the Bilgewater EEAR (Navy and EPA, 2003c). 

0.0.0 WPB 110 Class Cost-Benefit Analysis 

Cost benefit analysis for this vessel group is summarized below in Table 3-49. 

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DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Table 3-49. TPEs Removed for each MCPD Option and Associated Costs (WPB 110) 

Filter Media CHT 

TPE removed from primary 

discharge by listed treatment 1.47E+02 1.90E+02 

Cost to non-USCG per TPE removed 

over primary treatment ($/yr) $0 $408 

Each new vessel $73 $24 

Cost to USCG per TPE removed 

over primary treatment ($/yr) $0 $1,923 

Each new vessel $73 $36 

0.0 SUMMARY 

Surface vessel bilgewater was identified in Phase I of the UNDS program as a discharge 

requiring control with an MPCD. The vessels that produce this discharge were sorted into 13 

vessel groups. For five of these vessel groups, a streamlined analysis was performed because 

these vessels can collect, hold, and transfer (to shore for treatment at a properly permitted 

facility) all bilgewater that otherwise would be discharged within 12 nm of shore.. The 

remaining eight vessel groups were subjected to a full analysis, including feasibility and 

environmental effects components. Four MPCD option groups were identified and screened for 

the treatment of bilgewater, including CHT, primary treatment (represented by gravity 

coalescence), filter media, and ultrafiltration. 

The feasibility analysis of the four MPCD option groups (baseline was provided for comparison) 

culminated in a cost analysis of feasible options. These various costs can be found throughout 

this report. The only options deemed too impractical for consideration were the secondary 

treatment options (filter media and ultrafiltration) for the WHEC and WPB vessel groups. 

The environmental effects analyses culminated in a ranking of MPCD options. The application 

of CHT to bilgewater has the least environmental impact because there is no direct discharge to 

the receiving water within 12 nm. The secondary treatment options generally provide bilgewater 

treatment performance that is equal or superior, for each of the analysis methods (e.g., criteria 

exceedance, HI, and TPE), to primary treatment alone. Primary treatment is expected to result in 

fewer deleterious environmental effects than the baseline discharge. 

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DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

0.0 REFERENCES 

ACEIT. 1999. ACEIT Customers. ACEIT, Automating the Estimating Environment. 

http://www.aceit.com/main/aceitcustomers.asp. Accessed 11 June 2001. 

EPA. 1991. Technical Supporting Document for Water Quality-based Toxics Control. 

U.S. Environmental Protection Agency, Office of Water, Washington, DC. 

EPA/505/2-90-001. March 1991. 

EPA and DoD. 1999. Phase I Uniform National Discharge Standards for Vessels of the Armed 

Forces: Technical Development Document. US Environmental Protection Agency, 

Office of Water, Washington, DC. EPA 821-R-99-001. 

Freeman, H.M. 1989. Standard Handbook for Hazardous Waste Treatment and Disposal. 

International Maritime Organization (IMO). Guidelines for the Implementation of Annex I of 

MARPOL 73/78. IMO, London. 1978. Revised 1992. 

Navy and EPA. 2000a. Environmental Effects Analysis Guidance for Phase II of the Uniform 

National Discharge Standards for Vessels of the Armed Forces. US Environmental 

Protection Agency, Office of Water, Washington, DC, and US Navy, Naval Sea Systems 

Command, Washington, DC. September 2000. 

Navy and EPA. 2000b. Marine Pollution Control Device Screen Criteria Guidance. US 

Environmental Protection Agency, Office of Water, Washington, DC, and US Navy, 

Naval Sea Systems Command, Washington, DC. October 2000. 

Navy and EPA. 2000c. Feasibility Impact Analysis Guidance Document for Phase II of the 

Uniform National Discharge Standards for Vessels of the Armed Forces. U.S. 

Environmental Protection Agency, Office of Water, Washington, DC, and U.S. Navy, 

Naval Sea Systems Command, Washington, DC. August 2000. 

Navy and EPA. 2001a. Vessel Grouping and Representative Vessel Class Selection for Surface 

Vessel Bilgewater/OWS Discharge. US Environmental Protection Agency, Office of 

Water, Washington, DC, and US Navy, Naval Sea Systems Command, Washington, DC. 

July 2001. 

Navy and EPA. 2001b. Technical Approach for Pierside Modeling to Support UNDS EEA 

Phase II. US Environmental Protection Agency, Office of Water, Washington, DC, and 

US Navy, Naval Sea Systems Command, Washington, DC. July 2001. 

Navy and EPA. 2001c. Development of TECs for Categories of Oily Substances Derived from 

Petroleum and Foods. U.S. Environmental Protection Agency, Office of Water, 

Washington, DC, and U.S. Navy, Naval Sea Systems Command, Washington, DC. May 

2001. 

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DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Navy and EPA. 2002a. Uniform National Discharge Standards (UNDS) New Design Analysis 

Approach. December 2002. 

Navy and EPA. 2002b. Shipboard Compliance and Pollution Prevention Programs for Armed 

Forces Vessels. 

Navy and EPA. 2003a. Characterization Analysis Report: Surface Vessel Bilgewater/OWS 

Discharge. U.S. Environmental Protection Agency, Office of Water, Washington, DC, 

and U.S. Navy, Naval Sea Systems Command, Washington, DC. March 2003. 

Navy and EPA. 2003b. Feasibility Impact Analysis Report, Surface Vessel Bilgewater/OWS 

Discharge. US Environmental Protection Agency, Office of Water, Washington, DC, and 

US Navy, Naval Sea Systems Command, Washington, DC. March 2003. 

Navy and EPA. 2003c. Environmental Effects Analysis Report: Surface Vessel 

Bilgewater/OWS Discharge. U.S. Environmental Protection Agency, Office of Water, 

Washington, DC, and U.S. Navy, Naval Sea Systems Command, Washington, DC. 

January 2003. 

Navy and EPA. 2003d. High Resolution Gas Chromatography-Mass Spectrometry Analysis of 

Bilgewater Extract Samples for Pesticides. Report to: US Navy, Naval Sea Systems 

command (Code 05M4), Washington, DC, and US Environmental Protection Agency, 

Office of Water, Washington, DC. Prepared by: Dr. Thomas G. Hartman, Center for 

Advanced Food Technology, Cook College, Rutgers University, New Brunswick, NJ. 

Navy. 1998. Sampling Episode Report - Volume II. US Navy, Naval Sea Systems Command, 

Washington, DC. March 1998. 

Navy. 2000a. Uniform National Discharge Standards Surface Vessel Bilgewater/ Oil-Water 

Separator (OWS) Discharge Sampling Episode Report -USS BONHOMME RICHARD 

(LHD 6). Naval Surface Warfare Center, Carderock Division, Philadelphia, PA. 4 

October 2000. NSWCCD-TM-63-99/241. 

Navy. 2000b. Uniform National Discharge Standards Surface Vessel Bilgewater/OWS 

Discharge Gas Turbine Water Wash, Reverse Osmosis Brine, and Seawater Cooling 

Overboard Discharge Sampling Episode Report USS MAHAN (DDG 72). Naval Surface 

Warfare Center, Carderock Division, Philadelphia, PA. 13 October 2000. NSWCCDTM-63-99/235. 

Navy. 2000c. Uniform National Discharge Standards Surface Vessel Bilgewater/ Oil-Water 

Separator (OWS) Discharge Sampling Episode Report –USS DAVID R. RAY (DD 971). 

Naval Surface Warfare Center, Carderock Division, Philadelphia, PA. 10 October 2000. 

NSWCCD-TM-63-99/233. 

83 
DRAFT - Surface Vessel Bilgewater – DAR 24 June 2003 

Navy. 2000d. Uniform National Discharge Standards Surface Vessel Bilgewater/Oil Water 

Separator (OWS) Discharge Sampling Episode Report USCGC MORGENTHAU 

(WHEC 722). Naval Surface Warfare Center, Carderock Division, Philadelphia, PA. 25 

August 2000. NSWCCD-TM-63-99/237. 

Navy. 2000e. Uniform National Discharge Standards Surface Vessel Bilgewater/OWS 

Discharge Sampling Episode Report USS OAK HILL (LSD 51). Naval Surface Warfare 

Center, Carderock Division, Philadelphia, PA. 12 October 2000. NSWCCD-TM-63-

99/236. 

Navy. 2001a. Uniform National Discharge Standards Surface Vessel Bilgewater/ Oil-Water 

Separator (OWS) Discharge Sampling Episode Report –USS CARNEY(DDG 64). Naval 

Surface Warfare Center, Carderock Division, Philadelphia, PA. 20 April 2001. 

NSWCCD-TR-63-00/261. 

Navy. 2001b. Uniform National Discharge Standards Surface Vessel Bilgewater/OWS 

Discharge Gas Turbine Water Wash, Reverse Osmosis Brine, and Seawater Cooling 

Overboard Discharge Sampling Episode Report USS RUSHMORE (LSD 47). Naval 

Surface Warfare Center, Carderock Division, Philadelphia, PA. 8 June 2001. 

NSWCCD-TR-63-00/264. 

Oil Dri Corporation of America. 2000. Company Marketing Materials [advertisement]. June 

2000. 

OMB. 1992. Circular No. A-94 Revised (Transmittal Memo No. 64). Memorandum for Heads 

of Executive Departments and Establishments. Office of Management and Budget. 

Washington, DC. 29 October 1992. 

Putnam, D.R., and H. Singerman. 2001. Treatment Capability and Shipboard Feasibility of Oily 

Waste Treatment Alternatives. Native American Consultants, Inc. Annapolis, MD. 5 

April 2001. 

84