Phase 1: Uniform National Discharge Standards for Vessels of the Armed Forces, Technical Development Document


vvEPA
           United States
           Environmental Protection
           Agency	
           Office of Water
           4303
   A
EPA 821^99-00-)
   April 1999
PHASEI
UNIFORM NATIONAL DISCHARGE
STANDARDS FOR VESSELS OF
THE ARMED FORCES

Technical Development Document

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       Technical Development Document
                       for
Phase I Uniform National Discharge Standards
                       for
          Vessels of the Armed Forces
             Naval Sea Systems Command
              U.S. Department of the Navy
                 Arlington, VA 22202

                       and

            Engineering and Analysis Division
            Office of Science and Technology
                   Office of Water
          U.S. Environmental Protection Agency
                Washington, DC 20460
                    April, 1999

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                                    FOREWORD

      This Technical Development Document was produced jointly by the Naval Sea Systems
Command of the United States Navy and the Office of Water of the United States Environmental
Protection Agency. The purpose of this document is to provide, in part, the technical background
that was used to develop the Phase I regulation that is issued under authority of the Uniform
National Discharge Standards provisions of the Clean Water Act, 33 U.S.C., 1322(n).

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                                  TABLE OF CONTENTS
EXECUTIVE SUMMARY	ES-1

CHAPTER 1. BACKGROUND OF THE UNIFORM NATIONAL
       DISCHARGE STANDARDS
1.1 Background	1_1
1.2 Legal Authority and Statutory Requirements for the UNDS Regulations	1-2
       1.2.1 Discharges	1_2
       1.2.2 Vessels	1_2
       1.2.3 Waters	;	;..•"'" 1.3
1.3 UNDS Development Requirements	1-3
1.4 References...	  1_5

CHAPTER 2. VESSELS OF THE ARMED FORCES
2.1 Introduction	2-1
2.2 Description of Vessel Classes and Types	2-2
       2.2.1 Vessels of the U.S. Navy	"".'.".'.". 2-2
         .  _2.2.1.1 Navy Mission..,.„".'...-.	:	    2-2
            2.2.1.2 Navy Vessel Description	2-2
       2.2.2 Vessels of the Military Sealift Command	„	2-5
            2.2.2.1 Military Sealift Command Mission	2-5
            2.2.2.2 Special Mission Support Force	2-6
            2.2.2.3 Naval Fleet Auxiliary Force	2-6
       2.2.3 Vessels of the U.S. Coast Guard	,	2-7
            2.2.3.1 Coast Guard Mission	2-7
            2.2.3.2 Coast Guard Vessel Description	2-7
       2.2.4 Vessels of the U.S. Army	2-10
            2.2.4.1 Army Mission	2-10
            2.2.4.2 Army Vessel Description	2-10
       2.2.5 Vessels of the U.S. Marine Corps	2-12
            2.2.5.1 Marine Corps Mission	2-12
            2.2.5.2 Marine Corps Vessel Description	2-12
       2.2.6 Vessels of the U.S. Air Force	2-12
            2.2.6.1 Air Force Mission	2-12
            2.2.6.2 Air Force Vessel Description	2-12
       2.2.7 Vessels Not Covered by UNDS	2-13
            2.2.7.1 Army Corps of Engineers Vessels	2-13
            2.2.7.2 Maritime Administration Vessels	2-13
            2.2.7.3 Vessels Preserved as Memorials and Museums	2-14
            2.2.7.4 Time- and Voyage-Chartered Vessels	2-14
            2.2.7.5 Vessels Under Construction	2-14
            2.2.7.6 Vessels in Drydock	2-14
            2.2.7.7 Amphibious Vehicles	2-14

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2.3 Locations of Armed Forces Vessels	2-15
       2.3.1 Homeports	2-15
            2.3.1.1 Navy Ports	2-15
            2.3.1.2 Coast Guard Ports	2-15
            2.3.1.3 Army Ports	2-15
            2.3.1.4 Military Sealift Command, Marine Corps, and Air Force
                     Port Usage	2-16
       2.3.2 Operation within Navigable Waters of the U.S. and the Contiguous
              Zone 	2-16
2.4 References	2-20

CHAPTERS. DATA COLLECTION
3.1 Introduction	3-1
3.2 Surveys	•	3-1
3.3 Consultations with Department of Defense Personnel Having Equipment
       Expertise	3-2
3.4 Consultation and Outreach Outside the Department of Defense	3-3
       3.4.1 Initial State Consultation Meetings	3-4
       3.4.2 Second Round of State Consultation Meetings	3-4
       3.4.3 Consultation with Environmental Organizations	3-5
       3.4.4 UNDS Newsletter and Homepage	3-5
3.5 Sampling and Analysis	3-6
       3.5.1 Approach to Identifying Discharges Requiring Sampling	3-6
       3.5.2 Approach to Determining Analytes	3-6
       3.5.3  Shipboard Sampling	3-7
       3.5.4  Quality Assurance/Quality Control and Data Validation Procedures	3-8
3.6 References	3-10

CHAPTER 4. DISCHARGE EVALUATION METHODOLOGY
4.1 Introduction	4-1
4.2 Environmental Effects Determination	4-1
       4.2.1  Chemical Constituents	4-1
       4.2.2  Thermal Pollution	4-5
       4.2.3  Bioaccumulative Chemicals of Concern	4-6
       4.2.4 Nonindigenous Species	4-7
       4.2.5  Discharge Evaluation	4-7
 4.3 Nature of Discharge Analysis	4-8
       4.3.1  Nature of Discharge Report Contents	4-9
       4.3.2 Peer Review	4-10
 4.4 MPCD Practicability, Operational Feasibility, and Cost Analysis	4-11
       4.4.1  MPCD Practicability, Operational Feasibility, and Cost Report
              Contents	4-11
 4.5 References	4-12

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CHAPTERS. PHASE I DISCHARGE DETERMINATIONS
5.1  Discharges Determined To Require MPCDs	5-1
       5.1.1  Aqueous Film-Forming Foam	5-3
       5.1.2  Catapult Water Brake Tank and Post-Launch Retraction Exhaust	5-4
       5.1.3  Chain Locker Effluent	5-5
       5.1.4  Clean Ballast	5-6
       5.1.5  Compensated Fuel Ballast	5-7
       5.1.6  Controllable Pitch Propeller Hydraulic Fluid	5-8
       5.1.7  Deck Runoff.	5-9
       5.1.8  Dirty Ballast	5-10
       5.1.9  Distillation and Reverse Osmosis Brine	5-11
       5.1.10 Elevator Pit Effluent	5-12
       5.1.11 Firemain Systems	5-13
       5.1.12 Gas Turbine Water Wash	5-14
       5.1.13 Graywater	5-14
       5.1.14 Hull Coating Leachate	5-15
       5.1.15 Motor Gasoline Compensating Discharge	5-16
       5.1.16 Non-Oily Machinery Wastewater	5-17
       5.1.17 Photographic Laboratory Drains	5-17
       5.1.18 Seawater Cooling Overboard Discharge	5-18
       5.1.19 Seawater Piping Biofouling Prevention	5-19
       5.1.20 Small Boat Engine Wet Exhaust	5-20
       5.1.21 Sonar Dome Discharge	5-20
       5.1.22 Submarine Bilgewater	5-21
       5.1.23 Surface Vessel Bilgewater/Oil-Water Separator Discharge	5-22
       5.1.24 Underwater Ship Husbandry	5-22
       5.1.25 Welldeck Discharges	5-23
5.2  Discharges Determined To Not Require MPCDs	 5-25
       5.2.1  Boiler Slowdown	5-25
       5.2.2  Catapult Wet Accumulator Discharge	5-27
       5.2.3  Cathodic Protection	,	5-28
       5.2.4  Freshwater Lay-Up	5-29
       5.2.5  Mine Countermeasures Equipment Lubrication	5-30
       5.2.6  Portable Damage Control Drain Pump Discharge	5-31
       5.2.7  Portable Damage Control Drain Pump Wet Exhaust	5-32
       5.2.8  Refrigeration /Air Conditioning Condensate	5-33
       5.2.9  Rudder Bearing Lubrication	5-33
       5.2.10 Steam Condensate	5-34
       5.2.11 Stern Tube Seals and Underwater Bearing Lubrication	5-35
       5.2.12 Submarine Acoustic Countermeasures Launcher Discharge	5-36
       5.2.13 Submarine Emergency Diesel Engine Wet Exhaust	5-37
       5.2.14 Submarine Outboard Equipment Grease and External Hydraulics	5-38
5.3  References	5.39

GLOSSARY AND ABBREVIATIONS	GL-1
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                                 LIST OF TABLES

Table ES-1 Discharges Determined To Require MPCDs	ES-2
Table ES-2 Discharges Determined To Not Require MPCDs	ES-4

Table 2-1   Armed Forces Vessels Subject to UNDS Regulations	2-1
Table 2-2   Navy Vessel Classification	2-4
Table 2-3   Military Sealift Command Vessel Classification	2-7
Table 2-4   Coast Guard Vessel Classification	2-8
Table 2-5   Army Vessel Classification	2-11
Table 2-6   Marine Corps Vessel Classification	2-12
Table 2-7   Air Force Vessel Classification	2-13

Table 3-1   Incidental Discharges from Vessels of the Armed Forces	3-3
Table 3-2   States Involved in Initial Consultation Meetings	3-4
Table 3-3   States Involved in the Second Round of Consultation Meetings	3-5
Table 3-4   Discharges Sampled During Phase I of UNDS	3-6
Table 3-5   Type of Analysis According to Discharge	3-7
Table 3-6   Discharges Sampled by Ship	3-9
Table 3-7   Analytes and Analytical Methods	3-10
Table 3-8   Classical Analytes and Methods	3-10

Table 4-1   Aquatic Life Water Quality Criteria	4-3
Table 4-2   List of Bioaccumulative Chemicals of Concern	4-7

Table 5-1   Discharges Requiring the Use of a MPCD and the Basis for the
            Determination	5-2

                                 LIST OF FIGURES

Figure 2-1  Largest Navy Surface Ship and Submarine Homeports	2-17
Figure 2-2  Coast Guard Ports with Three or More Vessels Equal to or Longer than
            65 Feet	2-18

                                   APPENDICES

Appendix A Nature of Discharge (NOD) and Marine Pollution Control Device
             (MPCD) Reports	A-l
Appendix B Matrix of Navy Vessels and Discharges	B-l
Appendix C Matrix of MSC Vessels and Discharges	C-l
Appendix D Matrix of Coast Guard Vessels and  Discharges	D-l
Appendix E Matrix of Army Vessels and Discharges	E-l
Appendix F Matrix of Marine Corps Vessels and Discharges	F-l
Appendix G Matrix of Air Force Vessels and Discharges	G-l
                                          IV

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                               EXECUTIVE SUMMARY
       This Technical Development Document provides the technical background for the Phase I
regulation that is issued under authority of the Uniform National Discharge Standards (UNDS)
provisions of the Clean Water Act (CWA).  The purpose of Phase I of UNDS is to determine
those discharges that are incidental to the normal operation of Armed Forces vessels for which it
is reasonable and practicable to require the use of a marine pollution control device (MPCD) on
at least one vessel class, type, age, or size.  An extensive data collection effort was conducted to
identify vessels  of the Armed Forces producing discharges incidental to normal operations and to
characterize those discharges. Initial requests for information were made to each branch of the
Armed Forces to obtain discharge information and to help compile a list of vessels that could be
subject to UNDS requirements. EPA and DoD identified a list of 39 types of discharges
incidental to the normal operations of vessels of the Armed Forces and evaluated them during
Phase I of UNDS. Consultations with personnel having equipment expertise were held on each
discharge to identify available data and data gaps.  Sampling data were collected from various
vessels, where needed, to supplement existing data. Concurrently, existing laws and regulations
were reviewed,  including applicable international, Federal, State, and local standards. In
addition, consultation meetings were held with interested Federal agencies, States, and
environmental organizations.

       The information collected from surveys, consultations, and discharge sampling and
analysis was used collectively to evaluate the 39 types of discharges.  Phase I decisions were
made on these discharges according to the seven factors required to be considered by §
312(n)(2)(B) of the CWA:

       •  the nature of the discharge;
       •  the environmental effects of the discharge;
       •  the practicability of using a MPCD;
       •  the effect that installing or using the MPCD has on the operation or the operational
          capability of the vessel;
       •  applicable United States law;
       •  applicable international standards; and
       •  the economic costs of installing and using the MPCD.

       The Administrator of the Environmental Protection Agency ("Administrator") and the
Secretary of Defense ("Secretary") have determined that it is reasonable and practicable to
require MPCDs on at least one vessel class, type, age, or size for 25 of the 39 discharges to
mitigate adverse impacts or the  potential for adverse impacts on the marine environment. These
discharges are listed in Table ES-1 along with a brief description of each. For these 25
discharges, assessments of the practicability, operational impact, cost, and environmental
effectiveness of potentially available MPCDs were conducted.  The Administrator and the
Secretary also have determined  that it is not reasonable and practicable to require MPCDs for the
remaining 14 discharges because these discharges exhibit a low potential to cause adverse
                                          ES-l

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impacts to the marine environment. These discharges are listed and briefly described in Table
ES-2.
Table ES-1. Discharges Determined To Require MPCDs
Discharge
Aqueous Film-Forming Foam
Catapult Water Brake Tank and
Post-Launch Retraction Exhaust
Chain Locker Effluent
Clean Ballast
Compensated Fuel Ballast
Controllable Pitch Propeller
Hydraulic Fluid
Deck Runoff
Dirty Ballast
Distillation and Reverse Osmosis
Brine
Elevator Pit Effluent
Firemain Systems
Gas Turbine Water Wash
Description
The primary fire-fighting agent used for flammable liquid fires on vessels of the Armed
Forces. It is a concentrated liquid that is mixed with seawater to form a 3% to 6%
solution which is discharged during planned maintenance, testing, system inspections,
and flight deck certifications.
Discharge from the water brake and from retracting catapults on aircraft earners during
aircraft launching operations and testing. Lubricating oil that is applied to the catapult
cylinder collects in the water brake tank during these operations and is eventually
discharged overboard. Also, expended steam and residual oil are released overboard
when the catapult is retracted between launchings and testings.
Seawater and debris that collects in the anchor chain storage locker as a result of
anchor chain washdowns, retrievals, and heavy weather. The liquid collects in a sump
and is removed by a drainage eductor powered by the shipboard firemain.
Either seawater or freshwater that is transferred into and out of dedicated tanks to
adjust a surface ship's draft and to improve stability under various operating
conditions. On submarines, seawater taken aboard into the main ballast system to
control buoyancy and into the variable ballast system to control trim, list, and to adjust
buoyancy. The discharge is generated when the ballast is no longer required and the
tanks are partially or completely emptied.
Seawater that is introduced into fuel tanks to maintain the stability of a vessel by
compensating for the weight of the expended fuel that is consumed. During refueling,
this seawater is displaced overboard.
Hydraulic oil that is released from controllable pitch propeller (CPP) systems under
three conditions: leakage through CPP seals, releases during underwater CPP repair
and maintenance, or releases from equipment used for CPP blade replacement.
Water runoff from precipitation, freshwater washdowns, and seawater that falls on the
exposed decks of a vessel such as a weather deck or flight deck. This water washes off
residues from the deck and topside equipment, can be contaminated with materials
from other deck activities, and is discharged overboard to receiving waters.
Seawater that is occasionally pumped into empty fuel tanks for the specific purpose of
improving ship stability. Before taking on seawater, fuel in the tank to be ballasted is
transferred to another fuel tank or holding tank. Dirty ballast is comprised of residual
fuel mixed with seawater. The discharge is generated when the ballast is no longer
required and the tanks are partially or completely emptied.
Seawater concentrate or "brine" that is left over by water purification systems that
generate freshwater from seawater for a variety of shipboard applications including
potable water for drinking. This "brine" is discharged overboard.
Liquid from deck runoff and elevator equipment maintenance activities that collects in
the bottom of elevator shafts. The liquid waste is either directed overboard, collected
for shore-side disposal, or processed along with bilgewater.
Seawater distributed for fire fighting and other services aboard ships. Discharges of
firemain water from normal operations occur during firemain testing, maintenance and
training activities, anchor chain washdown, and cooling of auxiliary machinery.
Wash water discharge from cleaning internal and external propulsion and auxiliary gas
turbine components.
ES-2

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Table ES-1. Discharges Determined To Require MPCDs (contd.)
Discharge
Graywater
Hull Coating Leachate
Motor Gasoline Compensating
Discharge
Non-Oily Machinery Wastewater
Photographic Laboratory Drains
Seawater Cooling Overboard
Discharge
Seawater Piping Biofouling
Prevention
Small Boat Engine Wet Exhaust
Sonar Dome Discharge
Submarine Bilgewater
Surface Vessel Bilgewater/Oil-
Water Separator Discharge
Underwater Ship Husbandry
Welldeck Discharges
Description
Wastewater from showers, galleys, laundries, deck drains, lavatories, interior deck
drains, water fountains, miscellaneous shop sinks, and similar sources.
Antifouling agents that leach into surrounding waters from hull coatings designed to
prevent corrosion and to inhibit biological growth on the hull surface.
Seawater used to compensate for expended motor gasoline (MOGAS) used to operate
equipment stored on some Navy vessels. MOGAS is stored in a compensating tank
system to which seawater is added to fuel tanks as fuel is consumed. The discharge
occurs as a result of refueling when the displaced water is discharged overboard.
Generated from the operation of distilling plants, water chillers, low- and high-pressure
air compressors, and propulsion engine jacket coolers. The discharge is captured in a
dedicated system of drip pans, funnels, and deck drains to segregate the water from
bilgewater, and is either drained directly overboard or into dedicated collection tanks
before being discharged overboard.
Shipboard photographic lab wastes from processing color and black-and-white film.
Typical wastes include spent film processing chemical developers, fixer-bath solutions,
and film rinse water.
Seawater used to cool heat exchangers, propulsion plants, and mechanical auxiliary
systems.
Anti-fouling compounds such as sodium hypochlorite introduced in seawater cooling
systems to inhibit the growth of fouling organisms on interior piping and component
surfaces.
Seawater injected into the exhaust of small boat engines for cooling and to quiet
operation. Exhaust gas constituents are entrained in the injected seawater and
discharged overboard as wet exhaust.
Some domes that house detection, navigation, and ranging equipment are filled with
freshwater and/or seawater to maintain their shape and pressure. The discharge occurs
when water from inside the dome is pumped overboard before performing maintenance
or repair on the dome and when materials leach from the dome exterior.
Sources of bilgewater include seawater accumulation, normal leakage from machinery,
and fresh water washdowns that collect in the bilge. On some submarines, oily
wastewater is separated from non-oily wastewater. The oily wastewater is held for
shore-side disposal and the non-oily wastewater is discharged overboard.
Sources include condensate from steam systems, boiler blowdowns, water fountains,
and machinery space sinks that drain to the bilge. Bilgewater is either held for shore-
side disposal or treated in an oil-water separator before being discharged overboard.
Discharge from the grooming, maintenance, and repair of hulls and hull appendages
performed while a vessel is waterbome. Underwater ship husbandry includes hull
cleaning, fiberglass repair, welding, sonar dome repair, non-destructive testing, masker
belt repairs, and painting operations.
Water and residuals from precipitation, equipment and vehicle washdowns, washing
gas turbine engines, graywater from stored landing craft, and general washdowns of
welldecks and vehicle storage areas.
                          ES-3

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Table ES-2. Discharges Determined To Not Require MPCDs
Discharge
Boiler Slowdown
Catapult Wet Accumulator
Discharge
Cathodic Protection
Freshwater Lay-Up
Mine Countenneasures Equipment
Lubrication
Portable Damage Control Drain
Pump Discharge
Portable Damage Control Drain
Pump Wet Exhaust
Refrigeration /Air Conditioning
Condensate
Rudder Bearing Lubrication
Steam Condensate
Stem Tube Seals and Underwater
Bearing Lubrication
Submarine Acoustic
Countermeasures Launcher
Discharge
Submarine Emergency Diesel
Engine Wet Exhaust
Submarine Outboard Equipment
Grease and External Hydraulics
5- '.
Description'
Water removed from the boiler system to prevent particulates, sludge, and treatment
chemical concentrations from accumulating.
Steam and water discharged from the wet accumulator tank to keep the water level in
the accumulator within operating limits. The catapult wet accumulator provides steam
to operate the catapult during aircraft launching.
Zinc, aluminum, and chlorine-produced oxidants released during the consumption of
sacrificial anodes and the operation of impressed current cathodic protection systems.
The purpose of cathodic protection is to prevent hull corrosion.
Freshwater used to fill condensers when submarine seawater cooling systems are
placed in stand-by mode, or "lay-up." While the condenser is in lay-up mode, the
water is discharged and refilled approximately every 30 days.
Lubricating grease and oil released from mine countermeasures equipment that is
towed behind vessels to locate and destroy mines.
Seawater and harbor water that is discharged by the portable damage control drain
pumps during pump maintenance, testing, and training.
Water used to quiet and cool the exhaust from gasoline- and kerosene-fueled portable
damage control drain pumps. Portable damage control drain pump wet exhaust
discharge occurs during training and monthly planned maintenance activities.
Condensate from air conditioning, refrigerated spaces, and stand-alone refrigeration
units. The condensate is collected hi drains and is either discharged directly overboard
or held in dedicated tanks before discharge.
Grease and oil used to lubricate rudder bearings. The grease and oil can be released
while the vessel is moving, when the rudder is used, or when pierside because the oil
lubricant is slightly pressurized.
Condensate from steam used to operate auxiliary systems, such as laundry facilities,
heating systems, and other shipboard systems, that drains into collection tanks and is
discharged overboard.
Lubricants used in propeller support struts and bearings that can be released to the
environment.
Water contained in the acoustic countermeasures Mk 2 launch tube after the
countermeasures device is expelled.
Water used to quiet and cool the exhaust of submarine emergency diesel engines.
These emergency diesel engines are operated for equipment checks that occur before
submarine deployment, during monthly testing, and during periodic trend analyses.
Grease applied to a submarine's outboard equipment. The grease is released to the
environment by erosion from mechanical action of seawater while the submarine is
underway and by slow dissolution of the grease into the seawater.
                         ES-4

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1. BACKGROUND OF THE UNIFORM NATIONAL DISCHARGE STANDARDS
This chapter provides background on and summarizes the requirements of the Uniform
National Discharge Standards (UNDS) legislation. Section 1.1 describes the evolution of the
UNDS legislation; section 1.2 cites the legal authority for the UNDS regulations and gives an
overview of the scope of UNDS, including key definitions; section 1.3 describes the multi-phase
UNDS development process; and section 1.4 lists the references cited in chapter 1.

1.1 Background

Armed Forces vessels produce liquid discharges that vary greatly in composition, amount,
and potential for causing adverse environmental effects. Many are common to nearly all vessels
while others are unique to specific vessel types. The composition and volume of a specific
discharge may also vary with vessel type and age, installed hardware, operating mode, external
environmental conditions, and other factors. Many discharges are discrete waste streams such as
graywater (which includes effluent from sources such as sinks, showers, and galleys) and
seawater cooling overboard discharge, while others, such as leachate from hull protective
coatings, lubricants from various external bearings and joints, and contaminants from other
external surfaces are released by direct contact with the marine environment or runoff from
precipitation.

In support of national defense and other missions assigned by the President, Armed
Forces vessels are required to operate in and visit coastal waters and ports throughout the United
States. The potential for different ship discharge requirements between local and State
jurisdictions makes it difficult for Armed Forces vessels to simultaneously ensure environmental
regulatory compliance and operational readiness. Clear, achievable, and uniform discharge
standards would enable the Armed Forces to design, build, and train their crews to operate
environmentally sound vessels and simultaneously maintain their ability to meet national defense
and other mission requirements. In addition, uniform national standards would result in
enhanced environmental protection because standards would be established for certain discharges
that presently are not comprehensively regulated. Establishing national standards for discharges
from the vessels of the Armed Forces is the purpose of the UNDS program.

In 1990, the Navy began preliminary discussions with various Federal agencies concerning the
need for uniform national standards to maintain operational flexibility while promoting
environmentally responsible ships. The U.S. Environmental Protection Agency (EPA), the Coast
Guard, the National Oceanic and Atmospheric Administration, and other agencies were
contacted. The Navy also actively solicited input from the States, recognizing that coastal States,
in particular, have a great interest in the quality of the water in and around their ports. State
briefings and discussions held before UNDS legislation was passed began in October 1993 and
continued through the winter of 1995.1 During the same period, the Navy hosted several
information sessions on UNDS with Federal and State environmental officials, environmental
interest groups, and congressional staff. As a result, legislation was drafted and sent to Congress.
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Ultimately, Congress enacted UNDS legislation as part of the 1996 Defense Authorization Bill
and the President signed the bill into law as part of the National Defense Authorization Act of
1996.

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

• enhance the operational flexibility of vessels of the Armed Forces domestically and
internationally;
• stimulate the development of innovative vessel pollution control technology; and
• advance the development by the United States Navy of environmentally sound ships.

1.2 Legal Authority and Statutory Requirements for the UNDS Regulations

Section 325 of the National Defense Authorization Act of 1996, entitled "Discharges
from Vessels of the Armed Forces" (Pub. L. 104-106,110 Stat. 254), amended § 312 and
§ 502(6) of the Federal Water Pollution Control Act (also known as the Clean Water Act or the
CWA) to require the Administrator of the EPA ("Administrator") and the Secretary of Defense
("Secretary") to develop uniform national standards to control certain discharges from vessels of
the Armed Forces.
1.2.1 Discharges

The UNDS legislation specifies that standards would apply to discharges (other than
sewage) incidental to the normal operation of vessels of the Armed Forces unless the Secretary
finds that complying with UNDS would not be in the national security interests of the United
States (CWA § 312(n)(l)). The standards would apply anytime the vessel is waterborne in inland
U.S. waters or within 12 nautical miles (n.m.) from the United States or its territories, regardless
of whether the vessel is underway or pierside (see section 1.2.3). Discharges subject to UNDS
include discharges from the operation, maintenance, repair, or testing of vessel propulsion
systems, maneuvering systems, habitability systems, or installed major systems such as elevators
or catapults, and discharges from protective, preservative, or adsorptive hull coatings. UNDS
does not apply to discharges overboard of rubbish, trash, garbage, or other such materials; air
emissions resulting from a vessel propulsion system, motor driven equipment or incinerator; or
discharges that require permitting under the National Pollutant Discharge Elimination System
(NPDES) program, Title 40 Part 122 of the Code of Federal Regulations (CFR) (see CWA §
312(a)(12)). UNDS does not apply to discharges containing source, special nuclear, or byproduct
materials. These materials are regulated under the Atomic Energy Act of 1954, as amended (42
United States Code (USC) 2011). See Train v. CIPR, Inc., 426 U.S. 1 (1976).

1.2.2 Vessels

Armed Forces vessels subject to the UNDS regulations include most watercraft or other
artificial contrivances used, or capable of being used, as a means of water transportation by the
Armed Forces. Examples of such vessels are ships, submarines, barges, tugs, floating drydocks,
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and landing craft, as well as boats of all sizes. Armed Forces vessels are any vessel owned or
operated by the Department of Defense other than time- or voyage-chartered vessels. This
includes vessels of the Navy, Army, Marine Corps, Air Force, and Military Sealift Command
(MSC). In addition, a vessel of the Armed Forces is defined as any vessel owned or operated by
the Department of Transportation (DOT) that is designated by the Secretary of the Department in
which the Coast Guard is operating as a vessel equivalent to a vessel of the DoD. The Secretary
of the DOT has determined that Coast Guard vessels are equivalent to DoD vessels and are
therefore included as vessels of the Armed Forces for the purposes of UNDS.

A vessel becomes a vessel of the Armed Forces when the government assumes overall
operational control of the vessel. Vessel discharges that occur before the government assumes
control of the vessel (e.g., vessels under construction) and those that occur during maintenance
and repair while the vessel is in drydock are addressed by the NPDES permits issued to the shore
facility or the drydock. Discharges related to a floating drydock's function as a vessel are
covered by UNDS and do not require authorization by NPDES permits.

While the majority of Armed Forces vessels are subject to UNDS, there are several
classes of vessels that are not subject to UNDS. The Armed Forces vessels that are subject to
UNDS and those vessels not subject to UNDS are discussed hi detail in chapter 2.

1.2.3 Waters

UNDS is applicable to discharges from Armed Forces vessels when they operate in the
navigable waters of the United States and the contiguous zone. As defined in § 502 of the CWA,
the term "navigable waters" means all inland waters of the United States, including the Great
Lakes, and all waters seaward from the coastline to a distance of three n.m. from the shore of the
States, District of Columbia, Commonwealth of Puerto Rico, the Virgin Islands, Guam,
American Samoa, the Canal Zone, and the Trust Territories of the Pacific Islands. The
contiguous zone extends from three n.m. to 12 n.m. from the coastline. Therefore, UNDS
applies to Armed Forces vessel discharges into inland waters and into waters from the shoreline
out to 12 n.m. of shore. UNDS is not enforceable beyond the contiguous zone.

1.3 UNDS Development Requirements

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

Phase I. The first phase of UNDS requires the Administrator and the Secretary to
determine for which Armed Forces vessel discharges it is reasonable and practicable to require
control with a marine pollution control device (MPCD) on at least one vessel class, type, age, or
size to mitigate potential adverse impacts on the marine environment (CWA § 312(n)(2)). The
UNDS legislation states that a MPCD may be a piece of equipment or a management practice
designed to control a particular discharge (CWA § 312(a)(13)). The Administrator and the
Secretary are required to consider the following seven factors when determining if a discharge
requires a MPCD:
1-3

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       •   the nature of the discharge;
       •   the environmental effects of the discharge;
       •   the practicability of using the MPCD;
       •   the effect that installing or using the MPCD has on the operation or the operational
          capability of the vessel;
       •   applicable United States laws;
       •   applicable international standards; and
       •   the economic costs of installing and using the MPCD.

       The Administrator and the Secretary are required to consult with the Secretary of the
department in which the Coast Guard is operating (i.e., DOT), the Secretary of Commerce, and
interested States during Phase I rule development. The statute provides that after promulgation
of the Phase I rule, neither States nor political subdivisions of States may adopt or enforce any
State or local statutes or regulations with respect to discharges identified as not requiring control
with a MPCD, except to  establish no-discharge zones (CWA § 312(n)(6)). A no-discharge zone
is an area of water determined by a State or the Administrator to need greater environmental
protection than that provided by UNDS. It can encompass one or more discharges that will be
prohibited from being released, either treated or untreated, into the waters of the no-discharge
zone. In addition, States and their political subdivisions will be similarly prohibited from
adopting or enforcing any statutes or regulations affecting discharges that require control with
MPCDs once "Phase m" regulations (see below) that govern the design, construction,
installation, and use of the MPCDs for those discharges are promulgated.

       When there is new, significant information not considered during the Phase I rulemaking
that could result in a change to the Phase I discharge determination, § 312(n)(5)(D) of the CWA
authorizes the Governor of any State to submit a petition to the Administrator and the Secretary
requesting them to re-evaluate whether a discharge requires control.  In addition, § 312(n)(5) of
the CWA requires the Administrator and the Secretary to review the Phase I determinations every
five years and, if necessary, revise the determinations based on significant new information.

       Phase n. The second phase of UNDS requires the Secretary and the Administrator to
promulgate Federal performance standards for each MPCD determined to be required in Phase I
(CWA § 312(n)(3)). Phase n requires that the Secretary of the department in which the Coast
Guard is operating, the Secretary of State, the Secretary of Commerce, other interested Federal
agencies, and interested States be consulted. When developing performance standards for the
MPCDs during Phase n, the Secretary and Administrator must consider the same seven factors
that were considered during Phase I (see above), and may establish standards that:

       •  distinguish between vessel class, type and size;
       •  distinguish between new and existing vessels; and
       •  provide a waiver from UNDS requirements as necessary or appropriate for particular
           classes, types, sizes, or ages of vessels.
                                            1-4

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       The performance standards developed during Phase n are to be issued two years after the
Phase I regulation is issued, and reviewed every five years in accordance with § 312(n)(5) of the
CWA.

       Phase III. The third phase of UNDS requires the Secretary, after consulting with the
Administrator and the Secretary of the department in which the Coast Guard is operating, to
establish requirements for designing, constructing, installing, and using the MPCDs identified in
Phase n (CWA § 312(n)(4)).  These requirements will be codified under the authority of the
Secretary. Phase HI is to be completed within one year after Phase n is promulgated. Following
completion of Phase IE, neither States nor political subdivisions of States may adopt or enforce
any State or local statutes or regulations with respect to discharges identified as requiring control
with a MPCD, except to establish no-discharge zones (CWA §312(n)(6)).

1.4    References

1.  Quinn, John P., Captain U.S. Navy. "Uniform National Discharge Standards for Armed
   Forces Vessels: Enhancing Operational Flexibility and Environmental Protection." Presented
   at the 22nd Environmental Symposium and Exhibition of the American Defense Preparedness
   Association. Orlando, Florida. 21 March 1996.
                                          1-5

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                       2.   VESSELS OF THE ARMED FORCES
       This chapter describes Armed Forces vessels, to which UNDS is applicable, and clarifies
which vessels do not qualify as such. Section 2.1 gives a brief overview of the vessels subject to
UNDS; section 2.2 provides a more detailed description of the different vessel types and lists the
vessel classes covered by UNDS in each branch of the Armed Forces and those not covered by
UNDS; section 2.3 discusses where these vessels operate; and references are listed in section 2.4.

2.1    Introduction

       The UNDS legislation defines vessels of the Armed Forces as any vessel owned or
operated by the DoD, other than a time or voyage chartered vessel, or any vessel owned or
operated by the Department of Transportation (DOT) that is designated by the Secretary of the
department in which the Coast Guard is operating as being equivalent to a vessel of the Armed
Forces (CWA § 312(a)(14)). The branches of the Armed Forces that own or operate vessels that
are subject to UNDS are listed in Table 2-1 along with the number of vessels as of August 1997.

             Table 2-1. Armed Forces Vessels Subject to UNDS Regulations
Branch of Armed Forces
United States Navy
United States Coast Guard
United States Marine Corps
United States Army
Military Sealift Command
United States Air Force
Branch
Abbreviation
USN
USCG
USMC
USA
MSC
USAF
Number of
Vessels
4,760
1,445
538
334
57
36
TOTAL = 7,170
       Categories of vessels that are not covered by UNDS include: commercial vessels;
privately owned vessels; vessels owned or operated by State, local, or tribal governments; vessels
under the jurisdiction of the Army Corps of Engineers; vessels, other than those of the Coast
Guard, under the jurisdiction of the Department of Transportation; vessels owned or operated by
other Federal agencies that are not part of the Armed Forces (i.e., Maritime Administration
(MARAD) vessels); vessels preserved as memorials and museums; time- and voyage-chartered
vessels; vessels under construction; vessels in drydock; and amphibious vehicles. Several
categories of these vessels are described in section 2.2.7.

       The five largest Navy ports are Norfolk, VA; San Diego, CA; Pearl Harbor, HI; Puget
Sound (Bremerton), WA; and Mayport, FL. Numerous other naval ports are located around the
country. The largest Coast Guard base is located in Portsmouth, VA; with other major bases in
California, Florida, Hawaii, Massachusetts, South Carolina, Texas, and Washington. Fort Eustis,
                                         2-1

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VA, is the primary site for the Army vessels, but the Army also ports vessels in California,
Florida, Hawaii, Maryland, North Carolina, and Washington. Military Sealift Command vessels
make use of Navy ports, as available, and commercial ports at all other times. Neither the
Marine Corps nor the Air Force has a major port. Marine Corps craft are typically stowed aboard
larger Navy vessels and maintained and stationed ashore. Air Force vessels are located in
Florida, North Carolina, Virginia, New Mexico, and Nevada. Operating locations for Armed
Forces vessels are discussed in more detail hi Section 2.3.

2.2 Description of Vessel Classes and Types

The number of specific vessel types within each branch of the Armed Forces constantly
changes due to vessel commissionings, decommissionings, and transfers within branches of the
Armed Forces. In order to maintain consistency, the Armed Forces vessel population as of
August 1997 was used in analyses supporting this rule.
.1-4
2.2.1 Vessels of the U.S. Navy

2.2.1.1 Navy Mission

The role of the U.S. Navy is to maintain an effective naval fighting force to defend the
U.S. during war, and to use this force to prevent conflicts and control crises around the world.
The Navy is responsible for organizing, training, and equipping its forces to conduct prompt and
sustained combat operations at sea. For combat, as well as humanitarian missions, the Fleet must
be capable of quick deployment, while being optimized for carrying personnel, weapons, and
supplies whenever and wherever needed.

2.2.1.2 Navy Vessel Description

There are approximately 4,800 Navy vessels (active and inactive), the majority of which
are small boats and service craft. Navy vessels can be categorized into eight groups according to
mission: aircraft carriers, surface combatants, amphibious ships, submarines, auxiliaries, mine
warfare ships, small boats and service craft, and inactive assets. Differences in vessel size,
mission, and mode of operation are explained below. Table 2-2 summarizes Navy vessel
characteristics including length, displacement, and mission for each vessel classification. A
summary of vessel-related abbreviations may be found in the Glossary and Abbreviations
section.

Aircraft Carriers. Aircraft carriers are the largest vessels in Navy service, averaging
approximately 1,100 feet long. They provide combat air support to the fleet. To accomplish this,
aircraft carriers have landing and launch platforms for fixed-wing aircraft and helicopters.
Carriers are classified as having either conventional propulsion (CV) or non-conventional
propulsion (CVN). The USS Nimitz (CVN 68) Class, is the largest class of carriers, composed
of ships that are intended to provide fleet support well into the next century. Aircraft carriers are
ocean-going vessels that typically operate within 12 n.m. only during transit in and out of port.
However, testing and maintenance activities may be conducted in port and during transits.
2-2

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Surface Combatants. Surface combatants provide air defense, ballistic missile defense,
antisubmarine warfare support, antisurface warfare support, merchant and carrier group
protection, independent patrol operations, and tactical support of land-based forces. They
include cruisers (CG and CGN), destroyers (DD and DDG), frigates (FFG), and coastal patrol
craft (PC). The Navy's surface combatants range from 171 feet long (for PCs) to 596 feet long
(for CGNs), and may have either conventional or non-conventional propulsion. Surface
combatants are ocean-going vessels that, for the most part, operate inside 12 n.m. only during
transit in and out of port and for short periods of time to meet mission requirements, such as
training. Testing and other systems maintenance activities may be done in port and during
transits.

Amphibious Ships. Amphibious ships provide a platform for vertical landing and take-
off of aircraft, primarily helicopters, and conduct launch and recovery operations of smaller
landing craft. They include command ships (LCC and AGF), assault ships (LHD, LHA, and
LPH), transport docks (LPD), and dock landing ships (LSD). Amphibious ships range from .522
to 844 feet long and use landing craft and helicopters to move Marine Corps equipment and
vehicles ashore. Amphibious ships are ocean-going vessels that operate inside 12 n.m. not only
during transit in and out of port, but also to train for and perform their designed mission as an
interface between water- and land-based operations. Testing and maintenance activities may be
performed in port and during transits.

Submarines. Submarines provide strategic missile, battlefield support, stealth strike,
special forces, littoral warfare, and other miscellaneous capabilities. They are categorized as
attack (SSN), ballistic missile (SSBN), and research and survey (AGSS) types. Navy submarines
range from 165 feet long for the research submarine to 560 feet long for ballistic missile
submarines. Nearly all submarines in active service have non-conventional propulsion, with the
exception of search and rescue types. Submarines are ocean-going vessels that operate inside 12
n.m. for transit in and out of port and to meet mission requirements, such as training. Testing
and maintenance activities may be performed in port and during transits.

Auxiliaries. Auxiliary ships provide logistical support, such as underway replenishment
of ordnance, fuel, and consumable products (AO and AOE); and rescue and salvage operations
(ARS). Submarine tenders (AS) provide maintenance facilities, weapon stores, hospital
facilities, and additional berthing space for submarines. Auxiliary vessels range in length from
255 feet to 795 feet. Auxiliaries are ocean-going vessels that typically operate inside 12 n.m. for
transit in and out of port or to meet mission requirements. Testing and maintenance activities
may be performed in port and during transits.

Mine Warfare Ships. Mine warfare ships (mine countermeasures ships (MCM) and
minehunter, coastal (MHC)) conduct minesweeping missions to find, classify, and destroy
moored and bottom mines. These vessels range in length from 188 to 224 feet long. Mine
warfare vessels primarily operate in coastal waters.
2-3

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Small Boats and Service Craft. Due to their large numbers and diverse duties, small
boats and service craft have been summarized collectively in Table 2-2. The Navy owns and
operates approximately 4,200 small boats and service craft. Small boats are used as harbor patrol
boats, transport boats, work boats (WB), and utility boats (UB). Many of the service craft are
non-self-propelled "lighters," or barges (YC, YFN, YON, and YRBM), used for berthing, office,
messing, or repair functions or to carry fuel or equipment. Other small boats and service craft
include: tugboats of various sizes (YTB, YTM, and YTL), training patrol craft (YP), landing
craft (LCU, LCM, CM, and PL), torpedo retrievers (TWR, TRB, and TR), floating drydocks
(AFDB, AFDL, AFDM, ARD, and ARDM), and rigid inflatable boats (designated RB or RIB).
Small boats are often kept out of the water when not in use to increase the vessels' longevity or
for storage while transiting to operational areas. Small boats and service craft operate within the
waters of the homeport area and other coastal locations within 12 n.m. from shore.

Inactive Assets. The Navy owns and maintains additional surface ships in various states
of readiness. These inactive assets are comprised of numerous vessel types with varying
missions and capabilities. The Navy also owns and maintains inactive submarines. The
significant majority of these inactive assets are scheduled for scrapping or other permanent
disposal. Some surface ships might be transferred to MARAD to be made part of the National
Defense Reserve Fleet, or might be destined for sale to foreign nations. However, due to the
Navy's retained ownership of these assets, pending final disposal, these vessels are covered
under UNDS. These inactive vessels are prepared for long-term storage with their systems and
equipment secured or removed and are not operated. They are moored in designated port
locations and typically not moved until final disposal.

Table 2-2. Navy Vessel Classification
Vessel Type
Aircraft
Carriers
Surface
Combatants
Amphibious
Ships
Ship Class
CV59
CV63
CVN65
CVN68
CG47
CGN36
CGN38
DD963
DDG 993
DDG51
FFG7
PCI
LCC19
AGF3
AGF11
LHD1
LHA1
Number
Active
1
3
1
7
27
2
1
31
4
18
43
13
2
1
1
4
5
Class
Length
(ft)
1,056
1,046
1,102
1,092
567
596
585
563
563
504
445
171
636
522
569
844
834
Displacement
fully loaded
(tons)
82,360
81,985
93,970
95,413
9,589
10,530
11,400
8,280
9,574
8,373
3,658
329
16,790
13,900
16,912
40,530
39,967
Mission
Provide air combat support to
the fleet with landing and
launch platform for airplanes
and helicopters
Provide air defense, missile
defense, antisubmarine and
antisurface warfare support,
merchant and earner group
protection, independent patrol
operations, and tactical
support of land-based forces
Provide a landing and take-off
platform for aircraft, primarily
helicopters, and a means for
launching and recovering
smaller landing craft
2-4

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                      Table 2-2. Navy Vessel Classification (contd.)
Vessel Type
Amphibious
Ships (contd.)
Submarines
Auxiliaries
Mine Warfare
Ships
Small Boats
and Service
Craft
Inactive Assets
Ship Class
LPD4
LPD7
LPD14
LPH2
LSD 36
LSD 41
LSD 49
SSN 671
SSN 637
SSN 688
AGSS 555
SSBN 726
AOE1
AOE6
AO177
AS 33
AS 39
ARS50
MCM1
MHCS1
YTB760
YTB756
YTB752
YTT9
YP654
YP676
Various
others
Various
surface
ships
Various
sub-
marines
T ^ *
< , *!
Number
Active
3
3
2
2
5
8
3
1
13
56
1
17
4
3
5
1
3
4
14
12
68
3
1
3
1
27
4,089
228
16
'~ Class
Length
(ft)
569
569
569
602
553
609
609
315
302
360
165
560
795
755
708
644
646
255
224
188
109
109
101
187
—
—
12-192
—
--
Displacement
fully loaded
(tons)
17,595
17,595
17,595
18,300
13,680
16,165
16,695
5,284
4,250
6,300
860
16,754
53,600
48,800
37,866
19,934
22,650
3,193
1,312
918
356
409
375
1,200
—
_
-
—
-
^ ' *
Mission

Provide strategic missile
defense, search
and rescue, and research and
survey capability
Provide logistical support,
such as underway
replenishment, material
support, and rescue and
salvage operations
Conduct minesweeping
missions to find and destroy
mines
Provide a variety of services.
Includes: patrol training craft
(YP), tug boats (YTB),
torpedo trials craft (YTT),
landing craft, barges, transport
boats, personnel boats, harbor
patrol boats, work boats, utility
boats, floating drydocks, and rigid
inflatable boats
Vessels in various states of
readiness, the majority of which
are scheduled for
scrapping, transfer to MARAD,
or sale to foreign nations.
TOTAL Vessels = 4,760
2.2.2   Vessels of the Military Sealift Command1'5'6

2.2.2.1 Military Sealift Command Mission

       The Military Sealift Command (MSC) transports DoD materials and supplies, provides
towing and salvage services, and conducts specialized missions for Federal agencies. To
                                          2-5

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accomplish this mission, the MSC maintains and operates a fleet of vessels classified within four
major maritime programs: the Special Mission Support Force (SMSF), the Naval Fleet Auxiliary
Force (NFAF), Strategic Sealift, and the Afloat Prepositioning Force (APF, which is sometimes
categorized under Strategic Sealift). Consistent with the definition of vessel of the Armed Forces
in CWA § 312(a)(14), UNDS does not apply to chartered Strategic Sealift and APF vessels.

Table 2-3 summarizes MSC vessel characteristics including length, displacement, and
mission for each vessel classification. MSC owned vessels are differentiated from Navy vessels
by the prefix, "T-" (e.g., T-AGOS and T-AGS). Although MARAD's Ready Reserve Force
(RRF) ships come under the direction of the MSC and its Strategic Sealift program when
activated, they are normally maintained and crewed by MARAD. RRF ships are discussed in
section 2.2.7.2 in conjunction with other MARAD vessels.

2.2.2.2 Special Mission Support Force

The MSC's Special Mission Support Force (SMSF) includes ships designed to support
the Navy, Air Force, and the Army in specialized military missions. SMSF vessels often operate
in remote areas to conduct undersea surveillance, missile range tracking, oceanographic and
hydrographic surveys, acoustic research, and submarine escort. SMSF vessels range from 234
feet to 595 feet long. They include the following vessel types: ocean surveillance (AGOS),
surveying (AGS), miscellaneous (AG) navigation test support and acoustic research; missile
range instrumentation (AGM), and cable repairing (ARC) vessels. The vessels are operated by
civil service mariners or mariners under contract to the MSC. SMSF vessels are ocean-going
ships that operate inside 12 n.m. during transit hi and out of port or to meet mission
requirements. Additionally, cable repairing vessels may operate frequently inside 12 n.m. for
mission purposes. Testing and maintenance activities may be conducted hi port and during
transits.

2.2.2.3 Naval Fleet Auxiliary Force

The MSC's Naval Fleet Auxiliary Force (NFAF) is comprised of auxiliary ships that
provide underway replenishment services to Navy surface combatants, in addition to ocean
towing and salvage services. By transporting and delivering fuel, food, spare parts and
equipment, and ammunition, NFAF ships enable surface combatants to remain at sea for
extended periods. NFAF vessels are between 240 feet and 677 feet in length. The NFAF vessels
are ocean-going, and typically operate inside 12 n.m. only to transit in and out of port or to meet
certain mission requirements. Testing and maintenance activities may be conducted in port and
during transits.
2-6

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Table 2-3. Military Sealift Command Vessel Classification6
MSC^ _
Maritime
Program
Classification
SMSF

NFAF

Class/Ship

T-AGOS
T-AGOS
T-AGS
T-AG
T-AGM
T-ARC

T-AE
T-AFS
T-AO
T-ATF

Number
Active

5
4
9
2
1
1

.. 8
8
12
7

Class
Length "'
(ft).

234
285
442
455
595
502

563
523
677
240

Displacement
fully loaded
(tons) ,
' *
3,438
2,558
12,208
11,860
21,478
14,225

19,937
16,792
40,700
2,260

, Mission
<•
* j
''"
Support the Armed
Forces in specialized
missions such as
undersea surveillance,
missile range tracking,
oceanographic and
hydrographic surveys,
acoustic research, and
submarine escort
Provide underway
replenishment services
(i.e., deliver fuel, food,
spare parts, equipment, and
ammunition) to Navy
surface combatants, as well
as ocean towing and salvage
services
TOTAL Vessels = 57
2.2.3 Vessels of the U.S. Coast Guard1'7'8

2.2.3.1 Coast Guard Mission

The Coast Guard is part of DOT and is responsible for enforcing laws on the waters of the
U.S., including coastal waters, oceans, lakes, and rivers that are subject to the jurisdiction of the
U.S. During war, the Coast Guard may become part of the Navy. The principal peacetime
missions of the Coast Guard are enforcing recreational boating safety, conducting search and
rescue operations, maintaining aids to navigation (e.g., lighthouses and navigational lights),
ensuring merchant marine safety (e.g., via vessel inspection and operator certification), providing
drug interdiction, and participating in environmental protection efforts. The Coast Guard also
carries out port safety responsibilities (e.g., icebreaking), enforces laws and treaties (e.g.,
customs, immigration, and fisheries law enforcement), and, ultimately, defends U.S. harbors and
coasts during war. Table 2-4 summarizes Coast Guard vessel characteristics including length,
displacement, and mission for each vessel classification.

2.2.3.2 Coast Guard Vessel Description

Cutters. Coast Guard cutters are vessels 65 feet or longer that are capable of
accommodating crew living on board. Cutters are used for patrol, air defense, search and rescue,
and drug interdiction. High endurance cutters (WHEC), medium endurance cutters (WMEC),
2-7

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



Tenders
Ship Class
Hamilton
WHEC715
Bear
WMEC901
Reliance
WMEC615
Storis
WMEC38
Escape
WMEC6
Island
WPB 1301
Point
WPB 82301
Juniper
WLB201
Balsam
WLB62
Ida Lewis
WLM
Red
WLM
White
WLM
Buckthorn
WLI
Cosmos
WLI 293
Berry
WLI
Pamlico
WLIC
Cosmos
WLIC
Anvil
WLIC
Sumac
WLR
Kankakee
WLR
Number
Active
12
13
16
1
1
49
36
2
23
2
5
4
1
1
4
4
3
7
1
3
Class
Length
(ft)
378
270
210
230
213
110
82
225
180
175
157
133
100
100
65
160
100
75
115
75
Displacement
fully loaded
(tons)
3,050
1,820
1,007
1,925
1,745
155
69
2,000
1,038
916
525
600
200
178
71
416
178
145
478
172
Mission
Provide multi-mission capability,
including patrol,
air defense, search and rescue,
and drug interdiction
Used to maintain inland, river,
coastal, and offshore
buoys and navigational aids, or
to serve as a construction
platform
                    2-8

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Table 2-4. Coast Guard Vessel Classification (contd.)
Vessel
Classification
Tenders
(contd.}:
Icebreakers
Tugboats
Small Boats and
Craft
Other Vessels
Ship Class
Gasconade
WLR
Ouachita
WLR
Polar
WAGE 10
Mackinaw
WAGE 83
Bay
WTGB
Capstan
WYTL
Various
Eagle
WIX327
Number
-Active
10
6
2
1
9
11
1,217
1
Class
Length
(ft)
75
65
399
290
140
65
22-58
295
Displacement
fully loaded
(tons)
141
143
13,190
5,320
662
72
2-32
1,784
, Mission
/
« * h

Support the winter icebreaking
efforts in order to
maintain open waterways in the
Arctic, Antarctic, and the
northern regions of the U.S.
including the Great Lakes,
Northwest, and Northeast
Provide towing and support
services (icebreaking, search
and rescue, and law
enforcement) to other vessels
Used in harbors (drug
interdiction, port security, cable
repair, harbors and inland
waters, navigation aids, illegal
dumping, search and rescue, "
etc.), in rough surf for rescue, for
inland river and lake patrol, as
transports, and for firerlghting
A sailing cutter used for training
TOTAL Vessels = 1,445
and patrol boats (WPB) have multi-mission capabilities due to features such as anti-ship missiles,
gun systems, and other weapon systems. Because of these capabilities, the cutters are
strategically stationed along the Atlantic and Pacific coasts of the U.S. The Coast Guard no
longer maintains anti-submarine warfare capability. WHECs perform patrol, air defense, and
search-and rescue operations, and can remain at sea for 30-45 days without support. This
compares to 10-30 days at sea for WMECs and 1-7 days for WPBs. The cutters range in length
from 82 feet to 378 feet. Cutters are ocean-going vessels. However, they operate inside 12 n.m.
during transit in and out of port, and during certain patrol or search and rescue missions. Testing
and maintenance activities maybe performed in port and during transits.

Tenders. Tenders are a specific type of cutter used to maintain inland, river, inshore,
coastal, and offshore buoys and navigational aids, or to serve as a construction platform in inland
waters. Coast Guard tenders range in size from 65 to 225 feet in length to accommodate
numerous and diverse tasks. Tenders are operated frequently inside 12 n.m.
2-9

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Icebreakers. Icebreakers have multi-mission capabilities and are often equipped with
hangar decks, flight decks, gun systems, and arctic or oceanographic laboratories. They primarily
support winter icebreaking efforts in order to maintain open waterways in the Arctic and
Antarctic, and the northern regions of the U.S. including the Great Lakes, Northwest (e.g.,
Alaska and Washington), and Northeast (e.g., Maine and Massachusetts). The Coast Guard
icebreakers range in length from 290 to 399 feet. Icebreakers are frequently operated inside 12
n.m.

Tugboats. Tugboats operate in various capacities, providing towing and support services
to other vessels. Icebreaking tugs (WTGB) are 140 feet long and specially designed to break
through thick ice. By joining this tug with a work barge, it can also be used to maintain aids to
navigation. Small harbor rugs (WYTL) are 65 feet long and, in addition to towing, can perform
law enforcement and search and rescue operations. They have also been used for small-scale
icebreaking, firefighting, delivering humanitarian aid, and assisting in spill containment.
Tugboats usually operate within 12 n.m. of shore; however, specific missions may require them
to operate beyond 12 n.m.

Small Boats and Craft. Small boats and craft are used for various harbor duties, rough
surf rescues, inland river and lake patrols, transporting equipment, and firefighting. Some of
these vessels can be transported by trailer and used on any inland waterway in the U.S. Due to
their numbers and diversity, small boats and craft of the Coast Guard have been summarized
collectively in Table 2-4.

Other Vessels. Coast Guard Academy cadets use the Coast Guard's training cutter
(WIX), a multi-masted sailing vessel, as a summer training vessel.

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

2.2.4.1 Army Mission

The role of the Army is to preserve the peace and security, and provide for the defense of
the U.S., territories, commonwealths, possessions, and any areas occupied by the U.S. The Army
has land and aviation combat forces, augmented, in part, by waterborne transport vessels. Army
vessels are used primarily for ship to shore transfer of equipment, cargo, and personnel.

2.2.4.2 Army Vessel Description

The Army's fleet is divided into three sections: the Transportation Corps, the Intelligence
and Security (I&S) Command, and the Corps of Engineers (COE). The COE operates survey and
construction craft, tugs, barges, and other utility craft. COE boats and craft are not covered by
UNDS as described in section 2.2.7.1.

The Army Transportation Corps operates lighterage and floating utility vessels.
Lighterage are craft used to transport equipment, cargo, and personnel between ships, from ship-
to-shore, and for operational mission support, and include logistics support vessels, landing craft,
2-10

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and modular powered causeway ferries. Floating utility craft are used to perform port terminal
operations and include ocean and harbor tugs, floating cranes, barges, and floating causeways.
Army Transportation Corps vessels operate primarily within 12 n.m., with the exception of the
LSV, LCU-2000, and the LT-28, which are ocean-going.

       Army I&S vessels are aerostat radar-equipped patrol ships operated in the Caribbean Sea
to counter illegal drug flights. The patrol ships operate within 12 n.m. during transit in and out
of port, but most often operate outside of 12 n.m. Table 2-5 summarizes Army vessel
characteristics including length, displacement, and mission for each vessel classification.
                        Table 2-5. Army Vessel Classification
                                                             4,8
Vessel
Type'
Lighterage
Floating
Utility
Patrol Ships
Vessel
Classification ,
>
LSV
LCU-2000
LCU-1600
LCM-8
CF
BC
BD
BG
BK
CHI
FB
HF
J-Boat
LT-128
LT-100
PB
Q-Boat
SLWT
ST-65
ST-45
T-Boat
Workboats
ABT
Number
" " Active
l
6
35
13
104
1
37
10
8
7
1
2
1
4
6
16
10
1
4
11
2
1
47
7
Class
Length
fft)
273
174
135
74
—
120
140
120
45
25
75
65
46
128
107
25
65
—
71
45
65
—
190-194
Displacement
fully loaded
(tons) '
4,199
1,087
390
111
—
760
1630
763
33
—
64
—
12
1,057
390
—
37
—
122
29
—
—
1500-1,900
Mission
Transport equipment, cargo,
and personnel between ships,
from ship to shore, or for
operational mission support
Perform port terminal
operations
Perform drug interdiction in the
Caribbean Sea
TOTAL Vessels = 334
                                          2-11

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2.2.5 Vessels of the U.S. Marine Corps
1,11
2.2.5.1 Marine Corps Mission

As part of the Department of the Navy and in conjunction with the other Armed Forces,
the Marine Corps develops the tactics, techniques, and equipment necessary to employ forces
onto land from the sea.

2.2.5.2 Marine Corps Vessel Description

The Marine Corps operates a large number of watercraft and amphibious craft used
during special operations. Assets that are primarily land-operated vehicles, such as the
amphibious assault vehicles (AAVs), are not included under UNDS. The watercraft consist of
inflatable combat rubber raiding craft (CRRC) and fiberglass rigid raiding craft (RRC). The
CRRCs are used for in-port, river, lake, and coastal operations, and can be transported to the
combat area by nearly all of the Navy's vessels. The RRCs are normally deployed aboard Navy
transport dock ships (i.e., LPDs) for transport to the combat area. The CRRCs and RRCs operate
exclusively in coastal waters. Table 2-6 summarizes Marine Corps vessel characteristics
including length, weight, and mission for each vessel classification.

Table 2-6. Marine Corps Vessel Classification
Vessel
Type
RRC
CRRC
TOTAL
Description
Rigid Raiding Craft
Zodiak
(replacing RRCs)
Number
Active
120
418
Class
Length (ft)
18
15
Weight
Obs)
-
265
(without
the
engine)
Mission
Perform offensive
amphibious operations
Vessels = 538
2.2.6 Vessels of the U.S. Air Force1

2.2.6.1 Air Force Mission

The U.S. Air Force defends the U.S. through control and exploitation of air and space.
The Air Force provides land and space-based air forces needed to establish air support for ground
forces in combat and the primary airlift capability for use by all of the nation's military services.
The Air Force operates vessels to support this mission.

2.2.6.2 Air Force Vessel Description

Missile retrievers (MRs) are aluminum vessels used for the location and recovery of
practice missiles. MRs range in length from 65 to 120 feet. These vessels primarily operate
within 12 n.m.
2-12

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Floating utility vessels provide logistics support for Air Force operations and include
utility boats (U), training and recovery boats (TR), and personnel boats (P) ranging in length
from 17 to 40 feet. These vessels operate almost entirely within 12 n.m. Table 2-7 summarizes
Air Force vessel characteristics including length, displacement, and mission for each vessel
classification.

Table 2-7. Air Force Vessel Classification
'Vessel
Type
Missile
Retrievers
Floating
Utility
Vessel
Classification,
MR
U
TR
P
'r.x
Number
Active
5
27
2
2
Class
Length
(ft)
65-120
17-33
21-25
22-40
v " a
Displacement
fully loaded
(tons)
90-133
—
—
—
Mission
' - 1 i *
T fi.
Locate and recover practice
missiles
Used for personnel and utility
transport, training, and repair
operations
TOTAL Vessels = 36
2.2.7 Vessels Not Covered by UNDS

UNDS applies only to Armed Forces vessels. UNDS does not apply to commercial
vessels; privately owned vessels; vessels owned or operated by State, local, or tribal
governments; or vessels owned or operated by Federal agencies that are not part of the Armed
Forces. In addition, several other categories of vessels are not covered by UNDS, including: 1)
vessels under the jurisdiction of the Army COE; 2) vessels, other than those of the Coast Guard,
under the jurisdiction of the DOT (e.g., MARAD vessels); 3) vessels preserved as memorials and
museums; 4) time- and voyage- chartered vessels; 5) vessels under construction; 6) vessels in
drydock; and 7) amphibious vehicles. These vessels are discussed below.

2.2.7.1 Army Corps of Engineers Vessels

Army Corps of Engineers vessels are typically used for civil works purposes. Congress
has consistently addressed the Army Corps of Engineers separately from other parts of the DoD
in both authorization and appropriations bills.12 The DoD and EPA do not consider that
Congress intended to apply UNDS to Army Corps of Engineers vessels. Therefore, vessels of the
Army Corps of Engineers are not covered by UNDS.

2.2.7.2 Maritime Administration Vessels

A number of vessels are operated or maintained by the Maritime Administration
(MARAD), which is a part of the DOT. As established in § 312(a)(14) of the CWA, the
definition of'Vessel of the Armed Forces" includes those DOT vessels that are designated by the
Secretary of the department in which the U.S. Coast Guard is operating (currently the DOT) as
operating as a vessel equivalent to a DoD vessel. The Secretary of Transportation has
2-13

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determined that MARAD vessels, including the National Defense Reserve Fleet, do not operate
equivalently to DoD vessels, and therefore, MARAD vessels are not covered by UNDS.13

2.2.7.3 Vessels Preserved as Memorials and Museums

Ships and submarines preserved as memorials and museums once served a military
mission. However, with the exception of one submarine, these vessels are no longer owned or
operated by the Armed Forces, and therefore, they are not vessels of the Armed Forces, and
UNDS does not apply to them. The Navy owns and operates the submarine Nautilus as a
museum; however, the vessel is stationary and its systems are not routinely operated. Therefore,
the EPA and DoD have excluded this vessel from the scope of UNDS.

2.2.7.4 Time-and Voyage-Chartered Vessels

Section 312(a)(14) of the CWA specifically excludes time- and voyage-chartered vessels
from the definition of'Vessels of the Armed Forces." Time- and voyage-chartered vessels are
vessels operating under a contract between the vessel owner and a charterer (in this case, the
Armed Forces) whereby the charterer hires the vessel for a specified time period or voyage,
respectively. Such vessels at. all times remain manned and navigated by the owner, and they are
not owned and operated by the Armed Forces. Examples of chartered vessels are those operated
by the MSC in the APF and the Strategic Sealift Program.

2.2.7.5 Vessels Under Construction

EPA and DoD do not consider a vessel under construction for the DoD or Coast Guard,
and for which the Federal government has not taken custody, to be a "vessel of the Armed
Forces." Therefore, UNDS does not apply to these vessels until the Federal government gains
custody.

2.2.7.6 Vessels in Drydock

The statutory definition of "discharge incidental to the normal operation of a vessel"
includes incidental discharges whenever the vessel is waterbome. See CWA § 312(a)(12).
UNDS does not apply to discharges from vessels while they are in drydock (either land-based or
floating) because they are not waterborne, even if the discharges would otherwise meet the
definition of a "discharge incidental to the normal operation of a vessel."

2.2.7.7 Amphibious Vehicles

EPA and DoD do not consider amphibious vehicles as vessels for the purposes of UNDS
because they are operated primarily as vehicles on land. Water use of these vehicles is of short
duration for near-shore transit to and from vessels.
2-14

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2.3 Locations of Armed Forces Vessels

2.3.1 Homeports

Homeports are the bases from which vessels perform the majority of their operations that
occur within 12 n.m. of shore, and thus give an indication of the zones where most vessel
discharges occur. The sizes and locations of Armed Forces homeports vary with the mission of
the vessels they service. Homeports provide pierside services (e.g., potable water, sewage and
trash disposal, and electrical power), supplies (e.g., repair parts, cleaning materials, and food);
and maintenance and repair functions (e.g., drydock, afloat, and shoreside services).

2.3.1.1 Navy Ports

Norfolk, VA; San Diego, CA; Mayport, FL; Puget Sound, WA; and Pearl Harbor, ffl are
the five largest Navy ports based on the number of ships serviced. In addition to these five ports,
the Navy has many comparably sized and smaller ports throughout the U.S. UNDS evaluations
pertain to all U.S. ports, and are not limited to those mentioned above. Figure 2-1 shows the
location of homeports for Navy surface ships and submarines only, and the approximate vessel
distribution. Inactive vessels and vessels ported outside of the U.S. (e.g., in Japan or Bahrain) are
not shown, nor is the distribution of small boats and craft. Small boats and craft are widely
distributed with heavy concentrations near San Diego and Norfolk.

2.3.1.2 Coast Guard Ports

Coast Guard duty stations are found on coastal waters, as well as on rivers, lakes, and
other inland waterways throughout the U.S. Figure 2-2 shows the Coast Guard homeport
locations having three or more vessels that are 65 feet or greater in length. Using the number of
large vessels as an indication of base size, the largest Coast Guard bases are located in
Portsmouth, VA; Honolulu, HI; Boston, MA; Charleston, SC; Alameda, CA; Galveston, TX;
Seattle, WA; and St. Petersburg, FL. Some of the mid-sized bases are located in Corpus Christi,
TX; Key West, FL; Roosevelt Roads, PR; and Miami Beach, FL. There is a ship repair and
overhaul facility in Baltimore, MD. Ship repair and overhaul is usually done at a commercial
facility near the homeport of the vessel.

2.3.1.3 Army Ports

The Army has one major active-component port facility at Fort Eustis near Newport
News, VA. In addition, smaller active and reserve-component port facilities are located in
Accotink, VA; Baltimore, MD; Cieba, PR; Edgewood, MD; Ford Island, HI; Morehead City,
NC; Oakland, CA; Palakta, FL; St. Petersburg, FL; Stockton, CA; Tacoma, WA; and Virginia
Beach, VA. Repair, overhaul, and planned maintenance is performed at commercial shipyards
located near the homeport of the vessel.
2-15

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

The Military Sealift Command makes use of Navy ports, as available, and commercial
ports at all other times. The Marine Corps and Air Force make use of local port facilities, since
they operate no major port facilities of theu: own. Air Force floating utility vessel locations
include Alamogordo, NM; Cape Canaveral, FL; Fayetteville, NC; Goldsboro, NC; Langley, VA;
Las Vegas, NV; Melbourne, FL; and Pensacola, FL. Air Force missile retrievers are located at
Panama City, FL; Key West, FL; and Carrabelle, FL.

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

UNDS applies to discharges from Armed Forces vessels in the navigable waters of the
U.S. and the contiguous zone. As defined hi the CWA (§ 502(7)), the term "navigable waters"
means waters of the U.S., including the Great Lakes, and includes waters seaward from the
coastline to a distance of 3 nautical miles from the shore of the States, District of Columbia,
Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, the Canal Zone, and
the Trust Territories of the Pacific Islands. The contiguous zone extends from 3 nautical miles to
12 nautical miles from the coastline. Discharges that occur within this zone that extends 12 n.m.
from shore are addressed in following chapters. UNDS is not enforceable beyond the contiguous
zone.

The amount of time each vessel spends in its homeport varies based on factors such as
vessel class, command, assignment/demand, and budget. For the purposes of UNDS, the DoD
estimated the amount of time spent each year in waters subject to UNDS requirements for each
vessel type, as discussed below.

Ocean-going vessels operate inside 12 n.m. while transiting in and out of port.
Periodically, they may also be used for mission or training exercises within this zone. Service
craft and small boats operate far more frequently near the homeport and within 12 n.m. These
vessels may be stowed aboard ships while in transit to operational areas. When in port, small
boats and craft are often removed from the water until the next required use.

The DoD and EPA used five years of Navy, Coast Guard, and MSC vessel movement
data to support the estimation of time spent within 12 n.m..14 From this operational data, the
average number of port entries, port exits, and days spent in port was determined for most vessel
classes.

The DoD data on ship movement was originally organized as a series of trips from one
point to another for each ship. Each record contained a succeeding trip leg. For example, if a
ship went from Norfolk to Mayport, it may have been reported as a single trip with the date and
time of departure from Norfolk recorded as the departure, and the date and time it arrived in
Mayport as the arrival. It may also have been reported as a series of trips from Norfolk to some
latitude/longitude pair in the Atlantic, from that latitude/longitude to another, from the second
latitude/longitude to a third, etc., with the last entry being a trip from the last latitude/longitude to
2-16

-------




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Mayport. Each of the legs of the journey was recorded as a separate record. All of one ship's
trips for the given year (1991,1992,1993,1994, or 1995) were recorded in succession, before
going on to the next ship. Since the records were in order, it was obvious if there were missing
entries in the data. A missing entry consisted of a ship arriving at a location in one record, and
then departing from a different location in the next record.

The first step was to translate the data from the format received into a format that was
usable for the purposes of UNDS. For the purposes of UNDS, it was more useful to know when
the ship arrived at and departed from a specific location (i.e., a U.S. port), as opposed to looking
at individual trip legs. Therefore, the DoD created a simplified database that was obtained by
taking the arrival location and time from one record, and the departure time and location from the
next. At this point, the data was filtered to exclude data where the location began with a
latitude/longitude pair, and where the arrival location and departure location were not the same
(i.e., a missing entry).

The UNDS program only used the ship/year data from ships where complete data was
available for the entire year. If there was a complete record of where that ship was for the entire
year, the number of days that that ship spent in U.S. ports that year, and the number of times it
transited into and out of any U.S. port that year were recorded. The number of transits and days
in port were totaled for every ship in the class, and that total was divided by the number of ship-
years compiled in order to derive averages for that ship class. These final numbers can be
interpreted as the number of transits into and out of U.S. ports and the number of days spent in
U.S. ports for a typical ship of that class.

These numbers vary widely between ship classes due to differing missions, operational
schedules, maintenance, etc.. For instance, a typical DDG 51 Class destroyer averages 101 days
per year in port with 11 transits in and out, compared to a typical ARS 50 Class salvage ship
which may spend an average of 208 days per year in port with 22 transits. The number of days
spent in port and the number of transits per year can vary significantly for the same vessel in
different years due to varying operational and maintenance schedules. For example, the aircraft
carrier CVN 68 spent 10 days in port with two transits in 1995, compared to 237 days in port and
nine transits in 1992. For non-self-propelled vessels (e.g., barges, cranes, and dry dock
companion craft) or harbor-oriented vessels (e.g., harbor utility craft, dredges, and harbor tugs), it
was assumed that the vessels operate within 12 n.m. from shore for the entire year.

By multiplying these typical numbers of days in port and number of transits by the
number of ships in that ship class in service in any given year, a reasonable approximation of the
total number of days spent in U.S. ports and the total number of transits into and out of U.S. ports
for all ships in that class during the year in question was calculated. These values were then used
in combination with pollutant concentration data to calculate mass loadings for vessel discharges.

Based on Navy and Coast Guard operational experience, four hours are typically required
for each one-way transit between port and 12 n.m. (The estimated vessel transit time from shore
to 3 n.m. is approximately 2-3 hours for most locations. A vessel typically requires one
additional hour in order to traverse to 12 n.m. from 3 n.m.) Significantly longer transits, such as
2-19

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11 hours to travel 12 num. offshore from Puget Sound can occur, but are atypical.  Ten hours may
be required hi Puget Sound to travel 3 n.m. from the overall shoreline because the port is located
in an inlet at the southern end of the Sound, requiring travel through both the Sound and the
Straits of Juan de Fuca. This creates a transit distance that is actually greater than 3 n.m. when
measured from the port itself.

2.4    References

1. UNDS Vessel Database. August 1997.
2. Polmar, Norman. The Naval Institute Guide to the Ships and Aircraft of the U.S. Fleet, 16{
   ed. Annapolis: Naval Institute Press. 1997.
3. Prezelin, Bernard (Ed.). The Naval Institute Guide to Combat Fleets of the World.
   Compiled by A.D. Baker m. U.S. Annapolis: Naval Institute Press.  1995.
4. Naval Sea Systems Command. Data Book for Boats and Craft of the  United States Navy,
   NAVSEA 0900-LP-084-3010, Revision A.  15 May 1988.
5. Commander, Military Sealift Command.  "Force Inventory."  Report #3110-4. Publication
   4.  1 June 1996.
6. Military Sealift Command. "Mission Service to Customers, MSC's Five Programs."  1997.
7. Saunders, N. T. (U.S. Coast Guard, Assistant Commandant for Operations). "Register of
   Cutters of the U.S. Coast Guard." COMDTINST M5441.5L. 18 November 1996.
8. Schema, Robert L. U.S. Coast Guard Cutters & Craft 1946-1990. Annapolis: Naval Institute
   Press. 1990.
9. Brown, Daniel G. (U.S. Army, Chief of Transportation). Army Watercraft Master Plan.
   November 1996.
10. United States Army, Office of the Chief of Transportation (OCOT). "Marine Qualification
   Division."  10 June 1996.
11. Halberstadt, Hans. U.S. Naw Seals in Action. Motorbooks International. 1995.
12. Fatz, Raymond J. (Department of the Army, Deputy Assistant Secretary; Environment, Safety
   and Occupational Health).  Memorandum through Deputy Assistant Secretary of the Navy
   (Environment & Safety). "Status of Army Actions on the Uniform National Discharge
   Standards." 19 May 1997.
13. Delpercio, M. Jr. (Department of Transportation, MARAD, Office of Ship Operations).
   Letter to Capt. J. W. Taylor (U.S. Navy, CNO N45) regarding applicability of UNDS to the
   Maritime Administration's National Defense Reserve Fleet.  27 March 1997.
14. Pentagon.  "USN, USCG, and MSC Vessel Movement Data from 1991-1995.
                                         2-20

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                              3.  DATA COLLECTION
       This chapter describes the efforts that were made to obtain information on the UNDS
discharges. An overview of the information collection effort is presented in section 3.1; the
surveys issued to gather discharge information are described in section 3.2 along with the list of
incidental discharges from Armed Forces vessels that resulted; the consultations with personnel
having discharge expertise to review information and identify data gaps are described in section
3.3;  section 3.4 describes the consultation and outreach efforts with organizations outside DoD;
section 3.5 discusses the approach to discharge sampling and analysis; and section 3.6 lists the
references cited in Chapter 3.

3.1    Introduction

       Section 312(n)(2)(B) of the CWA lists seven factors to consider when determining if a
vessel discharge should be controlled by a MPCD (see section 1.3). One of these factors is the
"nature of the discharge." To comprehensively consider this factor  as well as the other six
factors, EPA and DoD jointly established an UNDS Technical Working Group (TWO) composed
of representatives from EPA and the Armed Forces.  The TWG gathered and analyzed technical
data to identify:  1) the universe of Armed Forces vessels subject to UNDS requirements
(described in chapter 2); 2) the characteristics of the vessel discharges, including sources,
frequencies, amounts, and specific constituents;  3) relevant U.S. laws, regulations, and
international standards that limit or otherwise set standards on the amount of contamination
allowed in the discharges; and 4) any controls that are currently in place.

       Initial requests were made to each branch of the Armed Forces for discharge information
and for information that would allow a list of vessels subject to UNDS requirements to be
compiled. Personnel within and outside DoD with specific discharge expertise were consulted to
help identify additional available data and data gaps. Where needed, sampling data were
collected from various Armed Forces vessels to  supplement existing data. The methods that
were used to collect discharge information are discussed in the following sections.

3.2    Surveys

       Survey questionnaires were issued in 1996 by the Navy to obtain information about
vessel discharges and to provide a broad basis for subsequent technical efforts.  As part of these
surveys, a memorandum was distributed to the Navy's technical community, including Navy fleet
commands, subcommands, shore installations, and shipboard operators; other branches of the
Armed Forces; and to all other organizations that are represented on the TWG.1 The
memorandum provided background on the UNDS development effort, an explanation of the
UNDS scope and approach, and two enclosures. The first enclosure was a report entitled U.S.
Navy Ship Wastewater Discharges,2 which provided those surveyed with findings from previous
Navy-sponsored efforts on vessel wastewater identification, characterization,  and quantification.
The second enclosure was a survey entitled Equipment/System Discharge Stream Questionnaire.3
This questionnaire sought information about vessel discharges such as: system description, how
                                           3-1

-------
the discharge is generated and released (if applicable), time and location of the discharge,
discharge volume, discharge constituents and their concentrations, contributing vessel classes
and number of vessels, applicable regulations, currently employed control devices and/or
management practices, and any reports or documentation available that were pertinent to the
system or the discharge.  Survey recipients were requested to review the report, provide
comments on its contents, and respond to the questionnaire.

       In addition to information from the surveys, information was also obtained during pre-
sampling "ship checks" (i.e., vessel inspections) and during other scheduled visits to vessels.
During these checks and visits, additional information was often obtained by directly observing
discharges and by talking with the ship's crew.

3.3    Consultations with Department of Defense Personnel Having Equipment Expertise

       The survey responses helped identify incidental vessel discharges and their
characteristics. However, the survey responses did not, in all cases, provide sufficient
understanding of the discharges to make well-supported Phase I decisions.  Therefore, the Navy
and EPA met with vessel discharge experts from the government and the private sector (as
consultants to the Navy), including engineers, field-activity representatives, and Navy laboratory
personnel.  The objective of these consultations was to obtain information that was not obtained
from the survey responses,  such as:

       •  system equipment design, operation, and maintenance practices;
       •  discharge volume and composition;
       •  the numbers and types of vessels producing the discharge; and
       •  existing engineering and environmental analysis reports for the discharge including
          available sampling data.
       In addition, these meetings provided information beyond the scope of the surveys, such
as:
       •  potential MPCD options for controlling the discharge;
       •  ongoing research and development efforts; and
       •  information useful for assessing the practicability of implementing various MPCD
          options.

       The information that was gathered during the numerous consultations on large-vessel
 systems (i.e., ships and submarines) was supplemented with information on discharges from
 small Navy watercraft during a meeting with the Navy's small boat group in Norfolk, Virginia.
 Meetings were also held with Army representatives from the U.S. Army Tank-Automotive and
 Armaments Command (TACOM) in Warren, Michigan and from the 7th Transportation Group at
 Fort Eustis, VA to review Army watercraft systems, operations, and discharges.
                                          3-2

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       After the survey responses and information obtained during ship checks were analyzed,
DoD and EPA developed a list of 39 types of discharges incidental to the normal operation of
Armed Forces vessels. These discharges are listed in Table 3-1.

           Table 3-1.  Incidental Discharges from Vessels of the Armed Forces
       Aqueous Film-Forming Foam
       Boiler Slowdown
       Catapult Water Brake Tank and Post-
       Launch Retraction Exhaust
       Catapult Wet Accumulator Discharge
       Cathodic Protection
       Chain Locker Effluent
       Clean Ballast
       Compensated Fuel Ballast
       Controllable Pitch Propeller Hydraulic
       Fluid
       Deck Runoff
       Dirty Ballast
       Distillation and Reverse Osmosis Brine
       Elevator Pit Effluent
       Gas Turbine Water Wash
       Graywater
       Hull Coating Leachate
       Firemain Systems
       Freshwater Lay-Up
       Mine Countermeasures Equipment
       Lubrication
       Motor Gasoline Compensating
       Discharge
       Non-Oily Machinery Wastewater
Photographic Laboratory Drains
Portable Damage Control Drain Pump
Discharge
Portable Damage Control Drain Pump
Wet Exhaust
Refrigeration/Air Conditioning
Condensate
Rudder Bearing Lubrication
Seawater Cooling Overboard Discharge
Seawater Piping Biofouling Prevention
Small Boat Engine Wet Exhaust
Sonar Dome Discharge
Steam Condensate
Stern Tube Seals and Underwater
Bearing Lubrication
Submarine Acoustic Countermeasures
Launcher Discharge
Submarine Bilgewater
Submarine Emergency Diesel Engine
Wet Exhaust
Submarine Outboard Equipment Grease
and External Hydraulics
Surface Vessel Bilgewater/Oil-Water
Separator Discharge
Underwater Ship Husbandry
Welldeck Discharges
3.4    Consultation and Outreach Outside the Department of Defense

       During Phase I of UNDS, DoD and EPA consulted with other interested Federal agencies,
States, and environmental organizations. Other Federal agencies that have been involved in
UNDS development include the Coast Guard for DOT; the Department of State; and the National
Oceanic and Atmospheric Administration for the Department of Commerce. The Coast Guard
has been involved in all aspects of UNDS development.  The other agencies have participated
with DoD, EPA, and the Coast Guard as members of the UNDS Executive Steering Committee
                                        3-3

-------
(ESC), which is responsible for UNDS policy development and is composed of senior-level
managers. Separately, DoD and EPA provided an overview of the Phase I process and results to
the U.S. Fish and Wildlife Service and the National Marine Fisheries Service.

Two mechanisms were used to consult with States. First, a representative from the
Environmental Council of the States (ECOS) participates in UNDS ESC meetings. ECOS is the
national association of State and territorial environmental commissioners and was established, in
part, to provide State positions on environmental issues to EPA. Second, representatives from
the Navy (as the lead for DoD), EPA, and the Coast Guard met at least once, and in most cases
twice, with each State interested in UNDS development. The states agreeing to these meetings
were predominantly those with significant numbers of Navy or Coast Guard vessels.

3.4.1 Initial State Consultation Meetings

In early 1996, the Navy and EPA invited States with a DoD or Coast Guard vessel
presence to participate in an initial round of consultation meetings. Of the approximately 40
States invited, 21 requested a meeting. These initial State consultation meetings were held
between August and December 1996. State environmental regulatory authorities hosted each
meeting, which consisted of a Navy/EPA briefing on UNDS activities and an opportunity to
discuss State-specific issues. A Coast Guard representative was present at each meeting to
address discharges from Coast Guard vessels. The Navy/EPA briefing summarized the UNDS
legislative history and requirements, considerations for evaluating discharges, the technical
approach for determining which discharges require control, an overview of the vessels to which
UNDS is applicable, and the roles of DoD and EPA in the rulemaking process. The States that
participated in the first round of State meetings are listed in Table 3-2. The minutes from these
meetings are compiled hi the Uniform National Discharge Standards State Consultation
Meetings (Round #1) Compendium of Minutes.4

Table 3-2. States Involved in Initial Consultation Meetings
• Alaska
• California
• Connecticut
• Delaware
• Florida
• Georgia
• Hawaii
• Illinois
• Indiana
• Kentucky
• Louisiana
• Maryland
• Michigan
• Mississippi
• Nevada
• New York
• North Carolina
• Rhode Island
• South Carolina
• Virginia
• Washington
3.4.2 Second Round of State Consultation Meetings

The Navy and EPA held a second round of State consultation meetings from October
1997 through January 1998. Of the 22 States consulted during the second round of meetings,
five had not been briefed initially. The second round of consultation meetings provided Navy
3-4

-------
and EPA an opportunity to summarize the activities that had taken place since the initial round of
consultation meetings. This included discussing the 39 types of vessel discharges that were
identified and the preliminary decisions regarding which of the discharges would be proposed to
require control.  States were given information on the equipment or process generating the
discharges, the locations where the discharges occur, vessels producing the discharges, the
preliminary results of environmental effects screenings, and the preliminary conclusions of
whether MPCDs would be required. States were generally supportive of the UNDS effort.
States most commonly expressed interest in matters related to the implementation of UNDS
regulations, including enforcement and procedures for establishing no-discharge zones; the
relationship between UNDS and other State programs; which vessels are subject to UNDS; and
potential MPCD options.  States that participated in the second round of consultation meetings
are identified in Table 3-3. The minutes from these meetings are compiled in the Uniform
National Discharge Standards State Consultation Meetings (Round #2) Compendium of
Minutes.
        Table 3-3. States Involved in the Second Round of Consultation Meetings
• Alaska
• California
• Connecticut
• Florida
• Georgia
• Hawaii
• Indiana
• Kentucky
• Louisiana
• Maryland
• Massachusetts
• Michigan
• Mississippi
• New Hampshire
• New Jersey
• New York
• North Carolina
• Oregon
• Rhode Island
• Texas
• Virginia
• Washington


       Separately, city representatives from Portland, OR requested a briefing on UNDS
activities. In February 1998, the Navy, EPA, and Coast Guard provided an overview of UNDS to
city representatives. This meeting is summarized in the Uniform National Discharge Standards
State Consultation Meetings (Round #2) Compendium of Minutes.5

3.4.3  Consultation with Environmental Organizations

       In addition to State meetings, the Navy, EPA, and Coast Guard met with environmental
organizations to provide an overview of UNDS and the preliminary results of the first phase of
the UNDS regulatory development process. These meetings were held in December 1997 and
May 1998 and are summarized in the Uniform National Discharge Standards State Consultation
Meetings (Round #2) Compendium of Minutes?

3.4.4  UNDS Newsletter and Homepage

       To provide a continuous source of information on UNDS and as a way to receive
information relative to UNDS, the Navy and EPA publish a newsletter and an Internet web site.
                                          3-5

-------
The newsletter contains feature articles on UNDS-related subjects (e.g., nonindigenous species,
Navy research and development programs, etc.), provides answers to frequently asked questions,
and provides an update on recent progress and upcoming events. The newsletter is mailed to
State and environmental group representatives, Armed Forces and EPA contacts, and interested
members of the general public. Approximately 360 newsletters are distributed, approximately
200 of which are distributed outside the EPA, DoD, and their contractor's organizations.
Electronic copies of the newsletter are available for downloading from the UNDS Internet site
(http://206.5-146.100/n45/doc/imds/unds.html). In addition to providing an electronic version of
the newsletter, the Internet site provides UNDS legislative information, a summary of the
technical and management approach to used to develop the rule, and a description of the benefits
expected to result from UNDS. Both the newsletter and the Internet site provide points of
contact for obtaining information on UNDS.

3.5    Sampling and Analysis

3.5.1  Approach to Identifying Discharges Requiring Sampling

       The available information for each discharge was evaluated to determine if additional
data were necessary to adequately evaluate potential environmental  effects.  Sampling was not
required for discharges where existing information was sufficient to characterize the nature of the
discharge and to  assess potential environmental impacts, if any.  Nine of the 39 types of
discharges required additional information and were sampled.6'7 Table 3-4 lists these discharges.

                Table 3-4. Discharges Sampled During Phase  1 of UNDS
       Boiler Blowdown
       Compensating Fuel Ballast
       Distillation and Reverse Osmosis Brine
       Firemain Systems
       Freshwater Lay-Up
Non-Oily Machinery Wastewater
Seawater Cooling Overboard Discharge
Steam Condensate
Surface Vessel Bilgewater/Oil-Water
Separator Discharge
 3.5.2  Approach to Determining Analytes

       To determine which constituents to analyze for in the nine sampled discharges, a
 comprehensive list of approximately 450 candidate analytes was considered, including the
 "priority pollutants" referenced in § 307(a) of the CWA.  Analyses for constituents or analytical
 groups were not performed if it was evident that these constituents or groups could not be present
 based on process knowledge. A sampling rationale document was prepared to describe the
 reasons for excluding analytes from analysis on a discharge-by-discharge basis.6'7  Table 3-5
 shows the categories of analytes that were analyzed in each of the nine sampled discharges.
                                           3-6

-------
                       Table 3-5. Type of Analysis According to Discharge
Discharge
Boiler Blowdown
Compensated Fuel
Ballast
Distillation and Reverse
Osmosis Brine
Firemain Systems
Freshwater Lay-Up
Non-Oily Machinery
Wastewater
Seawater Cooling
Overboard Discharge
Steam Condensate
Surface Vessel
Bilgewater/ Oil Water
Separator Discharge
Classicals
X
X
X
X
X
X
X
X
X
VOCs

X



X


X
SVOCs
X
X
X
X
X
X
X
X
X
Metals
X
X
X
X
X
X
X
X
X
Pesticides








X
PCBs
X


X
X
X
X

X
Mercury"

X



X


X
Hydrazine
X
X






X
Notes:
x = constituents analyzed for, but not necessarily detected.
Classicals: Includes analytes such as total dissolved solids (TDS) and total suspended solids (TSS), as well as other
   classical analytes listed in Table 3-8.
PCBs: polychlorinated biphenyls
VOCs: volatile organic compounds
SVOCs: semi-volatile organic compounds

3.5.3  Shipboard Sampling

       For the purpose of UNDS Phase I, samples were collected from ten vessels representing a
total of six Navy, Coast Guard, and MSC vessel types.  The Navy vessels that were sampled
included an aircraft carrier, three surface combatants, two amphibious ships, and a submarine. A
Coast Guard cutter and two MSC oilers, which are Naval Fleet Auxiliary Support Force vessels
used for fuel transport, were also sampled. The discharges that were sampled on each vessel are
presented in Table 3-6.  The reasoning for sampling specific discharges on certain vessel classes
is contained in the sampling rationale document.6'7 In addition, the sampling procedures for eight
of the ten vessels are presented in sampling and analysis plans (SSAP) prepared for each
vessel.8"15 SSAPs were not prepared for the USS Mitscher or the USNS Big Home because they
                                            3-7

-------
are the same class of vessel as the USSArleigh Burke and the USNS Laramie, respectively.
Therefore, the SSAPs for the USSArleigh Burke and the USNS Laramie were used when
sampling the USS Mitscher and the USNS Big Home, respectively. The details of each sampling
event are documented in a separate volume of the UNDS Phase I Sampling Episode Report,
which contains the sampling analytical results and discusses any deviations from the SSAPs.16
The laboratory methods used to analyze the samples are listed in Tables 3-7 and 3-8.

3.5.4 Quality Assurance/Quality Control and Data Validation Procedures

EPA-approved quality assurance/quality control (QA/QC) and data validation procedures
were used throughout the sample collection and sample analysis activities during Phase I of
UNDS. The field and analytical QA/QC procedures are described in detail in SSAPs8"15 and the
UNDS Phase I Sampling Episode Report.16 During sample collection in the field, trip and
equipment blanks were collected as well as field duplicate samples. Analytical QA/QC included
analysis of blanks, matrix spikes, and samples. The analyses followed the QA/QC requirements
specified in the analytical methods listed in Tables 3-7 and 3-8.

In addition, the analytical results were validated according to standard EPA procedures.
The purpose of the data validation was to detect and then verify any data values that may not
reflect actual sample constituents and concentrations. The data validation step was conducted to
identify data errors, biases, and outlying data so that such values would not be used when making
Phase I decisions.
3-8

-------
 a,

2
VI

 E?
 05
JS
 u
 09
vo

rn

 
1
P
g

X












vater Lay-Up
§




X



X
X
X



)ily Machinery
water
ll
X



X

X

X
X
X


J
ter Cooling Ovei
irge
3-|
CO P
X



X


X
X





Condensate
i
CO










X

(D
tt3 O
•S .£2
e Vessel Bilgew
ater Separator D
te
co 0

-------
                        Table 3-7. Analytes and Analytical Methods
Target Analytes
Classicals
Volatile Organic Compounds (VOC)
Semi-Volatile Organic Compounds (SVOC)
Metals
Pesticides, Polychlorinated Biphenyls (PCBs)
Mercury
Hydrazine
Analytical Method
see Table 3-8
EPA Method 1624
EPA Method 1625
EPA Method 1620
EPA Method 1656, 1657, 1658, 1660
EPA Method 1631
American Society for Testing and Materials (ASTM)
D1385-88
                      Table 3-8. Classical Analytes and Methods
Target Chemical/Analytfr
Ammonia as Nitrogen (NH3 - N)
Total Kfeldahl Nitrogen (TKN)
Nitrate/Nitrite (NO2/NO3)
Total Phosphorus
Total Suspended Solids (TSS)
Biochemical Oxygen Demand (BODS)
Total Organic Carbon (TOC)
Chemical Oxygen Demand (COD)
Total Dissolved Solids (TDS)
Total Volatile Solids (TVS)
Total Petroleum Hydrocarbons (TPH)
Oil and Grease
Cyanide
Chlorine
Alkalinity
Sulfate
Sulfide
Chloride
Analytical Method
EPA 350
EPA 351
EPA 353
EPA 365
EPA 160.2
EPA 405.1
EPA 415.1
EPA 410.4
EPA 160.1
EPA 160.4
EPA 1664
EPA 1664/
modified EPA 418.2
EPA 335
DPD* 17
EPA 3 10
EPA 375
EPA 376
EPA 325.1
                    Notes:
                    * DPD: N,N-diethyl-p-phenylene diamine
3.6    References
1. NAVSEA letter 5090, Set OOT/136. 1 July 1996.
2. Ships Environmental Support Office (SESO) Naval Surface Warfare Center Carderock
   Division.  "U.S. Navy Ship Wastewater Discharges," TM-63-95/08. 3 July 1995.
                                         3-10

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3.  NAVSEA. Equipment/System Discharge Stream Questionnaire.
4.  U.S. Navy/U.S. EPA. "Uniform National Discharge Standards (UNDS) State Consultation
   Meetings (Round #1) Compendium of Minutes."
5.  U.S. Navy/U.S. EPA. "Uniform National Discharge Standards (UNDS) State Consultation
   Meetings (Round #2) Compendium of Minutes."
6.  NAVSEA. "Uniform National Discharge Standards Rationale for Initial Discharge
   Sampling." December 1997.
7.  NAVSEA. Memorandum to File.  Subject: Explanation of Deviations from the Phase I
   "Rationale for Discharge Sampling" Document. 21 July 1998.
8.  NAVSEA. "Specific Sampling and Analysis Plan," USS Stennis (CVN). July 1997.
9.  NAVSEA. "Specific Sampling and Analysis Plan," USS Arleigh Burke (DDG). July 1997.
10. NAVSEA. "Specific Sampling and Analysis Plan," USS Anzio (CGN). July 1997.
11. NAVSEA. "Specific Sampling and Analysis Plan," USCG Dallas (WHEC). July 1997.
12. NAVSEA. "Specific Sampling and Analysis Plan," USS Oak Hill (LSD). July 1997.
13. NAVSEA. "Specific Sampling and Analysis Plan," USS Scranton (SSN). July 1997.
14. NAVSEA. "Specific Sampling and Analysis Plan," USNS Laramie (T-AO). July 1997.
15. NAVSEA. "Specific Sampling and Analysis Plan," USS Wasp (LHD).  July 1997.
16. NAVSEA. "UNDS Phase 1 Sampling Episode Report," Volumes 1-13. February 1998.
17. American Public Health Association, American Water Works Association, and the Water
   Pollution Control Federation. Standard Methods for the Examination of Water and
   Wastewater.  Method 4500-C1G. DPD Colorimetric Method. 17th Edition. Washington,
   DC: American Public Health Association. 1989.
                                       3-11

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                 4.  DISCHARGE EVALUATION METHODOLOGY
4.1    Introduction

       The information collected during Phase I from surveys, consultations, and from discharge
sampling and analysis was used collectively to evaluate the discharges and to make Phase I
decisions according to the seven factors listed in section 1.3. This chapter explains how Phase I
decisions were made for the 39 discharge types listed in Table 3-1 (i.e., which discharges need to
be controlled by MPCDs and which do not). Section 4.2 describes how the environmental effects
screening of the discharges was conducted. Section 4.3 describes the Nature of Discharge
(NOD) analysis and the contents of the NOD reports contained hi Appendix A.  Section 4.4
describes the MPCD practicability, operational feasibility, and cost analysis and the contents of
the MPCD reports - also contained in Appendix A. Section 4.5 lists the chapter 4 references.

4.2    Environmental Effects Determination

       EPA and DoD assessed the potential environmental effects of the discharges using a
screening approach characterized by the following questions concerning their chemical, physical,
and biological characteristics:

       • Chemical Constituents. Does the discharge contain constituents in concentrations
         that exceed State aquatic water quality criteria or Federal aquatic water quality criteria
         (as promulgated by EPA in the National Toxics Rule (NTR)1) and have the potential to
         be released into the environment hi significant amounts, resulting in a potential
         adverse impact on the environment?
       • Thermal Pollution. Does the discharge pose the potential to exceed State thermal
         water quality criteria in the receiving waters beyond a mixing zone, and to a degree
         sufficient to have an adverse impact on the environment?
       • Bioaccumulative Chemicals of Concern.  Does the discharge have the potential to
         contain bioaccumulative chemicals of concern in amounts sufficient to have an adverse
         impact on the environment?
       • Nonindigenous Species. Does the discharge have the potential to introduce viable
         nonindigenous aquatic species to new locations?

       If the answer to any of the above questions was "yes," EPA and DoD determined that the
discharge had a potential for adverse environmental effect.  Each of these  factors is discussed
below.

4.2.1   Chemical Constituents

       EPA and DoD used sampling results or process knowledge to identify the potential
presence and concentrations of constituents in the discharge. Constituent  concentrations hi the
discharge were compared to Federal aquatic water quality criteria promulgated by EPA in the
National Toxic Rule (NTR)1 and State aquatic water quality numeric criteria for the ten States
                                          4-1

-------
with the most significant presence of Armed Forces vessels.2"1 J These ten States are California,
Connecticut, Florida, Georgia, Hawaii, Mississippi, New Jersey, Texas, Virginia, and
Washington.  Constituent concentrations in the discharge were compared against the most
stringent of the Federal and ten States' criteria for that constituent. For almost all constituents,
the State aquatic water quality criteria are more stringent than the Federal NTR aquatic water
quality criteria. EPA and DoD used aquatic water quality criteria in this assessment because they
are a measure of the level of water quality that provides for the protection and propagation of
aquatic life.

       EPA and DoD used saltwater aquatic life criteria for screening the discharges because
most Armed Forces vessels operate hi the brackish water of estuaries or bays, or in the marine
environment off the coast or in open ocean, where the biology of the waterbody is dominated by
saltwater aquatic life,  hi addition, aquatic life criteria were used instead of human health criteria,
which are related to consumption offish and shellfish, because recreational activities such as
fishing and swimming generally do not occur in the immediate vicinity of Armed Forces vessels.

       Depending on the nature of the discharge, EPA and DoD compared discharge
concentrations to either the acute or chronic aquatic water quality criteria values. Where
discharges are intermittent or occasional in nature, of relatively short duration (a few seconds to a
few hours), and dissipate rapidly hi the environment, constituent concentrations were compared
to acute aquatic water quality criteria. Where discharges are of a longer duration or continuous
and likely to result in concentrations in the environment that approach a steady-state condition,
the constituent concentrations were compared to chronic aquatic water quality criteria. Table 4-1
is a list of the most stringent saltwater-based aquatic water quality criteria for the constituents
that were either detected in UNDS discharge samples or thought to be present based on
engineering knowledge. It contains aquatic water quality criteria for both short-term (acute) and
long-term (chronic) exposure published hi Federal and State regulations.

       Because metals maybe present hi the discharges hi both dissolved and solid forms, the
Federal criteria and many States' criteria distinguish between dissolved and "total recoverable"
forms. As issued by EPA  or a particular State, an aquatic water quality criterion for the dissolved
form of a metal is always less than or equal to the criterion for the "total recoverable" form.
However, not all States issue criteria for both forms of metal. For metal constituents, the
following method was used to compare concentrations in the discharge to aquatic water quality
criteria:

       •   When the form of the metal was known (i.e., either "total recoverable" or
           "dissolved") as hi the rune discharges that were sampled, as well as some of the non-
           sampled discharges, the measurement of "total recoverable" metal in the discharge
           was compared  to "total recoverable" criteria, and the measurement of "dissolved"
           metal hi the discharge was compared to "dissolved" criteria.

       •   When the form of the metal was unknown, the metal concentration was compared to
           the most stringent criteria, whether for "total recoverable" or "dissolved."
                                           4-2

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Table 4-1. Aquatic Life Water Quality Criteria
Constituent Name
% t *•
PRIORITY POLLUTANTS*
Acenaphthene
Acenaphthylene
Acrolein, 2-Propenal
Anthracene
Antimony
Arsenic (Dissolved)
Arsenic (Total)
Benzene •
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Beryllium
BHC, alpha- **
BHC,beta- **
BHC, gamma- \ Lindane **
Bis(2-ethylhexyl) phthalate
Cadmium (Dissolved)
Cadmium (Total)
Chromium (Dissolved)
Chromium (Total)
Chrysene
Copper (Dissolved)
Copper (Total)
Cyanide
Dibenzo(a,h)anthracene
Diethyl phthalate
Dimethyl phthalate
Ethylbenzene
Fluoranthene
Fluorene
Heptachlor
Heptachlor epoxide
Indeno(l,2,3-cd)pyrene
Lead (Dissolved)
Lead (Total)
Mercury ** (Dissolved)
Mercury ** (Total)
Most Stringent Acute
Aquatic Lift: Water
1 Quality Criterion
(ue/L)
320
0.031 a
18
1 10,000
4,300
69
36
71.28
0.000535
0.031 a
0.031 a
0.031 a
0.031 a
0.031 a
0.13
0.0131
0.046
0.0625
5.92
42
9.3
1,100
50
0.031 a
2.4
2.9
1
0.031
120,000
2,900,000
140
13
14,000
0.00021
0.0001 1
0.031 a
140
5.6
1.8
0.025
-Source of
Most Stringent
Acute Criterion

HI
FL
HI
GA
FL
EPA, CA, HI, CT
GA,FL
FL, GA
GA
FL
FL
FL
FL
FL
FL
GA
GA.FL
GA
GA
EPA, CA, CT
GA, FL
EPA & 6 STATES
GA,FL
FL
EPA, CT, MS
WA
EPA & 9 STATES
FL
GA
GA
HI
HI
GA
FL
GA
FL
HI.TX
GA, FL
EPA, CA, CT, MS
GA, FL
Most Stringent
Chronic Aquatic
Life Water Quality
Criterioa -
(Ug/L)

0.031 a
780
110,000
4,300
36
36
71.28
0.000535
0.031 a
0.031 a
0.031 a
0.031 a
0.031 a
0.13
0.0131
0.046
0.01
5.92
9.3
8
50
50
0.031 a
2.4
2.9
1
0.031
120,000
2,900,000
28,718
370
14,000
0.00021
0.00011
' 0.031 a
5.6
5.6
0.025
0.025
Source of
Most Stringent
Chronic Criterion


FL
GA
GA
FL
EPA, CA, HI, CT
GA, FL, WA, MS
FL,GA
GA
FL
FL
FL
FL
FL
FL
GA
GA,FL
VA
GA
EPA, CA, HI, VA, CT,
MS
WA
EPA & 6 STATES
WA, GA, FL
FL
EPA, CT, MS
GA.FL
EPA & 9 STATES
FL
GA
GA
GA
GA
GA
FL
GA
FL
TX
GA,FL
VA
EPA, WA, GA, CT, MS,
FL
                    4-3

-------
                      Table 4-1. Aquatic Water Quality Criteria (contd.)
Constituent Name
Naphthalene
Nickel (Dissolved)
Nickel (Total)
Nitrophenol, 4-
Phenanthrene
Phenol
Pyrene
Selenium (Dissolved)
Selenium (Total)
Silver (Dissolved)
Silver (Total)
Thallium
Toluene
Trichloroethane, 1,1,1-
Zinc (Dissolved)
Zinc (Total)
NON-PRIORITY
POLLUTANTS
Chlorine (Chlorine Produced
Oxidants)
Oil & Grease
Aluminum
Ammonia as NH3***
Bromine
Chloride
Iron
Nitrate/Nitrite***
Phosphorus***
Total Nitrogen***
Tributyltin
Most Stringent Acute
Aquatic Life Water
Quality Criterion
780
74
8.3
1,600
0.031 a
170
11,000
290
71
1.9
1.2
6.3
2,100
10,400
90
84.6

10
5,000
1,500
6
100
10%>
ambient
300
8
25
200
0.001
Source of
Most Stringent
Acute Criterion ,
HI
EPA, CA, CT
GA,FL
HI
FL
HI
GA
EPA, CA, CT
GA,FL
EPA, CA, MS
WA
FL
HI
HI
EPA, CA, CT, MS
WA

FL
FL
FL
HI
FL
FL
FL
HI
HI
HI
VA
Most Stringent
Chronic Aquatic
Life Water Quality
Criterion


8.2
7.9


0.031 a
58
11,000
71
71
	
1.2
6.3
200,000
	
81
76.6

7.5
5,000
1,500
6
100
10%>
ambient
300
8
25
200
0.001
Source of
Most Stringent >
Chronic Criterion

EPA, CA, CT
WA

FL
MS
GA
EPA, CA, HI, VA, CT,
MS
WA, GA, FL

WA
FL
GA

EPA, CA, MS
WA

HI, WA, VA, CT, MS,
NJ
FL
FL
HI
FL
FL
FL
HI
HI
HI,
VA
Notes:
* from 40 CFR 136.36
** Denotes bioaccumulative chemicals of concern (40 FR 15366, Table 6A)
*** Nutrient criteria are not specified as either acute or chronic and are, therefore, listed in both columns.
a: Total of acenaphthylene benzo(a)anthrancene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene,
benzo(k)fluoranthene chrysene, dibenz(a,h)anthracene, indeno(l,2,3-c,d)pyrene, and phenanthrene.
                                                  4-4

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       The initial screening process involved comparing the constituent concentrations in the
undiluted discharge to the aquatic water quality criteria.  For those discharges, such as cathodic
protection, where the constituents diffuse from the exterior of a vessel or vessel component, EPA
and DoD generally computed a concentration within a small mixing zone (a few inches to a few
feet).

       EPA and DoD further assessed those discharges that had constituents exceeding aquatic
water quality criteria. EPA and DoD considered mass loadings, flow rates, the geographic
location of the discharge, the manner in which the discharge occurs (e.g., continuous or
intermittent), and in some cases, the effect of the dilution within a small mixing zone.  The
purpose of this further assessment was to determine whether the constituents are discharged with
such a low frequency or in such small amounts that the resulting constituent mass loading has the
potential to produce only minor or undetectable environmental effects, or whether the
constituents are released in such a manner that dilution in a small mixing zone quickly results in
concentrations below aquatic water quality criteria. If so, EPA and DoD considered the chemical
constituents of the discharge not to have the potential to adversely affect the environment.

4.2.2  Thermal Pollution

       In addition to chemical constituents, EPA and DoD assessed whether the discharges
exceeded State thermal water quality criteria for the five States with the most significant presence
of Armed Forces vessels (California, Florida, Hawaii, Virginia, and Washington). A screening
study was performed on these discharges to quantify these potential effects.12 Many discharges
did not need a detailed assessment because they are discharged at ambient or only slightly
elevated temperatures, or the volume or discharge rate is very low. EPA and DoD determined
that six discharges are released at sufficiently high temperatures and volumes that further
assessment was warranted to determine whether the discharge had the potential to cause an
adverse thermal effect. These discharges are:

       •  Boiler Slowdown;
       •  Catapult Water Brake Tank and Post-Launch Retraction Exhaust;
       •  Catapult Wet Accumulator Discharge;
       •  Distillation And Reverse Osmosis Brine;
       •  Seawater Cooling Overboard Discharge; and
       •  Steam Condensate.

       EPA and DoD modeled these discharges to determine the size of the mixing zone that
would be needed for receiving waters to meet State thermal water quality criteria and compared
this zone to State thermal mixing zone allowances.  Small boat engine wet exhaust, firemain
systems, portable damage control drain pump wet exhaust, and submarine emergency diesel
engine wet exhaust discharges also have elevated temperatures above ambient when released.
These discharges generally have minimal temperature differences between the influent and
effluent streams, are released in small volumes, and generally occur only while the vessel is
moving, which distributes the heat load over a wide area. Submarine emergency diesel engine
wet exhaust is released into the air as a mist and cools before contacting the water.  The overall
                                          4-5

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thermal impact from these discharges is minimal; thus, they were not included in the thermal
effects study.

       Two screening protocols were used to evaluate thermal discharges. For discharges that
can be continuous such as steam condensate, seawater cooling overboard discharge, and
distillation and reverse osmosis brine, the Cornell Mixing Zone Expert System (CORMIX,
Version 3.2) was used to estimate the plume size and temperature gradients in the receiving
waterbody for comparison to mixing zone requirements for States with major naval ports.
CORMIX is a software model used to analyze and predict aqueous pollutant discharges into
water bodies. The output from CORMIX provides the shape and size of the thermal plume along
with temperature contours that can then be compared to various thermal criteria. However,
CORMIX has several limitations when modeling this discharge, including modeling the effect of
tidal action and turbulent mixing beyond the plunge zone (i.e., area of initial mixing from a
discharge above the waterline) on the discharge plume.  Therefore, additional modeling was
performed using a hydrodynamic transport model, CH3D, to evaluate steam condensate because
CH3D simulates the mixing of the buoyant plume with ambient and tidal flows by advection and
turbulent mixing both horizontally and vertically in the water column.13

       For discharges that can be intermittent, short-duration, or batch (boiler blowdown,
catapult water brake tank and post-launch retraction exhaust, and catapult wet accumulator
blowdown), thermodynamic equations were used to estimate the  temperature effects because
CORMIX and CH3D were designed primarily for continuous, steady-state discharges. Batch
discharges of high-temperature water require a different screening approach than continuous
discharges because these discharges are not steady-state and are generally small. The steps used
to estimate the maximum size of the impact zone for a given acceptable plume temperature
included:

       •   calculating the total heat and water mass released;
       •   calculating the volume of water needed to dilute this mass of water such that the
           acceptable mixed temperature is obtained; and
       •   determining the region around the release point assuming complete vertical mixing
           that will provide the required volume.
 4.2.3  Bioaccumulative Chemicals of Concern

       EPA and DoD reviewed each discharge to determine whether it contained
 bioaccumulative chemicals of concern, as identified in the Final Water Quality Guidance for the
 Great Lakes System.14 This guidance contains a list of bioaccumulative chemicals of concern
 identified after scientific study, in a process subjected to public notice and comment, designed to
 support a regionally uniform set of standards applicable to the waters of the Great Lakes. Table
 4-2 lists these bioaccumulative chemicals of concern. In every case where the presence of a
 bioaccumulative chemical of concern was confirmed in a discharge, EPA and DoD had already
                                          4-6

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determined based on other information that it was reasonable and practicable to require control of
that discharge.

4.2.4   Nonindigenous Species

       EPA and DoD also assessed each discharge for its potential to transport viable living
aquatic organisms between naturally isolated water bodies. Preventing the introduction of
invasive nonindigenous aquatic species has been recognized as important in maintaining
                   Table 4-2.  List of Bioaccumulative Chemicals of Concern
                                                                          14
           BHC, alpha-
           BHC, beta-
           BHC, delta-
           BHC, gamma- \Lindane
           Chlordane
           ODD
           DDE
           DDT
           Dieldrin
           Hexachlorobenzene
           Hexachlorobutadiene
           Mercury
           Mirex/Dechlorane
     PCB-1016
     PCB-1221
     PCB-1232
     PCB-1242
     PCB-1248
     PCB-1254
     PCB-1260
     Pentachlorobenzene
     1,2,4,5-Tetrachlorobenzene
     2,3,7,8-Tetrachlorodibenzo-
       p-dioxin
     Toxaphene
       Notes:
       BHCs are chlorinated cyclohexanes
       DDT is dichlorodiphenyl trichloroethane
DDD and DDE are metabolites of DDT
PCBs are polychlorinated biphenyls
biodiversity, water quality, and the designated uses of water bodies. If the available data indicate
that a discharge has a potential for transporting and then subsequently discharging viable aquatic
organisms into waters of the U.S., then EPA and DoD considered the discharge to present a
potential for causing adverse environmental effects from nonindigenous species.

4.2.5  Discharge Evaluation

       In some cases, EPA and DoD determined it was reasonable and practicable to require
MPCDs to control a discharge even though available information indicates that the discharge has
a low potential for adversely affecting the environment. For the Chain Locker Effluent and
Sonar Dome discharges, at least one class of Armed Forces vessel has a management practice or
control technology already in place to control the environmental effects of the discharge. EPA
and DoD considered the existence of a currently applied management practice or control
technology to be sufficient indication that it was reasonable and practicable to require a MPCD.
In other cases (Non-Oily Machinery Wastewater and Photographic Laboratory Drains), analysis
                                           4-7

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of whether the discharge had a potential to adversely affect the environment was inconclusive.
However, EPA and DoD determined that it was reasonable and practicable to require a MPCD to
mitigate possible adverse environmental effects from the discharge.

For each discharge that was determined to have the potential to adversely affect the
environment, EPA and DoD conducted an initial evaluation of the practicability, operational
impact, and economic cost of using a MPCD to control each discharge. EPA and DoD first
determined whether a control technology or management practice is currently in place to control
the discharge for environmental protection on any vessel type. The use of existing controls on a
vessel was considered sufficient demonstration that at least one reasonable and practicable
control is available for at least one vessel type. The Phase IUNDS rule does not address whether
existing control technologies or management practices are adequate to mitigate potential adverse
impacts. In Phase n of UNDS, EPA and DoD will promulgate MPCD performance standards for
the discharges requiring control. For discharges without any existing pollution controls, EPA
and DoD analyzed potential pollution control options to determine whether it is reasonable and
practicable to require the use of MPCDs. For every discharge that was found to have a potential
to cause adverse environmental effects, EPA and DoD determined that it is reasonable and
practicable to require a MPCD for at least one vessel type. The results of the MPCD assessments
are presented in Appendix A.

4.3 Nature of Discharge Analysis

The nature of the discharge was analyzed for each of the 39 discharges incidental to the
operations of Armed Forces vessels (Table 3-1), and based on this analysis, a NOD report was
prepared that describes the discharge hi detail, including the system that produces the discharge,
the equipment involved, the constituents released to the environment, and the current practice, if
any, to prevent or minimize environmental effects. The NOD report summarizes the results of
additional sampling or other data gathered on the discharge. Based on this information, the NOD
report describes how the estimated constituent concentrations and mass loadings in the
environment were determined. The constituent concentrations are compared to applicable
Federal and State water quality criteria. In addition to comparing discharge concentrations to
Federal and State water quality criteria, other U.S. laws and international standards were also
evaluated, including the standards for oil established by the International Convention for the
Prevention of Pollution from Ships (MARPOL) (73/78) as implemented by the Act to Prevent
Pollution from Ships, and the oil spill regulations at 40 CFR Part 110. Where Federal law and
international standards were relevant to a discharge, the law and standards are discussed hi the
NOD reports contained in Appendix A.

In addition, known bioaccumulative chemicals of concern are identified, possible thermal
effects are discussed (if applicable) and the potential for introducing nonindigenous aquatic
species is assessed. The NOD report also discusses the potential for the discharge to cause
adverse environmental effects.
4-8

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4.3.1 Nature of Discharge Report Contents

NOD reports are divided into six sections, the outline of which is presented below:
Section 1.0 — Introduction
Provides a brief description of the basic objectives of the NOD analysis. This section is identical for each of
the reports.

Section 2.0- Discharge Description

2.1 Equipment Description and Operation — this section describes the equipment and ship operations that
generate the discharge. It includes any pertinent figures and schematics that assist in explaining the origin
of the discharge.

2.2 Releases to the Environment - this section describes the actual discharge released to the environment.
The section also describes how the discharge is released, such as whether the flow is a stream, a mist, or
results from direct contact with surrounding waters.

2.3 Vessels Producing the Discharge — this section describes which Armed Forces vessels produce the
discharge.

Section 3.0 — Discharge Characteristics

3.1 Locality - this section describes whether the discharge occurs within 12 n.m.from shore.

3.2 Rate — this section presents the estimated flow rate of the discharge. This rate can be a distinct flow in
the case of liquid discharges, or a release rate in the case of constituents that corrode, erode, or dissolve into
the environment.

3.3 Constituents - this section identifies the constituents in the discharge, including thermal pollution, when
applicable. Included in this section is an identification of those pollutants known to be particularly
detrimental to environmental quality. Section 3.3 includes the following:

• a list of all constituents identified in the discharge;
• identification of priority pollutants; and
• identification ofbioaccumulative chemicals of concern.

3.4 Concentrations — this section presents the concentrations of the constituents in the discharge. When
possible, this is estimated from an analysis of the existing data or alternatively, from process knowledge of
the system that produces the discharge. When sampling was conducted, results of the sample analyses are
presented.

Section 4.0 - Nature of Discharge Analysis

4.1 Mass Loadinss — in this section, the flow rate and the concentrations presented in section 3.0 are used
to calculate an estimated annual mass loading on a fleet-wide basis.

4.2 Environmental Concentrations - this section varies with each analysis, but includes a comparison of
the concentrations (from section 3.4) with the Federal aquatic water quality criteria and aquatic water
quality criteria for selected States. Where appropriate, this section presents estimates of the concentrations
after dilution in the environment. Any mixing zone calculations are clearly explained and assumptions are
4-9

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listed. Pertinent figures from any analysis are included to support statements regarding the results of the
analysis.

4.3 Potential for Introducing Nonindieenous Species - this section describes an evaluation of the potential
for the discharge to transport and introduce nonindigenous aquatic species.

Section 5.0 — Conclusion
Provides a summary of the assessment of the potential for the discharge to cause an adverse environmental
effect based on information presented in the report.

Section 6.0 — Data Sources and References
This section contains a table that indicates the type and source of information presented in each section of
the analysis. The section also lists the references cited in the report.
4.3.2 Peer Review

Peer review is a documented critical review of a scientific and technical work product. It
is an in-depth assessment that is used to ensure that the final work product is technically sound.
Peer reviews are conducted by qualified individuals who are independent of those who prepared
the work product. For the Phase I rule, reviewers were selected because of their technical
expertise in assessing pollutant behavior in coastal and estuarine ecosystems, modeling pollutant
concentrations, and predicting the effects of pollutant loadings on ambient water quality,
sediments, and biota.

NOD reports for five discharges were selected for peer review. For each of these
discharges, EPA and DoD determined that it is not reasonable and practicable to require the use
of MPCDs because they exhibit a low potential for causing adverse impacts on the marine
environment. Peer reviewers were asked whether the data and process information presented in
the NOD reports are sufficient to characterize the discharges; whether the analyses are
appropriate for the discharges; and whether the conclusions regarding the discharges' potential
for causing adverse environmental impacts are supported by the information presented hi the
NOD reports. Peer review comments are compiled in a separate report.
15
EPA and DoD reviewed the peer review comments and determined that the comments did not
indicate any fundamental flaws hi the methodology used to assess a discharge's potential to cause
adverse impacts on the marine environment. EPA and DoD resolution of peer review comments
are compiled in Uniform National Discharge Standards For Vessels Of The Armed Forces Peer
Review Comment Response.16
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4.4    MPCD Practicability, Operational Feasibility, and Cost Analysis

       If a discharge was determined to have a potential to cause an adverse environmental
impact in the absence of pollution controls, EPA and DoD evaluated the practicability,
operational impact, and economic cost of using a MPCD to control the discharge. First, EPA and
DoD determined whether a control technology or management practice is currently in place to
control the discharge for environmental protection on any vessel type. The use of existing
controls was considered sufficient demonstration that at least one practicable control is available.
The Phase IUNDS rule does not address whether existing control technologies or management
practices are adequate to mitigate potential adverse impacts, hi Phase n of UNDS, EPA and
DoD will promulgate MPCD performance standards for the discharges requiring control.  For
discharges without any existing pollution controls but having the potential to cause an adverse
environmental impact, EPA and DoD analyzed potential pollution control options to determine
whether it is reasonable and practicable to require the use of MPCDs.  Practicability analyses
were prepared for the following four discharges (these analyses are contained in Appendix A):

       •   Distillation and Reverse Osmosis Brine;
       •   Hull Coating Leachate;
       •   Small Boat Engine Wet Exhaust; and
       •   Underwater Ship Husbandry.

       For every discharge that showed a potential to cause adverse environmental effects, EPA
and DoD determined that it is reasonable and practicable to require a MPCD.

4.4.1   MPCD Practicability, Operational Feasibility, and Cost Report Contents

       Each MPCD report gives a brief description of the discharge, lists and describes the
MPCD options, and reports the results of analyzing each MPCD option according to
practicability, operational impact, cost, and environmental effectiveness.  The contents of the
MPCD reports are briefly described below:
    Analysis of Practicability, Operational Impact, and Cost of Selected MPCD Options
    This section describes the purpose of the MPCD analysis and discusses the factors that are considered when
    determining which discharges should be controlled by MPCDs.

    1.0 MPCD Options
    This section describes the discharge and how it is generated and lists each of the MPCD options considered.

    2.0 MPCD Analysis Results
    This section presents the results of the MPCD analysis including discussions on practicability, effect on
    operational and warfighting capabilities, cost, environmental effectiveness, and a determination for each
    MPCD option.  It recommends one or more MPCD options for further consideration under Phase II of
    UNDS.
                                           4-11

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4.5 References

1. USEPA. "Water Quality Standards." 40 CFR Part 131.36. The following Federal Register
notices addressed the National Toxic Rule that is promulgated at 40 CFR Part 131.36:
"Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic Pollutants,"
57 FR 60848,22 December 1992, and "Water Quality Standards; Establishment of Numeric
Criteria for Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria," 60
FR 22230,4 May 1995.
2. State of Florida. "Florida Department of Environmental Protection. Surface Water Quality
Standards," Chapter 62-302. Effective 26 December 1996.
3. State of Georgia. Georgia Final Regulations. "Water Quality Control," Chapter 391-3-6 as
provided by The Bureau of National Affairs, Inc. 1996.
4. State of Connecticut. Connecticut Department of Environmental Protection. "Surface Water
Quality Standards," Effective 8 April 1997.
5. State of Mississippi. Mississippi Department of Environmental Quality, Office of Pollution
Control. "Water Quality Criteria for hitrastate, Interstate and Coastal Waters." Adopted 16
November 1995.
6. State of Texas. Texas Natural Resource Conservation Commission. 'Texas Surface Water
Quality Standards." 307.2 - 307.10. Effective 13 July 1995.
7. State of New Jersey. New Jersey Final Regulations. "Surface Water Quality Standards."
Section 7:9B-1, as provided by The Bureau of National Affairs, Inc. 1996.
8. USEPA. "Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants for the State of California," Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. .62, Number 150. 5 August 1997.
9. State of Hawaii. "Water Quality Standards." Chapter 54, Section 11-54.
10. State of Washington. "Water Quality Standards for Surface Waters of the State of
Washington." Chapter 173-201 A. Washington Administrative Code.
11. State of Virginia. "Water Quality Standards." Chapter 260. Virginia Administrative Code
VA9; VAC 25-260.
12. NAVSEA. "Thermal Effects Screening of Discharges From Vessels of the Armed Forces."
July 1997.
13. USNavy/USEPA. "Supplement to Thermal Effects Screening of Discharges from Vessels of
the Armed Forces."
14. USEPA. Table 6A of the "Water Quality Guidance for the Great Lakes System." 60 FR
15365. 23 March 1995.
15. USEPA. "Peer Review Comments Document, Nature of Discharge Reports for Uniform
National Discharge Standards." Contract No. 68-C7-0002, Work Assignment No. 1-50. 1
July 1998.
16. USNavy/USEPA. "Uniform National Discharge Standards For Vessels Of The Armed Forces
Peer Review Comment Response." 1 March 1999.
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5. PHASE I DISCHARGE DETERMINATIONS
This chapter summarizes the 39 discharge types listed in Table 3-1 and the UNDS Phase I
decisions made regarding whether MPCDs are required. Section 5.1 provides this information
for the discharges that EPA and DoD determined to require MPCDs; section 5.2 provides
information for the discharges determined not to require MPCDs; and section 5.3 lists the chapter
5 references.

5.1 Discharges Determined To Require MPCDs

For the reasons discussed below, EPA and DoD have determined that it is reasonable and
practicable to require the use of a MPCD to control 25 types of discharges from vessels of the
Armed Forces. Except where noted, the pollutant characteristics of these discharges indicate a
potential to cause adverse environmental impacts. Table 5-1 lists those discharges for which EPA
and DoD determined it was reasonable and practicable to require the use of an MCPD, and
identifies the characteristics of each discharge that formed the basis of the determination..

For the Phase I rule, EPA and DoD identified at least one potential MPCD control option
for each discharge that could mitigate the environmental impacts of the discharge from at least
one class of Armed Forces vessel, hi Phase n of the UNDS rulemaking, EPA and DoD will
perform a more detailed assessment of MPCD control options. EPA and DoD will consider
options that are being evaluated as part of research and development programs in addition to
those that are currently available. EPA and DoD will evaluate MPCDs for all classes of vessels
and promulgate the specific performance standards for each MPCD that are reasonable and
practicable for that class of vessel, hi developing specific MPCD performance standards, EPA
and DoD will consider the same factors considered in Phase I. The Phase n rule may distinguish
among vessel types and sizes, between new and existing vessels, and may waive the applicability
of Phase n standards as necessary or appropriate to a particular type or age of vessel (see CWA
section 312(n)(3)(B)).

A MPCD is a control technology or a management practice that can reasonably and
practicably be installed or otherwise used on a vessel of the Armed Forces to receive, retain,
treat, control or discharge a discharge incidental to the normal operation of the vessel.

The discussions below provide a brief description of the discharges and the systems that
produce the discharges EPA and DoD propose to control. The discussions highlight the most
significant constituents released to the environment, and describes the current practice, if any, to
prevent or minimize environmental effects. Because of the diversity of vessel types and designs,
these control practices are usually not uniformly applied to all vessels generating the discharge.
hi addition, these controls do not necessarily represent the only control options available. A
more detailed discussion of the discharges is presented hi the NOD reports in Appendix A.
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Table 5-1. Discharges Requiring the Use of a MPCD and the Basis for the Determination3

Discharge
Aqueous Film-Forming Foam
Catapult Water Brake Tank
Discharge and Post-Launch
Retraction Exhaust
Chain Locker Effluent
Clean Ballast
Compensated Fuel Ballast
Controllable Pitch Propeller
Hydraulic Fluid
Deck Runoff
Dirty Ballast
Distillation and Reverse
Osmosis Brine
Elevator Pit Overboard
Discharge
Firemain Systems
Gas Turbine Washdown
Discharge
Graywater
Hull Coating Leachate
Motor Gasoline
Compensating Overboard
Discharge
Non-Oily Machinery
Wastewater
Photographic Laboratory
Drains
Seawater Cooling Overboard
Discharge
Seawater Piping Biofouling
Prevention
Small Boat Engine Wet
Exhaust
Sonar Dome Discharge
Submarine Bilge Water
Surface Vessel Bilge
Water/Oil-Water Separator
Discharge
Underwater Ship Husbandry
Welldeck Discharges
Chemical Constituents
Oil

X


X
X
X
X

X

X


X






X
X

X
Metals








X

X


X



X





X

Organic
Chemicals











X
X






X






Thermal
Pollution

















X








Bioaccum-
, ulative
Chemicals
of Concern


























Nonindigenous
Species



X










X








X

«
Other
(b)

(c)












(d)
(d)

(e)

(c)




                                      5-2

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Notes:
(a) This table provides a simplified overview of the basis for requiring the use of MPCDs for particular
discharges. It is not intended to fully characterize the discharges or describe the analyses leading to the
decision. More complete characterizations of the discharges and the analyses leading to the decisions are
presented in this section and in Appendix A.
(b) Discharge may produce floating foam in violation of some State water quality standards.
(c) Discharge was determined to have a low potential to adversely affect the environment, but an existing
MPCD is hi place on at least one type of vessel to reduce this low potential even further.
(d) No conclusion was drawn on the potential of the discharge to adversely affect the environment, but EPA
and DoD determined a MPCD is reasonable and practicable to mitigate any possible adverse effects.
(e) Chlorine and chlorination byproducts.
5.1.1 Aqueous Film-Forming Foam (AFFF)

This discharge consists of a mixture of seawater and firefighting foam discharged during
training, testing, and maintenance operations. Aqueous film forming foam (AFFF) is the primary
firefighting agent used to extinguish flammable liquid fires on surface ships of the Armed Forces.
AFFF is stored on vessels as a concentrated liquid that is mixed with seawater to create the
diluted solution (3-6% AFFF) that is sprayed as a foam on the fire. The solution is applied with
both fire hoses and fixed sprinkler devices. During planned maintenance of firefighting systems,
system testing and inspections, and flight deck certifications, the seawater/fbam solution is
discharged either directly overboard from hoses, or onto flight decks and then subsequently
washed overboard. These discharges are considered incidental to the normal operation of Armed
Forces vessels. Discharges of AFFF that occur during firefighting or other shipboard emergency
situations are not incidental to normal operations and are not subject to the requirements of the
rule.

AFFF is discharged from all Navy ships, those MSC ships capable of supporting
helicopter operations, and Coast Guard cutters, icebreakers, and tugs. AFFF discharges generally
occur at distances greater than 12 n.m. from shore, and in all cases more than 3 n.m. from shore
due to existing Armed Forces operating instructions. The constituents of AFFF include water, 2-
(2-butoxyethoxy)-ethanol, urea, alkyl sulfate salts, amphoteric fluoroalkylamide derivative,
perfiuoroalkyl sulfonate salts, triethanolamine, and methyl-IH-benzotriazole. Because the water
used to mix with the AFFF concentrate comes from the vessel's firemain, the discharge will also
include bis(2-ethylhexyl)phthalate, nitrogen (measured as total Kjeldahl nitrogen), copper, nickel,
and iron from the firemain piping.

The AFFF discharge produces an aqueous foam intended to cool and smother fires. Water
quality criteria for some States include narrative requirements for waters to be free of floating
materials attributable to domestic, industrial, or other controllable sources, or include narrative
criteria prohibiting discharges of foam. AFFF discharges in State waters would be expected to
result in violating such narrative criteria for foam or floating materials. At present, the Navy uses
certain management practices to control these discharges, including a self-imposed prohibition
on AFFF discharges in coastal waters by most Armed Forces vessels. These management
practices to control discharges of AFFF demonstrate the availability of a MPCD to mitigate the
5-3

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potential adverse impacts that could result from the discharge of AFFF. Therefore, EPA and
DoD have determined that it is reasonable and practicable to require use of a MPCD for this
discharge.

AFFF discharges occur beyond 3 n.m. but within 12 n.m. from shore infrequently and in
relatively small volumes, and preliminary investigation indicates that the diluted (3-6%) AFFF
solution does not exhibit significant toxic effects. Further, any discharges that do occur take
place while the vessel is underway and will be dispersed in the turbulence of the vessel wake.

5.1.2 Catapult Water Brake Tank and Post-Launch Retraction Exhaust

This intermittent discharge is the oily water skimmed from the catapult water brake tank,
and the condensed steam discharged when the catapult is retracted. Catapult water brakes are
used to stop the forward movement of the steam-propelled catapults used to launch aircraft from
Navy aircraft carriers. The catapult water brake system includes water brake cylinders and a
water brake tank that contains freshwater. During flight operations, water from the catapult
water brake tank is continuously injected into the catapult water brake cylinders. At the end of a
launch stroke, spears located on the front of the catapult pistons enter the water brake cylinders.
The water in the cylinders builds pressure ahead of the spears, cushioning the catapult pistons to
a stop. The catapult brake water is continuously circulated between the catapult water brake tank
and the catapult water brake cylinders.

Prior to the launch stroke, lubricating oil is applied to the catapult cylinder through which
the catapult piston and piston spear are driven. As the catapult piston is driven forward during
the launch stroke, the catapult piston and spear carries lubricating oil from the catapult cylinder
into the water brake cylinder at the end of the stroke. Over the course of multiple launchings, the
oil and water circulating through the water brake cylinder and tank leads to the formation of an
oil layer in the water brake tank. The oil layer can adversely affect water brake operation by
interfering with the cooling of water in the water brake tank. To prevent excessive heat buildup
in the tank, the oil is periodically skimmed off and discharged overboard. Additionally, as the
catapult piston is retracted following the launch, expended steam from the catapult launch stroke
and some residual lubricating oil from the catapult cylinder walls are discharged below the
waterline through a separate exhaust pipe.

Only aircraft carriers generate this discharge. Catapult operations during normal flight
operations generate both the water brake tank discharge and the post-launch retraction exhaust;
however, flight operations take place beyond 12 n.m. from shore. Catapult testing which occurs
within 12 n.m. always discharges the post-launch retraction exhaust, but usually does not add
sufficient quantities of oil to the water brake tank to require skimming.

The water brake tank is used within 12 n.m. for dead-load catapult shots when testing
catapults on new aircraft carriers, and following major drydock overhauls or major catapult
modifications. This testing requires a minimum of 60 dead-load shots each and may occur over a
period of several days within 12 n.m. from shore. New carrier testing occurs only once, and
major overhauls generally occur on 5- to 7-year cycles in conjunction with drydocking. Major
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modifications to catapults may occur during an overhaul or pierside and are also infrequent
events. Carriers also routinely perform no-load shots when leaving port. The number of no-load
shots conducted when leaving port, however, usually do not add enough lubricating oil to the
water brake tank to require skimming the oil while the ship is within 12 n.m. from shore.

The Water Brake Tank and Post-Launch Retraction exhaust discharge includes
lubricating oil, a limited thermal load associated with the heated oil and water (or condensed
steam, in the case of the post-launch retraction exhaust), nitrogen (in the form of ammonia,
nitrates and nitrites, and total Kjeldahl nitrogen), and metals such as copper and nickel from the
piping systems. EPA and DoD analyzed the thermal effects of this discharge and concluded they
were unlikely to exceed thermal mixing zone criteria in the States where aircraft carriers most
frequently operate. The post-launch retraction exhaust discharge can contain oil, copper, nickel,
ammonia, bis(2-ethylhexyl)phthalate, phosphorus, and benzidine in concentrations exceeding
State acute water quality criteria. The post-launch retraction exhaust discharge can also contain
nitrogen in concentrations exceeding the most stringent State water quality criteria.

The Navy has imposed operational controls limiting the amount of oil applied to the
catapult cylinder during the launch stroke, which directly affects the amount of oil that is
subsequently discharged from the water brake tank or during the post-launch retraction exhaust.
The Navy has also established requirements prescribing when catapult testing is required within
12 n.m. from shore. These operational constraints minimize discharges of oil from the water
brake tank and post-launch retraction exhaust in coastal waters. These existing management
practices demonstrate the availability of controls for this discharge. Therefore, EPA and DoD
have determined that it is reasonable and practicable to require use of a MPCD to mitigate
potential adverse environmental impacts from this discharge.

5.1.3 Chain Locker Effluent

This discharge consists of accumulated precipitation and seawater that is occasionally
emptied from the compartment used to store the vessel's anchor chain.

The chain locker is a compartment used to store anchor chain aboard vessels. Navy
policy requires that the anchor chain, appendages, and anchor on Navy surface vessels be washed
down with seawater during retrieval to prevent onboard accumulation of sediment. During
washdown, some water adheres to the chain and is brought into the chain locker as the chain is
stored. The chain locker sump accumulates the residual water and debris that drains from the
chain following anchor chain washdown and retrieval, or washes into the chain locker during
heavy weather. Water accumulating in the chain locker sump is removed by a drainage eductor
powered by the shipboard firemain system.

All Armed Forces vessels housing their anchor chains in lockers, except submarines, can
generate this discharge. Since submarine chain lockers are always open to the sea, water is
always present hi the chain locker and there is no "collected" water to be discharged as effluent.
Navy policy prohibits discharging chain locker effluent within 12 n.m. Other vessels of the
Armed Forces are currently authorized to discharge chain locker effluent within 12 n.m.;
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however, most Armed Forces vessels also observe the 12 n.m. discharge prohibition. A recent
review of practices on several Navy ships found no water accumulation in the chain locker sump,
and the ships' crew confirmed that discharges of chain locker effluent occur outside 12 n.m.

In addition to water, materials collecting in the chain locker sump can include paint chips,
rust, grease, and other debris. Chain locker effluent may contain organic and inorganic
compounds associated with this debris, as well as metals from the sump and from sacrificial
anodes installed in the chain locker to provide cathodic protection. If the anchor chain
washdown is not performed and the chain locker effluent is subsequently discharged in a
different port, the discharge could potentially transport nonindigenous species. Discharge
volume will vary depending upon the frequency of anchoring operations, the number of anchors
used, and the depth of water (which determines the amount of chain that will be lowered into the
water).

Given the manner in which water collects in the chain locker sump and remains there for
extended periods of time, it is possible that the discharge could contain elevated levels of metals
at concentrations exceeding State water quality criteria. However, given the small volume of the
discharge and the infrequency of anchoring operations, it is unlikely that discharges of chain
locker effluent would adversely impact the environment. Nevertheless, the Navy and other
Armed Forces already have management practices in place for most vessels requiring anchors
and anchor chains to be washed down with seawater during retrieval, and prohibiting the
discharge of chain locker effluent until beyond 12 n.m. from shore. DoD has chosen as a matter
of policy to continue prohibiting the discharge of chain locker effluent within 12 n.m. from
shore. This prohibition, while not considered necessary to mitigate an existing or potential
adverse impact, will eliminate the possibility of discharging into coastal waters any metals, other
contaminants, or nonindigenous aquatic species that may have accumulated in the chain locker
sump. EPA and DoD have determined that the existing management practices demonstrate that
it is reasonable and practicable to require use of a MPCD for chain locker effluent.

5.1.4 Clean Ballast

This discharge is composed of the seawater taken into, and discharged from, dedicated
ballast tanks used to maintain the stability of the vessel and to adjust the buoyancy of
submarines.

Many types of Armed Forces vessels store clean ballast in dedicated tanks in order to
adjust a vessel's draft, buoyancy, trim, and list. Clean ballast may consist of seawater taken
directly onboard into the ballast tanks or seawater received from the vessel's firemain system.
Clean ballast differs from "dirty ballast" and "compensated ballast" discharges (described below)
in that clean ballast is not stored in tanks that are also used to hold fuel. Many surface vessels
introduce clean ballast into tanks to replace the weight of off-loaded cargo or expended fuel to
improve vessel stability while navigating on the high seas. Amphibious ships also flood clean
ballast tanks during landing craft operations to lower the ship's stern, allowing the well deck to
be accessed. Submarines introduce clean ballast into their main ballast tanks when submerging,
and introduce clean ballast into their variable ballast tanks to make minor adjustments to
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buoyancy, trim, and list while operating submerged or surfaced. The discharge occurs when fuel
or cargo is taken on and the ballast is no longer needed, when amphibious operations are
concluded and the vessel is returned to its normal operating draft, when submarines surface, or
when submarines make some operational adjustments in trim or list while submerged or
surfaced.

Clean ballast discharges are intermittent and can occur at any distance from shore,
including within 12 n.m. Constituents of clean ballast can include materials from tank coatings
(e.g., epoxy), chemical additives (e.g., flocculant chemicals or rust inhibitors), and metals from
piping systems and sacrificial anodes used to control corrosion. Based on analytical data for
firemain system discharges, metals expected to be present in the discharge include copper, nickel,
and zinc. These data indicate that the pollutant concentrations in the discharge may exceed State
water quality criteria.

Previous studies have documented the potential of ballasting operations to transfer
nonindigenous aquatic species into receiving waters. Ballast water potentially contains living
microorganisms, plants, and animals that are native to the location where the water was pumped
aboard. When the ballast water is transported to another port or coastal area and discharged, the
surviving organisms are released and have the potential to invade and impact the local
ecosystem.

The Navy, MSC, and Coast Guard either currently implement or are in the process of
approving a ballast water management policy requiring open-ocean ballast water exchange, based
on guidelines established by the International Maritime Organization.1 These management
practices demonstrate the availability of controls to mitigate the potential adverse environmental
impacts from this discharge. Therefore, EPA and DoD have determined that it is reasonable and
practicable to require a MPCD for discharges of clean ballast.

5.1.5 Compensated Fuel Ballast

This intermittent discharge is composed of the seawater taken into, and discharged from,
tanks designed to hold both fuel and ballast water to maintain the stability of the vessel.

Compensated fuel ballast systems are configured as a series of fuel tanks that
automatically draw in seawater to replace fuel as it is consumed. Keeping the fuel tanks full in
this manner enhances the stability of a vessel by using the weight of the seawater to compensate
for the mass of ballast lost through fuel consumption. During refueling, fuel displaces the
seawater, and the displaced seawater is discharged overboard.

Compensated fuel ballast is discharged by approximately 165 Navy surface vessels and
submarines. In most cases, surface ships with compensated fuel ballast systems discharge
directly to surface waters each time they refuel. However, hi some situations that discharge is
collected for processing on shore. Surface vessels are refueled both in port and at sea. All at-sea
refueling is accomplished beyond 12 n.m. from shore. For submarines, refueling occurs only in
port and the compensated ballast is transferred to shore facilities for processing.
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The compensated fuel ballast discharge can contain 2-propenal, phosphorus, thallium, oil
(and its constituents, such as benzene, phenol, and toluene), copper, mercury (a bioaccumulative
chemical of concern), nickel, silver, and zinc. Concentrations of 2-propenal, benzene, copper,
nickel, phosphorus, silver, thallium, and zinc can exceed acute Federal criteria or State acute
water quality criteria. The compensated fuel ballast discharge can also contain nitrogen (in the
form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen) in concentrations exceeding
the most stringent State water quality criteria.

To reduce the discharge of fuel in compensated fuel ballast discharge, the Navy has
instituted operational guidelines intended to reduce the potential for overfilling tanks or
discharging excessive amounts of fuel entrained hi the displaced compensating water while
refueling surface vessels. These guidelines limit the amount of fuel that can be taken on in port
(i.e., to prevent "topping off the fuel tanks) and establish maximum allowable rates for in port
refueling. Additionally, submarines transfer all compensated fuel ballast water to shore facilities
when refueling diesel fuel oil tanks. These operational controls for surface vessel refueling and
the practice of transferring the discharge to shore for submarines demonstrates the availability of
MPCDs to mitigate potential adverse environmental impacts; therefore, EPA and DoD have
determined it is reasonable and practicable to require the use of a MPCD for compensated fuel
ballast.

5.1.6 Controllable Pitch Propeller Hydraulic Fluid

This discharge is the hydraulic fluid that is discharged into the surrounding seawater from
propeller seals as part of normal operation, and the hydraulic fluid released during routine
maintenance of the propellers.

Controllable pitch propellers (CPP) are used to control a vessel's speed or direction while
maintaining constant propulsion plant output (i.e., varying the pitch, or "bite," of the propeller
blades allows the propulsion shaft to remain turning at a constant speed). CPP blade pitch is
controlled hydrauh'cally through a system of pumps, pistons, and gears. Hydraulic oil may be
released from CPP assemblies under three conditions: leakage through CPP seals, releases
during underwater CPP repair and maintenance activities, or releases from equipment used for
CPP blade replacement.

Over 200 Armed Forces vessels have CPP systems. Leakage through CPP seals can
occur within 12 n.m., but seal leakage is more likely to occur while the vessel is underway than
while pierside or at anchor because the CPP system operates under higher pressure when a vessel
is underway. Blade replacement occurs in port on an as-needed basis when dry-docking is
unavailable or impractical, resulting in some discharge of hydraulic oil. Approximately 30 blade
replacements and blade port cover removals (for maintenance) are conducted annually, fleetwide.

CPP assemblies are designed to operate at 400 psi without leaking. Typical pressures
while pierside range from 6 to 8 psi. CPP seals are designed to last five to seven years, which is
the longest period between dry-dock cycles, and are inspected quarterly to check for damage or
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excessive wear. Because of the hub design and the frequent CPP seal inspections, leaks of
hydraulic oil from CPP hubs are found to be negligible. During the procedure for CPP blade
replacement, however, hydraulic oil is released to the environment from tools and other
equipment. In addition, hydraulic oil could also leak from the CPP hub during a CPP blade port
cover removal.

The Navy's repair procedures impose certain requirements during blade replacement and
blade port cover removal to minimize the amount of hydraulic oil released to the extent possible.
In addition, booms are placed around the aft end of the vessel to contain possible oil release
during these procedures. Nevertheless, EPA and DoD have determined that the amount of
hydraulic oil released during underwater CPP maintenance could create an oil sheen and exceed
State water quality criteria. Constituents of the discharge could include paraffins, olefins, and
metals such as copper, aluminum, tin, nickel, and lead. Metal concentrations are expected to be
low because hydraulic oil is not corrosive, and the hydraulic oil is continually filtered to protect
against system failures.

EPA and DoD have determined that pollution controls are necessary to mitigate the
potential adverse environmental impacts that could result from releases of hydraulic oil during
underwater maintenance on controllable pitch propellers. The existing repair procedures and the
staging of containment booms and oil skimming equipment to capture released oil demonstrate
the availability of MPCDs (i.e., best management practices) for this discharge. Therefore, EPA
and DoD have determined that it is reasonable and practicable to require MPCDs to control
discharges of CPP hydraulic fluid.

5.1.7 Deck Runoff

Deck runoff is an intermittent discharge generated when water from precipitation,
freshwater washdowns, wave action, or spray falls on the exposed portion of a vessel such as a
weather deck or flight deck. This water is discharged overboard through deck openings and
washes overboard any residues that may be present on the deck surface. The runoff drains
overboard to receiving waters through numerous deck openings. All vessels of the Armed Forces
produce deck runoff, and this discharge occurs whenever the deck surface is exposed to water,
both within and beyond 12 n.m.

Contaminants present on the deck originate from topside equipment components and the
many varied activities that take place on the deck. This discharge can include residues of
gasoline, diesel fuel, Naval distillate fuel, grease, hydraulic fluid, soot, dirt, paint, glycol,
cleaners such as sodium metasilicates, and solvents. A number of metal and organic pollutants
may be present in the discharge, including silver, cadmium, chromium, copper, nickel, lead,
benzene, ethylbenzene, toluene, xylene, polycyclic aromatic hydrocarbons, and phenol. Mass
loadings and concentrations of these constituents will vary with a number of factors including
ship operations, deck washdown frequency, and the frequency, duration, and intensity of
precipitation events.
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Based on the results from limited sampling from catapult troughs (a component of runoff
from aircraft carrier flight decks), oil and grease, phenols, chromium, cadmium, nickel, and lead
could be present in this discharge at levels exceeding acute Federal criteria and State acute water
quality criteria. If not properly controlled, oil collecting in catapult troughs can cause deck
runoff from aircraft carrier flight decks to create an oil sheen on the surface of the receiving
water, which would violate State water quality criteria. Armed Forces vessels already institute
certain management practices intended to reduce the amount of pollutants discharged in deck
runoff, including keeping weather decks cleared of debris, immediately mopping up and cleaning
spills and residues, and engaging in spill and pollution prevention practices. These practices
demonstrate the availability of controls to mitigate adverse impacts from deck runoff. Therefore,
EPA and DoD have determined it is reasonable and practicable to require a MPCD for deck
runoff.

5.1.8 Dirty Ballast

This intermittent discharge is composed of the seawater taken into, and discharged from,
empty fuel tanks to maintain the stability of the vessel. The seawater is brought into these tanks
for the purpose of improving the stability of a vessel during rough sea conditions. Prior to taking
on the seawater as ballast, fuel in the tank to be ballasted is transferred to another fuel tank or
holding tank to prevent contaminating the fuel with seawater. Some residual fuel remains in the
tank and mixes with the seawater to form dirty ballast. Dirty ballast systems are configured
differently from compensated ballast and clean ballast systems. Compensated ballast systems
continuously replace fuel with seawater in a system of tanks as the fuel is consumed. Clean
ballast systems have tanks that carry only ballast water and are never in contact with fuel, hi a
dirty ballast system, water is added to a fuel tank after most of the fuel is removed.

Thirty Coast Guard vessels generate dirty ballast as a discharge incidental to normal
vessel operations. These Coast Guard vessels do so because then- size and design do not allow
for a sufficient volume of clean ballast tanks. The larger of these vessels discharge the dirty
ballast at distances beyond 12 n.m. from shore, while the smaller vessels discharge the dirty
ballast between 3 and 12 n.m. from shore. Coast Guard vessels monitor the dirty ballast
discharge with an oil content monitor. If the dirty ballast exceeds 15 parts per million (ppm) oil,
it is treated in an oil-water separator prior to discharge.

Expected constituents of dirty ballast are Naval distillate fuel or aviation fuel. Based on
sampling results for compensated fuel ballast, which is expected to have similar constituents to
dirty ballast, this discharge can contain oil (and its constituents such as benzene and toluene);
biocidal fuel additives; metals such as copper, mercury (a bioaccumulative chemical of concern),
nickel, silver, thallium, and zinc; and the constituents 2-propenal, nitrogen (in the form of
ammonia and total Kjeldahl nitrogen), and phosphorus.

Uncontrolled discharges of dirty ballast would be expected to exceed acute Federal
criteria or State acute water quality criteria for oil, benzene,, copper, nickel, phosphorus, 2-
propenal, silver, thallium, and zinc. Concentrations of nitrogen would be expected to exceed the
most stringent State water quality criteria. The use of oil content monitors and oil-water
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separators to reduce the concentration of oil (and associated constituents) demonstrates the
availability of MPCDs to control this discharge. Therefore, EPA and DoD have determined that
it is reasonable and practicable to require the use of MPCDs to control discharges of dirty ballast.

5.1.9 Distillation and Reverse Osmosis Brine

This intermittent discharge is the concentrated seawater (brine) produced as a byproduct
of the processes used to generate freshwater from seawater.

Distillation and reverse osmosis plants are two types of water purification systems that
generate freshwater from seawater for a variety of shipboard applications, including potable
water for drinking and hotel services, and high-purity feedwater for boilers. Distillation plants
boil seawater, and the resulting steam is condensed into high-purity distilled water. The
remaining seawater concentrate, or "brine," that is not evaporated is discharged overboard.
Reverse osmosis systems separate freshwater from seawater using semi-permeable membranes as
a physical barrier, allowing a portion of the seawater to pass through the membrane as freshwater
and concentrating the suspended and dissolved constituents in a saltwater brine that is
subsequently discharged overboard.

Distillation or reverse osmosis systems are installed on approximately 540 Armed Forces
vessels. This discharge can occur in port, while transiting to or from port, or while operating
anywhere at sea (including within 12 n.m.). Distillation plants on steam-powered vessels may be
operated to produce boiler feedwater any time a vessel's boilers are operating; however,
operational policy limits its use in port for producing potable water because of the increased risk
of biofouling from the water in harbors and the reduced demand for potable water. MSC steam-
powered vessels typically operate one evaporator while in port to produce boiler feedwater; most
diesel and gas-turbine powered MSC vessels do not operate water purification systems within 12
n.m.

Pollutants detected in distillation and reverse osmosis brine include copper, iron, lead,
nickel,, and zinc. The sampling data indicate that copper, lead, nickel, iron, and zinc can exceed
acute Federal criteria or State acute water quality criteria. The distillation and reverse osmosis
brine discharge can also contain nitrogen (in the form of ammonia, nitrates and nitrites, and total
Kjeldahl nitrogen) and phosphorus in concentrations exceeding the most stringent State water
quality criteria. The mass loadings of copper and iron are estimated to be significant. Thermal
effects modeling of distillation plant discharges indicates that the thermal plume does not exceed
State water quality criteria.

Review of existing practices indicate that certain operational controls limiting the use of
distillation plants and reverse osmosis units can reduce the potential for this discharge to cause
adverse environmental impacts in some instances. Additionally, it appears that, for some vessels,
reverse osmosis units may present an acceptable alternative to the use of distillation plants.
Reverse osmosis units discharge brines are expected to contain lower concentrations of metals
because these systems have non-metallic membranes and ambient operating temperatures,
resulting in less system corrosion. Further analysis is necessary before determining whether
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distillation plants should be replaced by reverse osmosis units. Nevertheless, existing operational
practices for distillation and reverse osmosis plants and the availability of reverse osmosis units
to replace distillation units on some vessels demonstrates the availability of MPCDs to reduce the
effects of this discharge. Therefore, EPA and DoD have determined that it is reasonable and
practicable to require the use of MPCDs to control discharges from distillation and reverse
osmosis plants.

5.1.10 Elevator Pit Effluent

This discharge is the liquid that accumulates in, and is occasionally discharged from, the
sumps of elevator wells on vessels. Most large surface ships have at least one type of elevator
used to transport supplies, equipment, and personnel between different decks of the vessel.
These elevators generally can be classified as either a closed design in which the elevator
operates in a shaft, or an open design used to move aircraft between decks. Elevators operating
in a shaft are similar to the conventional design seen in many buildings. For these elevators, a
sump is located in the elevator pit to collect liquids entering the elevator and shaft areas. Deck
runoff and elevator equipment maintenance activities are the primary sources of liquids entering
the sump. On some vessels, the elevator sump is equipped with a drain to direct liquid wastes
overboard. On others, piping is installed that allows an eductor to pump the pit effluent
overboard. However, most vessels collect and containerize the pit effluent for disposal onshore
or process it along with their bilgewater.

The elevators used on aircraft carriers to move aircraft and helicopters from one deck to
another are an open design (i.e., there is no elevator shaft). The elevator platform is supported by
cables and pulleys, and it operates on either the port or starboard side of the ship away from the
hull. Unlike elevators with pits, the aircraft elevators are exposed to the water below and there
are no systems in place for collecting liquid wastes.

Coast Guard, Army and Air Force vessels do not have elevators and therefore do not
produce this discharge. The discharge of elevator pit effluent may occur at any location, within
or beyond 12 n.m. from shore. Constituents in elevator pit effluent are likely to include grease,
lubricating oil, fuel, hydraulic fluid, cleaning solvents, dirt, paint chips, aqueous film-forming
foam, glycol, and sodium metasilicate. The discharge can also contain nitrogen (measured as
total Kjeldahl nitrogen) and metals from firemain water used to operate eductors draining the
elevator pit.

The concentrations of copper, iron, nickel, and bis(2-ethylhexyl)phthalate in firemain
water (discussed hi section 5.1.11) may exceed acute Federal criteria or State acute water quality
criteria. The elevator pit effluent discharge can also contain nitrogen hi concentrations
exceeding the most stringent State water quality criteria. Constituent concentrations and mass
loadings vary among ship classes depending on the frequency of elevator use, the size of the
elevator openings, the amount and concentration of deck runoff, and the frequency of elevator
equipment maintenance activities. Material accumulated hi elevator pits is either collected for
disposal onshore or directed to the bilgewater system for treatment through an oil-water separator
prior to discharge. These existing practices demonstrate the availability of controls to reduce the
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potential for this discharge to cause adverse impacts on the environment. Therefore, EPA and
DoD have determined that it is reasonable and practicable to require MPCDs for elevator pit
effluent.

5.1.11 Firemain Systems

This discharge is the seawater pumped through the firemain system for firemain testing,
maintenance, and training, and to supply water for the operation of certain vessel systems.

Firemain systems distribute seawater for firefighting and other services aboard ship.
Firemain water is provided for firefighting through fire hose stations, sprinkler systems, and
foam proportioned, which inject aqueous film-forming foam (AFFF) into firemain water for
distribution over flammable liquid spills or fire. Firemain water is also directed to other services
including ballast systems, machinery cooling, lubrication, and anchor chain washdown.
Discharges of firemain water incidental to normal vessel operations include anchor chain
washdown, firemain testing, various maintenance and training activities, bypass flow from the
firemain pumps to prevent overheating, and cooling of auxiliary machinery equipment (e.g.,
refrigeration plants). UNDS does not apply to discharges of firemain water that occur during
firefighting or other shipboard emergency situations, because they are not incidental to the
normal operation of a vessel.
. iL ' '
Firemain systems aboard Armed Forces vessels are classified as either wet or dry. Wet .
firemain systems are continuously charged with water and pressurized so that the system is
available to provide water upon demand. Dry firemains are not continuously charged with water,
and consequently do not supply water upon demand. Dry firemain systems are periodically
tested and are pressurized during maintenance or training exercises, or during emergencies.

With the exception of small boats and craft, all Armed Forces vessels use firemain
systems. All Navy surface ships and some MSC vessels use wet firemain systems. Submarines
and all Army and Coast Guard vessels use dry firemains. Firemain system discharges occur both
within and beyond 12 n.m. from shore. Flow rates depend upon the type, number, and operating
time of the equipment and systems using water from the firemain system.

Samples were collected from three vessels with wet firemain systems and analyzed to
determine the constituents present. Because of longer contact times between seawater and the
piping in wet firemains, and the use of zinc anodes in some seachests and heat exchangers to
control corrosion, pollutant concentrations in wet firemains are expected to be higher than those
in dry firemain systems. Pollutants detected in the firemain discharge include nitrogen
(measured as total Kjeldahl nitrogen), copper, nickel, iron, and bis(2-ethylhexyl)phthalate. The
concentrations of iron exceeded the most stringent State chronic water quality criteria. The
concentrations of nitrogen exceeded the most stringent State water quality criteria. Copper,
nickel, and bis(2-ethylhexyl)phthalate concentrations exceeded the relevant chronic Federal
criteria and State chronic water quality criteria. These concentrations contribute to a significant
total mass loading in the discharge due to the large volume of water discharged from wet
firemain systems. Circulation through heat exchangers to cool auxiliary machinery increases the
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temperature of the firemain water, but the resulting thermal effects do not exceed State mixing
zone criteria.

Firemain systems have a low potential for transporting nonindigenous aquatic species,
primarily because the systems do not transport large volumes of water over great distances. In
addition, stagnant portions of the firemain tend to develop anaerobic conditions that are
inhospitable to most marine organisms.

EPA and DoD believe that dry firemain systems may offer one means for reducing the
total mass of pollutants discharged from firemain systems. The use of dry firemains for Coast
Guard vessels demonstrates that, for at least some types of vessels, this option may be an
available control mechanism. Another possible MPCD option for achieving pollutant reductions
is the use of alternative piping systems (i.e., different metallurgy) that provide lower rates of pipe
wall corrosion and erosion. The use of dry firemains and the potential offered by alternative
piping systems demonstrates the availability of controls to mitigate potential adverse impacts on
the environment. Therefore, EPA and DoD have determined that it is reasonable and practicable
to require the use of a MPCD for firemain systems.

5.1.12 Gas Turbine Water Wash

Gas turbine water wash consists of water periodically discharged while cleaning internal
and external components of propulsion and auxiliary gas turbines. Approximately 155 Armed
Forces vessels use gas turbines for either propulsion or auxiliary power generation. Gas turbine
water wash is generated within 12 n.m. and varies by the type of gas turbine and the amount of
time it is operated. Because the dram collecting system is limited in size, discharges may occur
within 12 n.m. On most Navy and MSC gas turbine ships, gas turbine water wash is collected in
a dedicated collection tank and is not discharged overboard within 12 n.m. On ships without a
dedicated collection tank, this discharge is released as a component of deck runoff, welldeck
discharges, or bilgewater.

Expected constituents of gas turbine water wash are synthetic lubricating oil, grease,
solvent-based cleaning products, hydrocarbon combustion by-products, salts from the marine
environment, and metals leached from metallic turbine surfaces. The concentration of
naphthalene (from solvents) in the discharge is expected to exceed State acute water quality
criteria. To limit the impacts of gas turbine water wash discharge while operating in coastal
areas, most vessels direct the discharge to a dedicated holding tank for shore disposal. This
containment procedure demonstrates the availability of controls for this discharge. Therefore,
EPA and DoD have determined that it is reasonable and practicable to require the use of a MPCD
for gas turbine water wash.

5.1.13 Graywater

Section 312(a)(l 1) of the CWA defines graywater as "galley, bath, and shower water."
Recognizing the physical constraints of Armed Forces vessels and the manner in which
wastewater is handled on these vessels, graywater is more broadly defined for the purposes of
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UNDS. For the purposes of this regulation, the graywater discharge consists of graywater as
defined in CWA section 312(a)(l 1), as well as drainage from laundries, interior deck drains,
water fountains and miscellaneous shop sinks. All ships, and some small boats, of the Armed
Forces generate graywater on an intermittent basis. Graywater discharges occur both within and
beyond 12 n.m. from shore. Most Armed Forces vessels collect graywater and transfer it to shore
treatment facilities while pierside. Some vessel types, however, have minimal or no graywater
collection or holding capability and discharge the graywater directly overboard while in transit.
Graywater is discharged pierside when collection facilities are not available.

Less than half of all graywater discharged within 12 n.m. occurs pierside from vessels
lacking graywater collection holding capability. The remainder of the discharge in coastal waters
occurs during transit within 12 n.m. from shore. Copper, lead, mercury (a bioaccumulative
chemical of concern), nickel, silver, and zinc were detected hi concentrations that exceed acute
Federal criteria and State acute water quality criteria. Graywater also contains conventional and
nonconventional pollutants, such as total suspended solids, biochemical oxygen demand,
chemical oxygen demand, oil, grease, ammonia, nitrogen, and phosphates. Due to the large
volume of graywater generated each year, the mass loadings of these constituents may be
significant. The use of containment systems to transfer graywater to shore treatment facilities
demonstrates the availability of controls to mitigate adverse impacts on the environment.
Therefore, EPA and DoD have determined that it is reasonable and practicable to require a
MPCD to control graywater discharges.

5.1.14 Hull Coating Leachate

This discharge consists of constituents that leach, dissolve, ablate, or erode from hull
paints into the surrounding seawater.

Vessel hulls that are continuously exposed to seawater are typically coated with a base
anti-corrosive coating covered by an anti-fouling coating. This coating system prevents
corrosion of the underwater hull structure and, through leaching action releases antifouling
compounds. Ablative coatings allow the paint surface to erode or dissolve to release antifouling
compounds. These compounds inhibit the adhesion of biological growth to the hull surface.

The coatings on most vessels of the Armed Forces are either copper- or tributyl tin
(TBT)-based, with copper-based ablative paints being the most predominant coating system. The
Armed Forces have been phasing out the use of TBT paints, and currently it is found only on
approximately 10-20 percent of small boats and craft with aluminum hulls. Small boats and craft
that spend most of their tune out of water typically do not receive an anti-corrosive or anti-
fouling coating.

Hull coating leachate is generated continuously whenever a vessel hull is exposed to
water, within and beyond 12 n.m. from shore. Priority pollutants expected to be present in this
discharge include copper and zinc. TBT is also expected to be present in this discharge for those
vessels with TBT paint. The release rate of the constituents in hull coating leachate varies with
the type of paint used, water temperature, vessel speed, and the age of the coating. Using average
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release rates derived from laboratory tests, the wetted surface area of each vessel, and the number
of days the vessel is located within 12 n.m., EPA and DoD estimated the mass of copper, zinc,
and TBT released in the leachate and concluded that the discharge has the potential to cause an
adverse environmental effect.

Annual releases of TBT are expected to decrease since TBT coatings are being phased out
by DoD and the Coast Guard. Both DoD and the commercial industry have conducted research
on the use of advanced antifouling coatings such as easy release coatings (e.g., silicone) that
resist biofouling when the vessel is in motion and a critical speed is reached. The combination of
phasing out TBT paints, the potential to establish limits on copper release rates for copper-based
coating systems, and the potential for alternative coating systems to reduce copper discharges
demonstrates the availability of controls to mitigate potential environmental impacts from hull
coating leachate. Thus, EPA and DoD determined that it is reasonable and practicable to require
use of a MPCD for hull coating leachate.

5.1.15 Motor Gasoline Compensating Discharge

This intermittent discharge consists of seawater taken into, and discharged from, motor
gasoline tanks. Motor gasoline (MOGAS) is used to operate vehicles and equipment stored or
transported on some Navy amphibious vessels. MOGAS is stored in a compensating fuel tank
system in which seawater is automatically added to fuel tanks as the gasoline is consumed in
order to eliminate free space where vapors could accumulate. The compensating system is used
for MOGAS to provide supply pressure for the gasoline and to keep the tank full to prevent
potentially explosive gasoline vapors from forming. During refueling, gasoline displaces
seawater from the tanks, and the displaced seawater is discharged directly overboard.

The Navy has two classes of vessels with MOGAS storage tanks. Eleven of these vessels
are homeported in the U.S. Based on operational practices, vessels with MOGAS storage tanks
typically refuel once per year, and the refuelings are always conducted in port. Therefore, all
discharges from the MOGAS compensating system occur in port.

Seawater in the MOGAS compensating system is in contact with the gasoline for long
periods of time. MOGAS discharges are expected to contain components of gasoline, including
benzene, ethylbenzene, toluene, phenols, and naphthalenes at concentrations that exceed acute
water quality criteria.

Specific operating procedures are followed when refueling MOGAS tanks to reduce the
potential for discharging gasoline. These procedures require MOGAS tanks to be filled slowly
and prohibit filling the tanks beyond 80 percent of the total tank capacity. Containment is placed
around hose connections to contain any releases of gasoline, and containment booms are placed
in the water around the vessel being refueled. Diffusers are used within the tanks to prevent
entraining fuel into the discharged compensating water. These management practices
demonstrate the availability of controls to mitigate potential adverse impacts to the environment.
Therefore, EPA and DoD have determined that it is reasonable and practicable to require MPCDs
for the MOGAS compensating discharge.
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5.1.16 Non-Oily Machinery Wastewater

This intermittent discharge is composed of water leakage from the operation of
equipment such as distillation plants, water chillers, valve packings, water piping, low- and high-
pressure air compressors, and propulsion engine jacket coolers. Only wastewater that is not
expected to contain oil is collected in this system. The discharge is captured in a dedicated
system of drip pans, funnels, and deck drains to prevent mixing with oily bilgewater. Non-oily
machinery wastewater from systems and equipment located above the waterline is drained
directly overboard. Non-oily machinery wastewater from systems and equipment below the
waterline is directed to collection tanks prior to overboard discharge. In limited cases, steam
condensate generated when a vessel is hi port is directed to the non-oily machinery wastewater
collection tank. See section 5.2.10 for additional information on steam condensate discharges.

Nuclear-powered Navy surface vessels and some conventionally powered vessels have
dedicated non-oily machinery wastewater systems. Most other Armed Forces vessels have no
dedicated non-oily machinery wastewater system, so this type of wastewater drains directly to the
bilge and is part of the bilgewater discharge.

Non-oily machinery wastewater is discharged in port, during transit, and at sea. This
discharge is generated whenever systems or equipment are hi use, and varies in volume according
to ship size and the level of machinery use.

Pollutants, including copper, nickel, silver, bis(2-ethylhexyl)phthalate, and zinc were
present in concentrations that exceed acute Federal criteria or State acute water quality criteria.
Nitrogen (in the form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen) and total
phosphorus were present in concentrations exceeding the most stringent State water quality
criteria. Mercury (a bioaccumulative chemical of concern) was also detected, but at
concentrations that did not exceed Federal or State water quality criteria. There was significant
variability in sampling data, and flow rate data were insufficient for reliably estimating mass
loadings for this discharge. System design changes to control the types and numbers of
contributing systems and equipment, and implementation of management practices to reduce the
generation of non-oily machinery wastewater are potential options for reducing the potential
impact of this discharge on the environment. For this rule, EPA and DoD have determined that
it is reasonable and practicable to require MPCDs for non-oily machinery wastewater.

5.1.17 Photographic Laboratory Drains

This intermittent discharge is laboratory wastewater resulting from processing
photographic film. Typical liquid wastes from these activities include spent film processing
chemical developers, fixer-bath solutions and film rinse water.

Navy ship classes such as aircraft carriers, amphibious assault ships, and submarine
tenders have photographic laboratory facilities, including color, black-and-white and x-ray
photographic processors. The Coast Guard has two icebreakers with photographic and x-ray
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processing capabilities. The MSC has two vessels that have photographic processing equipment
onboard, but the equipment normally is not operated in U.S. waters. Army, Air Force, and
Marine Corps vessels do not use photographic equipment aboard their vessels and therefore dp
not produce this discharge.

Photographic laboratory wastes may be generated within and beyond 12 n.m. from shore,
although current practice is to collect and hold the waste onboard within 12 n.m. The volume
and frequency of the waste generation varies with a vessel's photographic processing capabilities,
equipment, and operational objectives.

Expected constituents in photographic laboratory wastes include acetic acid, aluminum
sulfate, ammonia, boric acid, ethylene glycol, sulfuric acid, sodium acetate, sodium chloride,
ammonium bromide, aluminum sulfate, and silver. Concentrations of silver can exceed acute
Federal criteria and State acute water quality criteria; however, the existing data are insufficient
to determine whether drainage from shipboard photographic laboratories has the potential to
cause adverse environmental effects.

The Navy has adopted guidance to control photographic laboratory drains, including
containerizing for onshore disposal all photographic processing wastes generated within 12 n.m.,
and is transitioning to digital photographic systems. The current handling practices and the
availability of digital photographic systems demonstrates that MPCDs are available to mitigate
potential adverse effects, if any, from photographic laboratory drains. Therefore, EPA and DoD
have determined that it is reasonable and practicable to require use of a MPCD for this discharge.

5.1.18 Seawater Cooling Overboard Discharge

This discharge consists of seawater from a dedicated system that provides noncontact
cooling water for other vessel systems. The seawater cooling system continuously provides
cooling water to heat exchangers, removing heat from main propulsion machinery, electrical
generating plants, and other auxiliary equipment. The heated seawater is discharged directly
overboard. With the exception of some small, non-self-propelled vessels and service craft, all
Armed Forces vessels discharge seawater from cooling systems. Typically, the demand for
seawater cooling is continuous and occurs both within and beyond 12 n.m. from shore.

Seawater cooling overboard discharge contains trace materials from seawater cooling
system pipes, valves, seachests, pumps, and heat exchangers. Pollutants detected in seawater
cooling overboard discharge include copper, zinc, nickel, arsenic, chromium, lead, and nitrogen
(in the form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen). Copper, nickel, and
silver were detected in concentrations exceeding both the chronic Federal criteria and State
chronic water quality criteria. Nitrogen was detected in concentrations exceeding State chronic
water quality criteria. These concentrations contribute to a significant total mass released by this
discharge due to the large volume of cooling water, hi addition, thermal effects modeling
indicates that some vessels may exceed State thermal mixing zone requirements. The seawater
cooling water system has a low potential for transporting nonindigenous species, because the
residence time for most portions of the system are short. However, a strainer plate is used to
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minimize the inflow of larger biota during system operation. The strainer plate is periodically
cleaned using low pressure air or steam to dislodge any accumulated material. This procedure
may result in releasing biota that have attached to the plate.

A potential MPCD option for achieving pollutant reductions is the use of alternative
piping systems (i.e., different metallurgy) that provide lower rates of pipe wall corrosion and
erosion. The potential substitution of materials demonstrates the availability of controls to
mitigate potential adverse impacts on the environment. Based on this information, EPA and
DoD have determined that it is reasonable and practicable to require use of a MPCD for this
discharge.

5.1.19 Seawater Piping Biofouling Prevention

This discharge consists of the additives used to prevent the growth and attachment of.
biofouling organisms hi seawater cooling systems on selected vessels, as well as the reaction
byproducts resulting from the use of these additives. Fouling reduces seawater flow and heat
transfer efficiency. Aboard some vessels, active biofouling control systems are used to control
biological fouling of surfaces within the seawater cooling systems. Generally, these active
biofouling control systems are used when the cooling system piping does not have inherent
antifbuling properties (e.g., titanium piping). The most common seawater piping biofouling
prevention systems include chlorination, chemical dosing, and anodic biofouling control systems.
All three systems act to prevent fouling organisms from adhering to and growing on interior
piping and components. Chlorinators use electric current to generate chlorine and chlorine-
produced oxidants from seawater. Anodic biofouling control systems use electric current to
accelerate the dissolving of an anode to release metal ions into the piping system. Chemical
dosing uses an alcohol-based chemical dispersant that is intermittently injected into the seawater
system.

Twenty-nine Armed Forces vessels use active seawater piping biofouling control systems.
Nine vessels use onboard chlorinators, 19 vessels use anodic biofouling control systems, and one
vessel employs chemical dosing. Chlorinators operate on a preset schedule of intermittent
operation, a few hours daily. Chemical dispersant dosing is performed for one hour every three
days. Anodic systems normally operate continuously.

Seawater discharged from systems with active biofouling control systems is likely to
contain residuals from the fouling control agent (chlorine, alcohol-based chemical additives, or
copper), in addition to constituents normally found in cooling water. Based on modeling of the
discharge plume, EPA and DoD estimate that receiving water concentrations of residual chlorine
could exceed chronic Federal criteria and State chronic water quality criteria. Because of the
large volume of seawater discharged from these systems, the resulting mass loading of chlorine
released to the environment is considered significant.

Existing operational controls that limit the residual chlorine discharged to the
environment demonstrate the availability of a MPCD to mitigate the potential for adverse
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impacts from this discharge. EPA and DoD have determined that it is reasonable and practicable
to require a MPCD for seawater piping biofouling prevention systems.

5.1.20 Small Boat Engine Wet Exhaust

This discharge is the seawater that is mixed and discharged with small boat propulsion
engine exhaust gases to cool the exhaust and quiet the engine. Small boats are powered by either
inboard or outboard engines. Seawater is injected into the exhaust of these engines for cooling
and to quiet engine operation. Constituents from the engine exhaust are transferred to the
injected seawater and discharged overboard as wet exhaust.

Most small boats with engines generate this discharge. The majority of inboard engines
used on small boats are two-stroke engines that use diesel fuel. The majority of outboard engines
are two-stroke engines that use a gasoline-oil mixture for fuel. This discharge is generated when
operating small boats. Due to their limited range and mission, small boats spend the majority of
their operating time within 12 n.m. from shore.

Wet exhaust from outboard engines contains several constituents that can exceed acute
Federal criteria or State acute water quality criteria including benzene, toluene, ethylbenzene, and
naphthalene. Wet exhaust from inboard engines can contain benzene, ethylbenzene, and total
polycyclic aromatic hydrocarbons (PAHs) that can exceed State water quality criteria. Mass
loadings of these wet exhaust constituents are considered large. Potential MPCD options include
replacing existing outboard engines with new reduced-emission outboard engines, and ensuring
all new boats and craft have inboard engines with dry exhaust systems. Therefore, EPA and DoD
have determined that it is reasonable and practicable to require use of a MPCD for small boat
engine wet exhaust.

5.1.21 Sonar Dome Discharge

This discharge is generated by the leaching of antifoulant materials from the sonar dome
material into the surrounding seawater and the discharge of seawater or freshwater from within
the sonar dome during maintenance activities. Hull-mounted sonar domes house the electronic
equipment used to navigate, detect, and determine the range to objects. Sonar domes are
composed of either rubber impregnated with tributyltin (TBT) anti-foulant, rubber without TBT,
steel, or glass-reinforced plastic, and are filled with freshwater and/or seawater to maintain their
shape and internal pressure. The discharge is generated when materials leach from the exterior
surface of the dome, or when water containing leach materials from inside the dome is pumped
overboard to allow for periodic maintenance or repairs on the sonar dome or equipment housed
inside the dome.

Only Navy and MSC operate vessels with sonar domes. Sonar domes are currently
installed on approximately 225 vessels, including eight classes of Navy vessels and one class of
MSC vessels. Sonar domes on MSC vessels are fiberglass and do not contain TBT.
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The leaching of materials from the exterior surface of the dome is a continuous discharge
and occurs both within and beyond 12 n.m. from shore. Discharges from the interior of the dome
are intermittent and occur while the vessel is pierside as water inside the dome is removed to
allow for periodic maintenance or repairs (approximately twice per year per dome).

Expected constituents of sonar dome water discharge are TBT, dibutyl tin, monobutyl tin,
and metals such as copper, nickel, zinc, and tin. Based on sampling data in the record,
concentrations of TBT, copper, nickel, and zinc can exceed acute Federal criteria or State acute
water quality criteria, although fleetwide mass loadings of these constituents are not considered
large (15 pounds/year of TBT, 23 pounds/year of copper, 11 pounds/year of nickel, and 122
pounds/year of zinc). Nevertheless, the Navy has instituted a program to install new sonar domes
that do not have TBT-impregnated internal surfaces as existing domes require replacement. This
practice demonstrates the availability of a control to mitigate potential adverse environmental
impacts, if any, from sonar dome discharges. Therefore EPA and DoD have determined that it is
reasonable and practicable to require a MPCD for sonar dome discharges.

5.1.22 Submarine Bilgewater

The submarine bilgewater discharge contains a mixture of wastewater and leakage from a
variety of sources that are allowed to drain to the lowest inner part of the hull, known as the
bilge. These sources can include condensed steam from steam systems, spillage from drinking
fountains, valve and piping leaks, and evaporator dumps (i.e., evaporator water that fails to meet
specifications for use). From the various collection points in the bilge, this bilgewater is
transferred via an auxiliary drain system to a series of holding tanks. Most submarines have the
capability to segregate oily wastewater from non-oily wastewater. The non-oily waste is
discharged directly overboard and the oily wastewater is collected in a tank that allows gravity
separation of the oil and water. The separated water phase is then discharged overboard, as
needed, and the oil phase held onboard until it can be transferred to shore facilities for disposal.

This discharge is generated by all submarines, all of which are operated by the Navy.
Approximately 60 of the submarines (the SSN 688 class) discharge the separated water phase
from the bilgewater collection tanks within and beyond 12 n.m. from shore. The remaining
submarines generally hold all bilgewater onboard until they are beyond 50 n.m. from shore. The
frequency and volume of the discharge is highly variable, depending upon crew size, operating
depth, and equipment conditions.

Sampling conducted onboard submarines showed concentrations of cadmium, chlorine,
copper, cyanide, heptachlor, heptachlor epoxide, mercury (a bioaccumulative chemical of
concern), nickel, oil, phenol, silver, and zinc that exceeded acute Federal criteria or State acute
water quality criteria. Submarines use gravity separation to reduce the concentration of oil in
bilgewater prior to discharge; however, this method apparently does not consistently produce a
discharge that meets water quality criteria. The adequacy of existing gravity separation treatment
to provide effective environmental protection will be addressed by the Phase n rulemaking. The
nature of this discharge is such that submarine bilgewater, if untreated, could potentially impact
the environment. Because of this potential to cause adverse environmental impacts, coupled with
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the demonstration that pollution controls are available to reduce the oil content of the discharge,
EPA and DoD have determined that it is reasonable and practicable to require the use of a MPCD
for submarine bilgewater.

5.1.23 Surface Vessel Bilgewater/OWS Discharge

The Surface Vessel Bilgewater/OWS Discharge consists of a mixture of wastewater and
leakage from a variety of sources that are allowed to drain to the lowest inner part of the hull,
known as the bilge. The sources of surface vessel bilgewater are generally similar to those
discussed above for submarines. An additional source of bilgewater for surface vessels is water
from the continual blowdown of boilers (i.e., boiler blowdown). On surface vessels, bilgewater
is usually transferred to an oily waste holding tank, where it is stored for shore disposal or treated
in an oil-water separator (OWS) to remove oil before being discharged overboard: Some vessels
also have an oil content monitor (OCM) installed downstream from the OWS to monitor
bilgewater oil content prior to discharge. Vessels with OCMs have the capability to return
bilgewater not meeting a preset oil concentration limit to the OWS for reprocessing until the
limit is met. Oil collected from the OWS separation process is held in a waste oil tank until
transferred to shore facilities for disposal.

All vessels of the Armed Forces produce bilgewater and most of the larger vessels have
OWS systems. Small craft bilgewater is collected and transferred to shore facilities while
pierside.

Bilgewater accumulates continuously; however, vessels of the Armed Forces do not
discharge untreated bilgewater. Under current policy, bilgewater treated by an OWS can be
discharged as needed within 12 n.m., while untreated bilgewater is held for transfer to a shore
facility for treatment. For vessels with an OWS and OCM, oil concentrations in the "treated
bilgewater must be less than 15 ppm prior to overboard discharge.

Sampling data for OWS effluent show oil, copper, iron, mercury (a bioaccumulative
chemical of concern), nickel, and zinc exceed acute Federal criteria or State acute water quality
criteria. Sampling data also show concentrations of nitrogen (in the form of ammonia, nitrates
and nitrites, and total Kjeldahl nitrogen) and phosphorus exceed the most stringent State water
quality criteria. The estimated mass loading for oil is considered to be large.

The existing policies prohibiting the discharge of untreated bilgewater, and the extensive
use of oil-water separators and oil content monitors demonstrate the availability of pollution
controls for bilgewater. The data in the record indicate that untreated bilgewater would likely
cause adverse environmental impacts. Therefore, EPA and DoD have determined that it is
reasonable and practicable to require the use of a MPCD for this discharge.

5.1.24 Underwater Ship Husbandry

The underwater ship husbandry discharge is composed of materials discharged during the
inspection, maintenance, cleaning, and repair of hulls and hull appendages performed while the
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vessel is waterborne. Underwater ship husbandry includes activities such as hull cleaning,
fiberglass repair, welding, sonar dome repair, propulsor lay-up, non-destructive testing, masker
belt repairs, and painting operations.

Underwater ship husbandry discharge is created occasionally by all Navy surface ships
and submarines, and some Coast Guard vessels. These ship husbandry operations are normally
conducted pierside. With the exception of underwater hull cleaning and propulsor (i.e.,
propeller) lay-up, other ship husbandry discharges have a low potential for causing an adverse
environmental effect. Underwater hull cleaning is conducted by divers using a mechanical brush
system. Gopper and zinc are released during cleaning in concentrations that exceed acute Federal
criteria and State acute water quality criteria and produce a significant mass loading of
constituents. The copper and zinc in this discharge originate from the anti-fouling and
anticorrosive hull coatings applied to vessels. Data from commercial vessels indicate that
underwater hull cleaning also has the potential to transfer nonindigenous aquatic species.
Propulsor lay-up requires the placement of a vinyl cover over the propulsor to reduce fouling of
the propulsor when the vessel is in port for extended periods. Chlorine-produced oxidants are
generated from impressed current cathodic protection systems and can build up within the cover
to levels exceeding State water quality criteria. However, discharges from this operation, as well
as other ship husbandry operations (excluding hull cleaning) are infrequent and small in terms of
volume or mass loading.

The Navy has established policies to minimize the number of hull cleanings, based on the
degree to which biological fouling has occurred. In addition, the Navy has established
procedures to use the least abrasive cleaning equipment necessary as a means for reducing the
mass of copper and zinc in the discharge. These practices represent available controls to mitigate
adverse impacts from underwater ship husbandry operations, and EPA and DoD have determined
that it is reasonable and practicable to require the use of a MPCD to control this discharge.

5.1.25 Welldeck Discharges

This discharge is the water that accumulates from the seawater flooding of the docking
well (welldeck) of a vessel used to transport, load, and unload amphibious vessels, and from the
maintenance and freshwater washings of the welldeck and equipment and vessels stored in the
welldeck.

Amphibious operations by the Armed Forces require transport of vehicles, equipment,
and personnel between ship and shore on landing craft. The landing craft are stored in a docking
well, or welldeck, of some classes of amphibious warfare ships. To load or unload landing craft,
amphibious warfare ships may need to flood the welldeck by taking on ballast water and sinking
the aft (rear) end of the ship. Water that washes out of the welldeck contains residual materials
that were on the welldeck prior to flooding. Other welldeck discharges are created by routine
operations such as washing equipment and vehicles with potable water, washing the gas turbine
engines of air-cushion landing craft (LCACs) in the welldeck with mild detergents, and
graywater from stored utility landing craft (LCUs). Additionally, the U.S. Department of
Agriculture (USD A) requires washing welldecks, vehicle storage areas, and equipment upon
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return from overseas locations. The washing is required to ensure that there is no inadvertent
transport of nonindigenous species to land. USDA-required washes of welldecks and vehicle
storage areas occur pierside, while vehicles and equipment are washed onshore in a USD A-
designated area. Effluent from such shipboard activities drain to unflooded welldecks and are
discharged directly overboard.

The Navy is the only branch of the Armed Forces with ships having welldecks. Thirty-
three amphibious warfare ships produce this discharge, which is released both within and beyond
12 n.m. from shore.

Depending upon the specific activities conducted, welldeck discharges contain a variety
of residual constituents, including oil and grease, ethylene glycol (antifreeze), chlorine,
detergents/cleaners, metals, solvents, and sea-salt residues. The volume of welldeck washout
varies depending upon the type of landing craft to be loaded or unloaded. The greatest volume of
welldeck discharge occurs when LCUs are being loaded into, or unloaded from the welldeck.
Loading and unloading of LCACs does not require the welldeck to be flooded. Instead, a small
"surge" of water enters the ship during these operations. Constituent concentrations in welldeck
washout are expected to be low due to dilution in the large volume of water discharged, and
because of general housekeeping procedures that require containment and cleanup of materials
spilled on the welldeck.

Other discharges from the welldeck include vehicle and craft washwater, gas turbine
engine washes, and USD A washes. Constituents of these discharges are expected to be identical
to those in welldeck washout. Of the various welldeck discharges, gas turbine water washes and
USDA washes may result in hydrocarbon, or metal concentrations that exceed acute water quality
criteria. In addition, there is a potential for nonindigenous species to be introduced from USDA-
required welldeck washes, although it should be noted that the viability of any species introduced
is questionable since they generally would have been exposed to air for extended periods of time
prior to their introduction into U.S. coastal waters (i.e., for the most part, these species would
have been removed from vehicles and deck surfaces and thus it would not be a water-to-water
transfer, in contrast to species transfers from ballast water systems).

Existing practices for containment and cleanup of welldeck spills demonstrate the
availability of controls to reduce contamination of welldeck discharges and the potential for
causing adverse environmental impacts (e.g., oil sheens). EPA and DoD have determined that it
is reasonable and practicable to require a MPCD for welldeck discharges.
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5.2 Discharges Determined To Not Require MPCDs

For the reasons discussed below, EPA and DoD have determined that it is not reasonable
and practicable to require the use of a MPCD to control 14 discharges incidental to the normal
operation of Armed Forces vessels. These discharges have a low potential to adversely affect the
environment by introduction of chemical constituents, thermal pollution, bioaccumulative
chemicals of concern, or nonindigenous species.

As discussed below, in some cases, the concentration of one or more constituents in the
undiluted discharge exceed water quality criteria at the point of discharge. However, such
discharges occur in low volumes or infrequently. In all of these instances, either the pollutant
concentration in the discharge plume quickly falls below water quality criteria once the dilution
effect of mixing zones is taken into account, or the low mass loading of the discharge is unlikely
to adversely affect the environment.

These 14 discharge types do not require control, and no control standards will be set for
them, hi Phase n of UNDS development. Upon promulgation of this Phase I rule, States and
then: political subdivisions are prohibited from adopting or enforcing any statute or regulation to
control these discharges, except by establishing no-discharge zones. States can petition EPA and
DoD to review the determination not to require MPCDs for these discharges.

The discussion below provides a brief description of the discharges and the systems that
produce the discharge and highlights the most significant constituents released to the
environment and other characteristics of the discharge. A more detailed discussion of these
discharges is presented in Appendix A.

5.2.1 Boiler Slowdown

This discharge is the water and steam discharged during the blowdown of a boiler or
steam generator, or when a safety valve is tested. Boilers are used to produce steam for
propulsion and a variety of auxiliary and hotel services. Water supplied to the boiler system
(feedwater) is treated with chemicals to inhibit corrosion and the formation of scale in the boiler
and boiler system piping. Periodically, water must be removed from the boiler to control the
buildup of particulates, sludge, and treatment chemical concentrations. The term "blowdown"
refers to the minimum discharge of boiler water required to prevent the buildup of these materials
in the boiler to levels that would adversely affect boiler operation and maintenance. There are
four types of boiler blowdown procedures employed on Armed Forces vessels: 1) surface
blowdowns for removing materials dissolved in the boiler water and for controlling boiler water
chemistry; 2) scum blowdowns for removing surface scum; 3) bottom blowdowns for removing
sludge that settles at the bottom of boilers; and 4) continuous blowdowns for removing dissolved
metal chelates and other suspended matter. The type of blowdown used is a function of the
boiler water chemistry and thus varies among vessel classes. With the exception of continuous
blowdowns, boiler blowdowns are discharged below the vessel waterline. Continuous
blowdowns are discharged inside the vessel and are directed to the bilge. These are addressed as
part of the surface vessel bilgewater/OWS discharge (see section 5.1.23). Another discharge
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occurs during periodic testing of steam generator safety valves on nuclear-powered vessels. The
safety valve discharge is a short-duration release of steam below the vessel waterline.

Approximately 360 surface vessels and submarines discharge boiler blowdowns directly
to receiving waters. These blowdowns occur both within and beyond 12 n.m. from shore.
Nuclear-powered ships perform steam generator safety valve testing only in port once every five
years.

Boiler blowdown is discharged intermittently in small volumes (approximately 300
gallons per discharge), at high velocities (over 400 feet/second), and at elevated temperatures
(over 325 degrees Fahrenheit). Boiler water treatment chemicals used by Armed Forces vessels
include ethylenediamine-tetraacetic acid (EDTA), hydrazine, sodium hydroxide, and disodium
phosphate. Sampling data for boiler blowdowns indicate the presence of nitrogen (in the form of
ammonia, nitrates and nitrites, and total Kjeldahl nitrogen), phosphorus, hydrazine, iron, bis(2-
ethylhexyl)phthalate, copper, lead, nickel, and zinc. Boiler blowdown discharges from
conventionally powered boilers can exceed Federal criteria or State water quality criteria for
copper, iron, lead, nickel, zinc, bis(2-ethylhexyl)phthalate, nitrogen (in the form of ammonia,
nitrates and nitrites, and total Kjeldahl nitrogen) and phosphorus. Blowdown discharges from
nuclear-powered steam generators exceed acute Federal criteria and State acute water quality
criteria for copper, and the most stringent State acute water quality criteria for lead and nickel.
For nitrogen (in the form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen) and
phosphorus, the most stringent State water quality criteria was exceeded. However, the turbulent
mixing resulting from the high velocity discharge, and the relatively small volume of the boiler
blowdown causes pollutant concentrations to rapidly dissipate to background levels or below
acute Federal criteria and State acute water quality criteria within a short distance from the point
of discharge.

Based on thermal modeling of the discharge plume, boiler blowdowns are not expected to
exceed State standards for thermal effects. Thermal effects from safety valve testing are
substantially less than those from blowdowns, thus safety valve testing also will not exceed State
standards for thermal effects.

While the pollutant concentrations in the boiler blowdown discharges exceed acute
Federal criteria and State acute water quality criteria, they are discharged intermittently and in
small volumes. Further, these discharges are distributed throughout the U.S. at Armed Forces
ports, and each individual port receives only a fraction of the total fleetwide mass loading. Based
on the information in the record regarding the low mass of pollutants discharged during boiler
blowdowns and safety valve discharges, and the manner in which the discharges take place, there
is a low potential for causing adverse environmental impacts. Therefore, EPA and DoD have
concluded that it is not reasonable and practicable to require the use of a MPCD to mitigate
adverse impacts on the marine environment for this discharge.
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5.2.2 Catapult Wet Accumulator Discharge

This discharge is the water discharged from a catapult wet accumulator, which stores a
steam/water mixture for launching aircraft from an aircraft carrier.

The steam used as the motive force for operating the catapults for launching aircraft is
provided to the catapult from a steam reservoir, referred to as the catapult wet accumulator. The
catapult wet accumulator is a pressure vessel containing a steam/water mixture at a high
temperature and pressure. The accumulator is fed an initial charge of boiler feedwater and
provided steam from boilers. As steam is released from the accumulator for the catapult launch,
the pressure reduction in the accumulator allows some of the water to flash to steam, providing
additional steam to operate the catapult. During operation of the system, steam condenses in the
accumulator and causes the water level in the accumulator to gradually rise. Periodic blowdowns
of the accumulator are required to maintain the water level within operating limits. This
steam/water mixture released during the blowdown is discharged below the vessel waterline. In
addition to blowdowns required during catapult operation and testing, wet accumulators are
emptied prior to major maintenance of the accumulator or when a carrier will be hi port for more
than 72 hours. When emptying the accumulator, multiple blowdowns are performed over an
extended period (up to 12 hours) to reduce pressure prior to draining the tank.

The Navy is the only branch of the Armed Forces with vessels generating this discharge.
Eleven of the aircraft carriers are homeported hi the United States.

Wet accumulator blowdowns are performed during flight operations, which occur beyond
12 n.m., and during catapult testing, which occurs within 12 n.m. from shore. Wet accumulators
are emptied outside 12 n.m. when returning to port for accumulator maintenance or when the
carrier will be in port for more than 72 hours. If catapult testing is conducted in port, and the
carrier will remain in port for more than 72 hours following the testing, the accumulator will be
emptied in port.

Catapult wet accumulator blowdowns have little potential for causing adverse
environmental impacts because of the low pollutant loadings and thermal effects of this
discharge. Because boiler feedwater is used for the initial charge of water to an empty
accumulator, the constituents of the discharge include water treatment chemicals present in boiler
feedwater. These chemicals include EDTA, disodium phosphate, and hydrazine. During normal
operation, the boiler feedwater chemicals are diluted by the supplied steam. Additional
constituents present in the blowdowns originate from the steam provided to the accumulator.
Based on sampling data for steam condensate (a similar discharge discussed below in section
5.2.10) and the volume of wet accumulator blowdowns performed within 12 n.m., the combined
mass loading for all metals is estimated at less than 0.01 pounds/year. Constituents found in
steam condensate include benzidine, bis(2-ethylhexyl)phthalate, copper, nickel, nitrogen (in the
form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen), and phosphorus. The
concentrations of benzidine, copper, and nickel in steam condensate were found to exceed acute
Federal criteria and State acute water quality criteria. The concentration of bis(2-
ethylhexyl)phthalate was found to exceed State acute water quality criteria. The concentrations
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of nitrogen and phosphorus were found to exceed the most stringent State water quality criteria.
However, using steam condensate data may overestimate wet accumulator pollutant
concentrations because of the shorter contact tune between catapult steam and its associated
piping system (resulting in less opportunity to entrain corrosion products from the piping).
Based on thermal modeling of the discharge plume, catapult wet accumulator blowdowns are not
expected to exceed State standards for thermal effects.

Catapult wet accumulator blowdowns have little potential for causing adverse
environmental impacts because of the very low pollutant mass loadings in this discharge and
because of the low thermal effects from this discharge. Therefore, EPA and DoD determined
that it is not reasonable and practicable to require the use of a MPCD to mitigate adverse impacts
on the marine environment for this discharge.

5.2.3 Cathodic Protection

This discharge consists of the constituents released into the surrounding water from
sacrificial anodes or impressed current cathodic protection systems used to prevent hull
corrosion.

Steel-hulled vessels require corrosion protection. In addition to anti-corrosion hull paints,
these vessels employ cathodic protection which is provided by either sacrificial anodes or
Impressed Current Cathodic Protection (ICCP) systems. The most common cathodic protection
system for vessels of the Armed Forces is the zinc sacrificial anode, although a few submarines
use aluminum anodes. With the sacrificial anode system, zinc or aluminum anodes attached to
the hull will preferentially corrode from exposure to the seawater and thereby minimize corrosion
of the vessel's hull.

hi ICCP systems, the vessel's electrical system passes a current through inert platinum-
coated anodes. This current protects the hull in a manner similar to sacrificial anodes by
generating current as the anodes corrode. Depending on the type of cathodic protection used, the
discharge will include either zinc or aluminum from sacrificial anodes, or chlorine-produced
oxidants (CPO) from ICCP systems. Zinc anodes are approximately 99.3% zinc and contain
small amounts of zinc, silicon, and indium (for activation). Aluminum anodes can contain
0.001% mercury as an impurity; mercury is a known bioaccumulator.

Approximately 2,170 large Armed Forces vessels use cathodic protection. Of these,
nearly 270 have ICCP systems, fewer than five use aluminum sacrificial anodes, and the
remaining use zinc sacrificial anodes. The discharge is continuous while the vessel is waterbome
and occurs both within and beyond 12 n.m. from shore.

EPA and DoD modeled the discharge from cathodic protection systems to determine the
range of constituent concentrations that could be expected in the water surrounding a vessel.
This discharge is best described as a mass flux of reaction byproducts emanating from the
electro-chemical reaction that occurs at the anodes. Two separate modeling techniques were
used for both sacrificial anodes and ICCP systems. The first technique was a dilution model for
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harbors that takes into account the number of homeported vessels and harbor-specific volume
and tidal flow information. Three Navy ports were modeled, representing a range of port sizes.
The resulting constituent concentrations calculated for the three ports in this dilution model were
below chronic Federal criteria and State chronic water quality criteria.

The second technique modeled mixing zones around a vessel using calculations for a hull
size typical of vessels using cathodic protection systems. The mixing model results indicate that
a mixing zone of five feet for CPO and 0.5 feet for zinc results in concentrations below the
chronic Federal criteria or State chronic water quality criteria. For vessels with aluminum
anodes, a mixing zone of less than 0.1 feet achieves concentrations below chronic Federal criteria
and State chronic water quality criteria. Concentrations of mercury will be 1,000 times lower
than the acute State water quality criteria and 35 times lower than the chronic criteria. The total
amount of mercury discharged from aluminum anodes on all Armed Forces vessels is estimated
to be less than 0.001 pounds annually.

For ICCP calculations, the modeling is based on an assumption that 100 percent of the
supplied electrical current results in CPO generation. Less CPO is actually expected to be
generated because the efficiency of the chlorine generation process is known to be less than 100
percent. In addition, using the generation rate alone does not account for the rapid decay of CPO
in water through chemical reactions involving CPO, which occur within minutes.

The dilution and mixing zone modeling performed for this discharge indicates that
cathodic protection has a low potential for causing adverse impacts on the marine environment.
Therefore, EPA and DoD determined that it is not reasonable and practicable to require the use of
a MPCD to mitigate adverse impacts on the marine environment for this discharge.

5.2.4 Freshwater Lay-Up

This discharge is the potable water that is periodically discharged from the seawater
cooling system while the vessel is in port, and the cooling system is in a lay-up mode.

Seawater cooling systems are used onboard some Armed Forces vessels to remove heat
from main propulsion machinery, electrical generating plants and other auxiliary equipment.
These are single-pass, non-contact cooling systems whereby the seawater enters the hull, is
pumped through a piping network and circulated through one or more heat exchangers, then exits
the vessel. On certain vessels, the seawater cooling systems are placed in a stand-by mode, or
lay-up, when the machinery is not in use. The lay-up is accomplished by blowing the seawater
from the condenser with low-pressure air. The condenser is then filled with potable water and
drained again to remove residual seawater as protection against corrosion. Then, the condenser is
refilled with potable water for the actual lay-up. After 21 days, the lay-up water is discharged
overboard and the condenser refilled. The condenser is discharged and refilled on a 30-day cycle
thereafter. The volume of each condenser batch discharge is approximately 6,000 gallons.

The Navy is the only branch of the Armed Forces with vessels discharging freshwater lay-
up. All submarines generate this discharge, which only occurs while in port. Eight aircraft
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carriers also lay-up their condensers; however, these condensers are drained to the bilge and the
water is handled as bilgewater. Generally, the cooling system is only placed in a lay-up condition
if the vessel remains in port for more than three days and the main steam plant is shut down.

Sampling data for submarine freshwater lay-up indicate the presence of chlorine, nitrogen
(in the form of ammonia, nitrates and nitrites, and total Kjeldahl nitrogen), and the priority
pollutants chromium, copper, lead, nickel, and zinc. The concentrations of chlorine, copper,
nickel, and zinc can exceed acute Federal criteria or State acute water quality criteria. For
nitrogen and phosphorus, the most stringent State water quality criteria was exceeded. Chlorine
was detected in the initial flush discharge, but was not found in the extended lay-up discharge.
Mass loadings for the priority pollutants (copper, nickel, and zinc) were estimated using total
annual discharge volumes and average pollutant concentrations. The total mass loading from all
discharges of freshwater lay-up from submarines is estimated at 7 pounds/year of copper, 36
pounds/year of nickel, 29 pounds/year of zinc, 55 pounds/year of nitrogen., 0.58 pounds of total
chlorine, 8.3 pounds/year total phosphorus. The mass discharge from any individual freshwater
lay-up discharge event would be a fraction of that total. Because of the low total annual mass
loading, the low frequency at which the discharge occurs, and the volume of an individual
discharge event, discharges of freshwater lay-up have a low potential for causing adverse
environmental impacts. Therefore, EPA and DoD determined that it is not reasonable and
practicable to require the use of a MPCD to mitigate adverse impacts on the marine environment
for this discharge.

5.2.5 Mine Countermeasures Equipment Lubrication

This discharge consists of the constituents released into the surrounding seawater by
erosion or dissolution from lubricated mine countermeasures equipment when the equipment is
deployed or towed. Various types of mine countermeasures equipment are deployed and towed
behind vessels to locate and destroy mines. Lubricating grease and oil applied to this equipment
can be released into surrounding seawater during its deployment and use, including during
training exercises.

The Navy is the only branch of the Armed Forces with a mine countermeasures mission.
The Navy uses two classes of vessels, totaling 23 ships, to locate, classify, and destroy mines.
The discharge is generated during training exercises, which are normally conducted between 5
and 12 n.m. from shore. Depending on the class of vessel and the type of mine countermeasures
equipment being used, the number of training exercises conducted by each vessel ranges from 6
to 240 per year.

Using estimates of the amount of lubricant released during each training exercise, EPA
and DoD calculated the annual mass loading of lubricant discharges to be approximately 770
pounds of grease and oil. Using the estimates of the pollutant mass loading released during an
exercise, and the volume of water through which the countermeasures equipment is towed or
operated during an exercise, EPA and DoD estimated the oil and grease concentrations resulting
from mine countermeasures training exercises. These estimated concentrations of oil and grease
in the receiving water range from 0.688 to 7.3 ug/1 and do not exceed acute water quality criteria.
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An additional calculation was performed for the lift cable for the SLQ-48 mine
neutralization vehicle (MNV). This lift cable is lubricated with grease; however, the cable is not
towed through the water and is only used to deploy or recover the MNV while a vessel is
stationary. Using the maximum predicted release of 0.15 ounces of grease per deployment,
modeling results indicate that the grease released from the lift cable would disperse in the
surrounding receiving waters and be at concentrations below the most stringent State acute water
quality criteria within 3 to 5 feet from the cable.

Most discharges from mine counteraieasures equipment occur while vessels are underway
and the pollutants are quickly dispersed in the environment due to the turbulent mixing
conditions caused by the wake of the vessel and towed equipment. Further, these discharges take
place beyond 5 n.m. from shore in waters with significant wave energy, allowing for rapid and
wide dispersion of the releases. The manner in which these releases occur, coupled with the
relatively small amounts of lubricants released, results in this discharge having a low potential
for causing adverse impacts on the marine environment. Therefore, EPA and DoD determined
that it is not reasonable and practicable to require the use of a MPCD to mitigate adverse impacts
on the marine environment for the mine countermeasures equipment lubrication discharge.

5.2.6 Portable Damage Control Drain Pump Discharge

This discharge consists of seawater pumped through the portable damage control dram
pump and discharged overboard during periodic testing, maintenance, and training activities.

Portable damage control (DC) drain pumps are used to remove water from vessel
compartments during emergencies or to provide seawater for shipboard firefighting in the event
water is unavailable from the firemain system. The types of pumps used are described in section
5.2.7, Portable Damage Control Drain Pump Wet Exhaust. Discharges from drain pumps being
used during onboard emergencies are not incidental to normal vessel operations, and therefore
are not within the scope of this rule. These pumps are, however, periodically operated during
maintenance, testing, and training, and pump discharges during these activities are within the
scope of this rule. To demonstrate that the pumps are functioning properly, the suction hose is
hung over the side of the vessel and the pump operated to verify that the pump effectively
transfers the seawater or harbor water. This pump effluent is discharged directly overboard
during this testing.

All large ships and selected boats and craft of the Armed Forces generate this discharge.
As part of equipment maintenance, testing, and training, the pumps are operated both within and
beyond 12 n.m. from shore. Navy, Army, and MSC vessels operate portable DC drain pumps for
approximately 10 minutes per month and an additional 15 minutes/year to demonstrate working
order and condition. Coast Guard vessels operate their portable DC dram pumps for
approximately 30 minutes/month for maintenance and testing.

This discharge consists of seawater/harbor water that only briefly passes through a
pumping process. The drain pump discharge is unlikely to cause adverse impacts because the
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water has a residence time of less than five seconds in the pump and associated suction and
discharge hoses, and no measurable constituents are expected to be added to the seawater/harbor
water. Therefore, EPA and DoD determined it is not reasonable and practicable to require the
use of a MPCD to mitigate adverse impacts on the marine environment for this discharge.

5.2.7 Portable Damage Control Drain Pump Wet Exhaust

This periodic discharge is seawater that has mixed and been discharged with portable
damage control drain pump exhaust gases to cool the exhaust and quiet the engine.

Portable, engine-driven pumps provide seawater for shipboard firefighting in the event
water is unavailable from the firemain. Two models of these portable damage control (DC) drain
pumps are used: P-250 and P-100. The P-250 pumps operate on gasoline, injected with oil-based
lubricants. Part of the seawater output from these pumps is used to cool the engine and quiet the
exhaust. This discharge, termed wet exhaust, is typically routed overboard through a separate
exhaust hose and does not include the main discharge of the pump which is classified separately
as Portable Damage Control Drain Pump Discharge and discussed in section 5.2.6.

Fuel residuals, lubricants, or their combustion byproducts are present in P-250 engine
exhaust gases, condense in the cooling water stream, and are discharged as wet exhaust. The P-
100 model operates on diesel fuel. Although the engine that drives the P-100 pump is air-cooled
and no water is injected into the exhaust of the pump, a small amount of water contacts the
engine during pump priming. Up to one-seventh of a gallon of water may be discharged during
each priming event. This water discharged during P-100 priming is considered part of the
portable DC drain pump wet exhaust.

The Navy operates approximately 910 drain pumps, the MSC approximately 140 drain
pumps, and the Coast Guard approximately 370 drain pumps.

Portable DC drain pump wet exhaust discharges occur during training and monthly
planned maintenance activities both within and beyond 12 n.m. from shore. During monthly
maintenance activities, the pumps are run for approximately 10 to 30 minutes. The use of
portable DC drain pumps during onboard emergencies is not incidental to normal operations, and
therefore not within the scope of this rule.

Based on data in the record, the wet exhaust discharge is likely to include metals, oil and
grease, and volatile and semi-volatile organic compounds. The concentrations of copper, lead,
nickel, silver, and zinc in portable DC drain pump wet exhaust can exceed acute Federal criteria
and State acute water quality criteria. Concentrations of oil and grease, benzene, toluene,
ethylbenzene, and naphthalene can exceed State acute water quality criteria. Concentrations of
these constituents in receiving waters are not expected to exceed water quality criteria because
they will dissipate quickly since the mass loadings per discharge event are small and the
discharge locations are dispersed fleetwide. The discharge from each of the 500 P-250 pumps
occurs separately at different discharge locations. On average, each P-250 pump discharges less
than 0.3 pounds of pollutants per discharge event. The duration of each discharge is short,
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averaging less than 30 minutes. These factors allow the pollutants to dissipate rapidly. Based on
this information, the portable DC drain pump wet exhaust is expected to have a low potential for
exhibiting adverse environmental impacts on the marine environment. Therefore, EPA and DoD
determined it is not reasonable and practicable to require a MPCD to mitigate adverse impacts on
the marine environment for this discharge.

5.2.8 Refrigeration and Air Conditioning Condensate

This discharge is the drainage of condensed moisture from air conditioning units,
refrigerators, freezers, and refrigerated spaces. Refrigerators, refrigerated spaces, freezers, and
air conditioning units produce condensate when moist air contacts the cold evaporator coils.
This condensate drips from the coils and collects in drains. Condensate collected hi drains above
the vessel waterline is continuously discharged directly overboard. Below the waterline,
condensate is directed to the bilge, non-oily machinery wastewater system, or is retained in
dedicated holding tanks prior to periodic overboard discharge.

Approximately 650 Navy, MSC, Coast Guard, Army, and Air Force vessels produce this
discharge. The condensate may be discharged at any time, both within and beyond 12 n.m. from
shore.

Condensate flow rates depend on air temperature, humidity, and the number and size of
cooling units per vessel. The discharge can contain cleaning detergent residuals, seawater from
cleaning refrigerated spaces, food residues, and trace metals leached from contact with cooling
coils and dram piping. Because evaporator coils are made from corrosion-resistant materials and
condensation is non-corrosive, condensate is not expected to contain metals in significant
concentrations. Discharges of refrigeration and air conditioning condensate are expected to have
a low potential for causing adverse environmental impacts, therefore EPA and DoD determined it
is not reasonable and practicable to require a MPCD to mitigate adverse impacts on the marine
environment for condensate discharges.

5.2.9 Rudder Bearing Lubrication

This discharge is the oil or grease released by the erosion or dissolution from lubricated
bearings that support the rudder and allow it to turn freely. Armed Forces vessels generally use
two types of rudder bearings, and two lubricating methods for each type of rudder bearing: 1)
grease-lubricated roller bearings; 2) oil-lubricated roller bearings; 3) grease-lubricated stave
bearings; and 4) water-lubricated stave bearings. Only oil-lubricated roller bearings and grease-
lubricated stave bearings generate a discharge.

Approximately 220 Navy vessels, 50 Coast Guard vessels, and eight MSC vessels use a
type of rudder bearing that generates this discharge. The discharge occurs intermittently,
primarily when a vessel is underway or its rudder is in use, although some discharges from oil-
lubricated roller bearings could potentially occur pierside even when the rudder is not being used
because the oil lubricant is slightly pressurized.
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This discharge consists of oil leakage and the washout of grease from rudder bearings.
EPA and DoD developed an upper bound estimate of the fleetwide release of oil and grease
based on allowable leakage/washout rates and the amount of time each vessel spends within 12
n.m. from shore. The maximum allowable oil leak rate for oil-lubricated roller bearings is one
gallon/day when the vessel is underway and one pint/day while in port. In practice, these leakage
rates are not reached under normal conditions. The grease washout rate for grease-lubricated
stave bearings is based on Navy specifications limiting grease washout to 5 percent. Grease
washout estimates for this rule are based on releasing 5 percent of the grease over a two-week
period, which corresponds to the time between grease applications.

EPA and DoD calculated the expected receiving water concentrations of oil and grease
from this discharge to evaluate the potential for the discharge to cause adverse impacts. The
underway receiving water volume was determined using an average size vessel and estimating
the volume of water displaced by the vessel while transiting from port to a distance of 12 n.m.
from shore. In port, discharges are not expected since the lower bearing seals are designed to
prevent leakage and, as noted above, the oil to the bearings is kept at a low pressure while in
port. The resulting estimated pollutant concentrations do not exceed acute Federal criteria or
State acute water quality criteria. The rudder bearing lubrication discharge has a low potential
for causing adverse environmental impacts. EPA and DoD determined that it is not reasonable
and practicable to require a MPCD to mitigate adverse impacts on the marine environment for
this discharge.

5.2.10 Steam Condensate

This discharge is the condensed steam discharged from a vessel in port, where the steam
originates from shore-based port facilities. Navy and MSC surface ships often use steam from
shore facilities during extended port visits to operate auxiliary systems such as laundry facilities,
heating systems, and other shipboard systems. In the process of providing heat to ship systems,
the steam cools and condenses. This condensate collects hi drain collection tanks and is
periodically discharged by pumping it overboard. The steam condensate is discharged above the
vessel waterline and a portion of the condensate can vaporize as it contacts ambient air.

This discharge is generated only in port because vessels only discharge the condensed
steam if it was generated by a shore facility. Ships producing their own steam will recycle their
condensate back to the boiler. Vessels take on shore steam when their own boilers are shut
down, and thus they have no means for reusing the condensate. There are no systems in place
that would allow vessels to return steam condensate to shore for reuse.

Depending on the steam needs of individual vessels, the discharge can be intermittent or
continuous whenever shore steam is supplied. Approximately 180 Navy and MSC vessels
discharge steam condensate. Coast Guard vessels do not generate this discharge because they
operate their auxiliary boilers to produce then: own steam even while in port. Army and Air
Force vessels do not have steam systems and therefore do not discharge steam condensate.
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The constituents of steam condensate include metals from onshore steam piping, ship
piping, and heat exchangers, and may have some residual water treatment chemicals.
Constituents found in the discharge include nitrogen (in the form of ammonia, nitrates and
nitrites, and total Kjeldahl nitrogen), phosphorus, bis(2-ethylhexyl)phthalate, benzidine, copper,
and nickel. Sampling of steam condensate from four vessels found copper concentrations that
exceed both chronic Federal criteria and State chronic water quality criteria. Nickel
concentrations exceeded the most stringent State chronic water quality criteria, but not the
chronic Federal criteria. Benzidine, bis(2-ethylhexyl)phthalate, nitrogen (in the form of
ammonia, nitrates and nitrites, and total Kjeldahl nitrogen), and phosphorus concentrations
exceeded the most stringent State water quality criteria.

The potential for steam condensate to cause thermal environmental effects was evaluated
by modeling the thermal plume generated by the discharge and then comparing the model results
to State thermal discharge water quality criteria. Results of the modeling indicate that only the
largest generator of steam condensate (an aircraft carrier) may exceed state thermal mixing zone
criteria, and then, only in the State of Washington. The models predict that the thermal plume
from an aircraft carrier moored at the pier in Bremerton, Washington would extend a distance of
80 m from the discharge port along the vessel hull, not extending past the end of the hull. The
plume would also extend outward no more than a distance of 30 m from the vessel hull at any
point along the hull. Results of the modeling indicate that the aircraft carrier may exceed
Washington criteria in an area that only covers 5% of the width, 2% of the length, and 0.07% of
the total surface area of Sinclair Inlet.

The EPA and DoD do not consider that the plume results in a significant environmental
impact. Such a localized plume would have a low potential for interfering with the passage of
aquatic organisms in the water body and would have a limited impact on the organisms that
reside in the upper water layer (sea surface boundary layer). In addition, because the discharge is
freshwater (no salinity) and warmer than the receiving water, the plume floats in the surficial
layer of the water body and has no impact on bottom-dwelling organisms.

The low mass loadings in the discharge and the thermal effects modeling results indicate
that steam condensate has a low potential for causing adverse environmental impacts. Therefore,
EPA and DoD determined that it is not reasonable and practicable to require a MPCD to mitigate
adverse impacts on the marine environment for this discharge.

5.2.11 Stern Tube Seals and Underwater Bearing Lubrication

This discharge is the seawater pumped through stern tube seals and underwater bearings
to lubricate and cool them during normal operation.

Propeller shafts are supported by stern tube bearings at the point where the shaft exits the
hull (for surface ships and submarines), and by strut bearings outboard of the ship (for surface
ships only). A stern tube seal is used to prevent seawater from entering the vessel where the
shaft penetrates the hull. The stern tube seals and bearings are cooled and lubricated by forcing
seawater from the firemain or auxiliary cooling water system through the seals and over the
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bearings. On submarines, potable water (freshwater) may be supplied from pierside connections
for stem tube seal lubrication during extended periods in port.

Strut bearings are not provided with forced cooling or lubrication. Instead, strut bearings
use the surrounding seawater flow for lubrication and cooling when the vessel is underway.
Submarines do not have strut bearings and instead use a self-aligning bearing aft of the stem tube
that supports the weight of the propeller and shafting outboard of the vessel.

Almost all classes of surface vessels and submarines have stern tube seals and bearings
that require lubrication, and these discharges are continuous. The discharge can contain synthetic
(Buna-N) rubber used in the construction of the bearings. Metals such as copper and nickel, the
materials of construction of the stern tube, can also be present hi the discharge. When freshwater
is used for lubricating submarine seals, the freshwater may contain residual chlorine. Based on
estimates of chlorine concentrations in potable water, fleetwide approximately 0.8 pounds/year of
chlorine exit through the stern tube seals and bearings.

Total annual mass loadings for the metal constituents of seawater lubrication were
calculated based on materials of construction in the stern tube, corrosion rates for those materials,
and the surface area of the material exposed to seawater for a DDG 51 Class ship. While the
copper concentrations can exceed chronic Federal criteria and State chronic water quality criteria,
the rate at which the water is discharged through a vessel's stern tube seal and bearings is
relatively small - 20 gal/min each shaft, 2 shafts per ship - resulting in a low pollutant mass
loading exiting through the seals and bearings. Further, these discharges are distributed
throughout the U.S. at Armed Forces ports, and each individual port receives only a fraction of
the total fleetwide mass loading. Given the low rate of the discharge and the low mass loadings,
this discharge has a low potential for causing adverse environmental impacts. Therefore, EPA
and DoD determined it is not reasonable and practicable to require the use of a MPCD to
mitigate adverse impacts on the marine environment for this discharge.

5.2.12 Submarine Acoustic Countermeasures Launcher Discharge

This intermittent discharge is composed of seawater that mixes with acoustic
countermeasure device propulsion gas after launching an acoustic countermeasure device, and
subsequently discharged either through exchange with the surrounding seawater or while
draining from an expended device being removed from the submarine.

Navy submarines have the capability to launch acoustic countermeasures devices to
improve the survivability of a submarine by generating sufficient noise to be observed by hostile
torpedoes, sonars, or other monitoring devices. The only countermeasures systems that generate
a discharge within 12 n.m. are the countermeasures set acoustic (CSA) Mk 2 systems, which
launch the countermeasure devices by gas propulsion through a launch tube. Following the
launch, a metal plate closes the launch tube forming a watertight endcap. To equalize pressure, a
one-way check valve allows water to flow into the tube after launch, but does not allow any of
the water to be released through the opening. The launch tube cap contains three, 3/8 inch, bleed
hole plugs that dissolve approximately three days after the launch. This allows exchange
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between the launch tube and the surrounding seawater while the submarine is moving. The bleed
holes also allow some launch tube water to drain into the surrounding water when the assembly
is removed from the submarine for replacement. The CSA Mk2 system is installed on 24 Navy
submarines.

Constituents found in the CSA Mk2 launch tubes after launching countermeasures
devices include copper, cadmium, lead, and silver. The discharge may also contain constituents
from the propulsion gas including hydrochloric acid, carbon dioxide, carbon monoxide, nitrogen,
alumina, iron (H) chloride, titanium dioxide, hydrogen, and iron (IT) oxide. Sampling indicates
that copper, cadmium, and silver concentrations are above both Federal acute water criteria and
the most stringent State acute water quality criteria; lead concentrations are above the most
stringent State water quality criteria. The total annual mass loadings from all discharges from
submarine CSA Mk2 countermeasure launcher systems are estimated at 0.0005 pounds/year
cadmium, 0.0009 pounds/year lead, 0.0007 pounds/year copper, and 0.00009 pounds/year silver.

Because of the low annual mass loading, the low frequency at which the discharge occurs,
and the volume of the individual discharge event (17 gallons), discharges from submarine CSA
launcher systems have a low potential for causing adverse environmental impacts. Therefore
EPA and DoD determined it is not reasonable and practicable to require a MPCD to mitigate
adverse impacts on the marine environment for this discharge.

5.2.13 Submarine Emergency Diesel Engine Wet Exhaust

This discharge is seawater that is mixed and discharged with exhaust gases from the
submarine emergency diesel engine for the purpose of cooling the exhaust and quieting the
engine.

Submarines are equipped with an emergency diesel engine that is also used in a variety
of non-emergency situations, including electrical power generation to supplement or replace
shore-supplied electricity, routine maintenance, and readiness checks. This wet exhaust
discharge is generated by injecting seawater (or harbor water) as a cooling stream into the diesel
engine exhaust system. The cooling water mixes with and cools the hot exhaust gases, and is
discharged primarily as a mist that disperses in the air before depositing on the surface of the
water body.

All submarines generate this discharge. Diesel engines must be operated for equipment
checks that occur prior to submarine deployment, monthly availability assurance, and periodic
trend analyses. On average, each submarine will operate the diesel engine for approximately 60
hours/year while within 12 n.m. from shore. Most of the operating time (54 hours/year) occurs
while the submarine is pierside.

Typical constituents of diesel engine exhaust include various hydrocarbon combustion
by-products, measured as volatile and semi-volatile organic compounds. The priority pollutants
expected to be present in the discharge include polycyclic aromatic hydrocarbons (PAHs),
toluene, and possibly metals. Although no individual pollutant exceeds water quality criteria, the
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total concentration of PAHs in the discharge is predicted to exceed State acute water quality
criteria. Nevertheless, the discharge of PAHs is unlikely to cause adverse impacts on the marine
environment because the total fleetwide annual mass loading of PAHs is calculated to be less
than 0.06 pounds/year. Therefore, EPA and DoD determined that it is not reasonable and
practicable to require a MPCD to mitigate adverse impacts on the marine environment for
submarine diesel engine wet exhaust.

5.2.14 Submarine Outboard Equipment Grease and External Hydraulics

This discharge occurs when grease applied to a submarine's outboard equipment is
released to the environment through the mechanical action of seawater eroding the grease layer
while the submarine is underway, and by the slow dissolution of the grease into the seawater.
This discharge also includes any hydraulic oil that may leak past the seals of hydraulically
operated external components of a submarine (e.g., bow planes).

Outboard equipment grease is discharged by all submarines, but the discharge of oil from
external hydraulic equipment is limited to 22 submarines. This discharge occurs continuously
both within and beyond 12 n.m. from shore, although the rate of discharge depends upon the
degree of contact between seawater and the greased outboard components, and how fast the
submarine is traveling. Most hydraulically-operated outboard equipment, for example, does not
contact seawater within 12 n.m. from shore because submarines generally operate on the surface
in this region, and the hydraulically-operated equipment producing this discharge is located
mostly above the waterline.

This discharge consists of grease (Termalene #2) and hydraulic oil. Termalene #2
consists of mineral oil, a calcium-based rust inhibitor, thickening agents, an antioxidant, and dye.
Using an assumption that 100 percent of all grease applied to outboard equipment is washed
away at a constant rate during submarine operations, the amount of grease released fleetwide
within 12 n.m. is approximately 520 pounds/year. This value is believed to overstate the actual
mass of grease discharged within 12 n.m. because submarines operate at lower rates of speed in
coastal waters (thus leading to less erosion of the grease) and a surfaced submarine exposes a
lesser amount of grease to the water than is exposed by a submerged submarine.

Hydraulic oil consists of paraffinic distillates and additives. Using a calculation that
assumes all hydraulic system seals leak oil at the maximum allowable leak: rate, approximately
0.4 pounds/year of hydraulic oil is released fleetwide within 12 n.m. from shore. (Based on
discussions with Navy hydraulic system experts, such oil leakage rates are not common and thus
this calculation overestimates the amount of oil actually leaked.) The submarine will displace
approximately 120 million cubic feet of water as it travels within 12 n.m. from shore. Assuming
that hydraulic oil and outboard grease are leaked at a constant rate, this will result in
concentrations below the levels established in acute Federal criteria and State acute water quality
criteria.

In addition, the turbulence created by the vessel wake is expected to result in rapid
dispersion of the constituents released. As a result, the submarine outboard equipment grease
5-38

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and external hydraulics discharge has low potential for causing adverse environmental effects.
EPA and DoD determined it is not reasonable and practicable to require a MPCD to mitigate
adverse impacts on the marine environment for this discharge.

5.3    References

1.  International Maritime Organization. "Guidelines for Preventing the Introduction of
   Unwanted Aquatic Organisms and Pathogens from Ships' Ballast Water and Sediment
   Discharge." 10 May 1995.
                                        5-39

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                      GLOSSARY AND ABBREVIATIONS
AAV
ABT
AC
AC
ACE
Administrator
AE
AF
AFB
AFDB
AFDL
AFDM
AFFF
AFS
AG
AGER
AGF
AGM
AGOR
AGOS
AGS
AGSS
AH
AKR
Amps
Anode
ANB
AO
AOE
AP
APF
APL
amphibious assault vehicle
aerostat balloon tender
area command cutter
anti-corrosive - as related to vessel hull coatings
armored combat earthmover
the Administrator of the U.S. Environmental Protection Agency
ammunition ship
anti-fouling
air force base
large auxiliary floating drydock
small auxiliary floating drydock
medium auxiliary floating drydock
aqueous film-forming foam
combat store ship
miscellaneous auxiliary
environmental research ship
miscellaneous command ship
missile range instrumentation ship
oceanographic research ship
ocean surveillance ship
surveying ship
auxiliary research submarine
hospital ship
vehicle cargo ship
amperes
the site at which oxidation occurs in an electrochemical cell
aids to navigation boat
oiler
fast combat support ship
area point system search craft
afloat pre-positioning force
barracks craft
                                      GL-l

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                 GLOSSARY AND ABBREVIATIONS (contd.)
APU
AR
ARC
ARD
ARDM
ARS
AS
ASR
ASTM
ASW
AT
ATC
ATF
avg.
AWR
B
BC
BCDK
BD
BDL
BG
BH
BK
BMP
BOD
BPL
BRM
BT
BU
BUSL
BW
CA
Cathode
CC
auxiliary power unit
repair ship
cable repairing ship
auxiliary repair dock
medium auxiliary repair dock
salvage ship
submarine tender
annual sedimentation rate
American Society for Testing and Materials
anti-submarine warfare
armored troop carrier
mini-armored troop carrier
fleet ocean tug
average
army war reserve
barge
dry cargo barge
decked, enclosed conversion kit barge
floating crane
below detection limit
liquid cargo barge
boom handling boat
deck cargo barge
best management practice
biochemical oxygen demand
delong mobile piers
refrigerated stores barge
bomb target
buoy utility boat
stern loading buoy utility boat
boston whaler
catamaran (also a gun cruiser, surface combatant)
the site at which reduction occurs in an electrochemical cell
cabin cruiser
                                     GL-2

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                 GLOSSARY AND ABBREVIATIONS (contd.)
CDNSWC
CFR
CG
CGN
CHT
CID
CM
Cm
CNO
COD
COE
COMNAVAIRLANT
COMNAVAIRPAC
COMNAVSURFLANT
COMNAVSURFPAC
COPHOS
CORMK
CPO
CPP
CRRC
CT
CU
CV
CVN
CWA
DB
DBT
DC
DC
DD
DDG
DFT
DoD
DOT
(see NSWCCD)
Code of Federal Regulations
guided missile cruiser
guided missile cruiser (non-conventional propulsion)
collection, holding and transfer (tank)
commercial item description
landing craft, mechanized
centimeter
Chief of Naval Operations
chemical oxygen demand
Corps of Engineers
Commander Naval Air Force, Atlantic Fleet
Commander Naval Air Force, Pacific Fleet
Commander Naval Surface Force, Atlantic Fleet
Commander Naval Surface Force, Pacific Fleet
coordinated phosphate treatment
Cornell mixing zone expert system
chlorine produced oxidants
controllable pitch propeller
combat rubber raiding craft
craft of opportunity coop trainer
landing craft, utility
multi-purpose aircraft carrier
multi-purpose aircraft carrier, non-conventional
Clean Water Act
distribution box boat
dibutyltin
direct current
damage control
destroyer
guided missile destroyer
dry film thickness
Department of Defense
Department of Transportation
                                    GL-3

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                 GLOSSARY AND ABBREVIATIONS (contd.)
DSRV
DSV
DT
DW
EDTA
EE
EOT
BOSS
EPA
ESC
FAS
FB
FFG
FLO/FLO
FMS
FR
FR
FSS
G
Gal
Gpm
GRP
HC
HEM
HOPM
HP
I&S
ICCP
ILS
MO
INSURV
EX
J-Boat
Kw
deep submergence rescue vehicle
deep submergence vehicle
diving tender
dive workboat
ethylenediaminetetraacetic acid, a chelating agent
equipment expert
emergency gas turbine
engineering operating sequencing systems
the U.S. Environmental Protection Agency
the UNDS Executive Steering Committee
fueling at sea
catamaran ferry
guided missile frigate
float-on/float-off vessel
floating machine shop
Federal Register
fouling rating
fast sealift ship
grams
gallons
gallons per minute
glass reinforced plastic
hydrocarbon
hexane extractable materials
hydraulic oil pressure module
horsepower
intelligence and security
impressed current cathodic protection
integrated logistics services
International Maritime Organization
board of inspection and survey
unclassified miscellaneous unit
work and inspection boat
kilowatt
                                      GL-4

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                 GLOSSARY AND ABBREVIATIONS (contd.)
L
LA
LARC
LASH
Lb
LC
LCAC
LCC
LCM
LCPL
LCU
LCVP
LH
LHA
LED
LPD
LPH
LSD
LST
LSV
LT
MARAD
MARPOL

MET
MET
MC
MCB
MCM
MDL
MDZ
MEB
MERR
liter
landing craft, assault
four-wheeled amphibious cargo vehicle
lighter-aboard-ship
pound
landing craft
landing craft, air cushion
amphibious command ship
landing craft, mechanized
landing craft, personnel, large
landing craft, utility
landing craft, vehicle, personnel
line handling boat
amphibious assault ship (general-purpose)
amphibious assault ship (multi-purpose)
amphibious transport dock
amphibious assault ship (helicopter)
dock landing ship
tank landing ship
logistics support vessel
large harbor tug
Maritime Administration
international convention for the prevention of pollution from
ships
monobutyltin
main ballast tank
mine countermeasures support craft
motor cargo boat
mine countermeasures ship
minimum detection limit
maritime defense zone
marine expeditionary brigade
metal element repair and restoration machine
micrograms (one millionth of a gram)
                                     GL-5

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                 GLOSSARY AND ABBREVIATIONS (contd.)
Mg
Mgal
Mgy
MHC
Min
ML
ML
MLB
MM
MNV
MOGAS
MFC
MPCD
MPS
MR
MRC
MSB
MSC
MSD
MSDS
MV
MW
MWT
n.m.
NAVSEA(orSEA)
NAVSTA
NDRF
NDZ
NFAF
NFESC
NFME
NFO
NL
NM
milligrams (one thousandth of a gram)
million gallons
million gallons per year
minehunter, coastal
minute
motor launch
milliliter (one thousandth of a liter)
motor life boat
marine mammal support craft
mine neutralization vehicle
motor gasoline
maintenance procedure card
marine pollution control device
maritime pre-positioning ship
missile retriever
major regional conflict
motor surf boat
Military Sealift Command
marine sanitation device
material safety data sheet
motor vessel
motor whaleboat
magnetic water treatment
nautical miles
Naval Sea Systems Command
naval station
National Defense Reserve Fleet
no-discharge zone
Naval Fleet Auxiliary Force
Naval Facilities Engineering Services Command
naval fleet marine expeditionary (see MEB)
normal fuel oil
no limit
noise measuring boat
                                    GL-6

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                 GLOSSARY AND ABBREVIATIONS (contd.)
NOAA
NOD
NPDES
NraD
NRF
NS
NSTM
NSWCCD
OCM
OPNAVINST
OWHT
OWS
P
PAH
PB
PB-HS
PER
PC
PCB
PE
PF
PG
PK
PL
PMS
PMS
Ppb
Ppm
PR
PREPO
Priority pollutants

PSB
Psi
National Oceanic and Atmospheric Administration
nature of discharge
national pollutant discharge elimination system
Naval Research and Development Command
Naval Reserve Fleet
non-standard (commercial) boat
naval ships' technical manual
Naval Surface Warfare Center, Carderock Division
oil content monitor
naval operations instruction manual
oily waste holding tank
oil-water separator
personnel boats
polynuclear aromatic hydrocarbon
patrol boat
patrol boat, harbor security
river patrol craft
patrol, coastal
polychlorinated biphenyl
personnel boat
patrol craft, fast
patrol gunboat
picket boat
landing craft, personnel light
preventative maintenance system
planned maintenance system
parts per billion
parts per million
plane personnel and rescue
pre-positioning ships
toxic pollutants designated in section 307(a) of the Clean
Water Act
port security boat
pounds per square inch
                                     GL-7

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                 GLOSSARY AND ABBREVIATIONS (contd.)
PT
PWB
RBorRJB
RHffi
RHIL
RHIM
RIMSS
RO
RO/RO
ROS
RRC
RRDF
RRF
RX
SB
SC
SCAMP
SCC
Secretary
SER
SERC
SES
SESO
SGT
SLO
SLWT
SMSF
SRB
SRFO
ss
ss
SSAP
SSBN
SSN
punt
ports and waterways boat
rigid inflatable boat
rigid hull inflatable boat
large rigid hull inflatable boat
medium rigid hull inflatable boat
redundant independent mechanical starting systems
reverse osmosis
roll-on/roll-off type vessel
reduced operating status
rubber raiding craft
roll-on/roll-off discharge facilities
Ready Reserve Fleet
rigid inflatable boat (non-standard)
sound/sail
support craft
submerged cleaning and maintenance platform
sample control center
the Secretary of the U.S. Department of Defense
sampling episode report
Smithsonian Environmental Research Center
surface effects ship
Ships Environmental Support Office
silicone gel treated
synthetic lubricating oil
side-loading warping tug
special mission support force
surf rescue boat
standard refueling, fuel oil
steamship
submarine, (also swimmer support)
specific sampling and analysis plan
ballistic missile submarine, non-conventional
submarine, non-conventional
                                     GL-8

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                 GLOSSARY AND ABBREVIATIONS (contd.)
ST
SVOC
T-Boat
TACOM
TANB
TBT
TC
TCLP
TD
TDD
TDS
TG
TOC
TPH
TR
TRC
TRO
TS
TSS
TWO
U
UB
UMI
UNDS
UNREP
UTB
UTL
VOC
VP
VSTOL
WAGB
WB
Welldeck
sail training craft also small harbor tug
semi-volatile organic compound
small freight and supply vessel
U.S. Army Tank-Automotive and. Armaments Command
trailerable aids to navigation boat
tributyltin
training craft
toxicity characteristic leaching procedure
target drone
technical development document
total dissolved solids
tugboat
total organic carbon
total petroleum hydrocarbons
torpedo retriever
total residual chlorine
total residual oxidants
training ship, State Maritime Academies
total suspended solids
technical working group
utility boat
utility boat
underway material inspections
uniform national discharge standards
underway replenishment
utility boat
large utility boat
volatile organic compound
landing craft, vehicle personnel
vertical/short take-off and landing
icebreaker
work boat
the docking well onboard amphibious warfare ships used to
store landing craft
                                     GL-9

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                 GLOSSARY AND ABBREVIATIONS (contd.)
WH
WHEC
WDC
WLB
WLI
WLIC
WLM
WLR
WMEC
WOCT
WOT
WPB
WQC
WT
WTGB
WYTL
WYTM
YC
YCF
YCV
YD
YDT
YFB
YFN
YFNB
YFND
YFNX
YFP
YFRN
YFRT
YFU
YGN
YL
YLC
wherry
high endurance cutter
training cutter/sailing bark
offshore buoy tender
inshore buoy tender
inland construction tender
coastal buoy tender
river buoy tender
medium endurance cutter
waste oil collection tank
waste oil tank
patrol boat
water quality criteria
warping tug
icebreaking tug
harbor tug, small
harbor tug, medium
open lighter
car float
aircraft transportation lighter
floating crane
diving tender
ferryboat or launch
covered lighter
large covered lighter
drydock companion craft
lighter - special purpose
floating power barge
refrigerated/covered lighter
covered lighter, range tender
harbor utility craft
garbage lighter
yawl
salvage lift craft
                                     GL-10

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                 GLOSSARY AND ABBREVIATIONS (contd.)
YM
YMN
YNG
YO
YOG
YOGN
YON
YOS
YP
YPD
YR
Yr
YRB
YRBM
YRDH
YRR
YRST
YSD
YSR
YTB
YTL
YTM
YTT
YWN
dredge
dredge
gate craft
fuel oil barge
gasoline barge
gasoline barge
fuel oil barge
oil storage barge
patrol craft, training
floating pile driver
floating workshop
year
repair and berthing barge
repair, berthing and messing barge
floating drydock workshop, hull
radiological repair barge
salvage craft tender
seaplane wrecking derrick
sludge removal barge
large harbor tug
small harbor tug
medium harbor tug
torpedo trials craft
water barge
                                     GL-11

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                              Appendix A
Nature of Discharge (NOD) and Marine Pollution Control Device (MPCD) Reports
                                  A-l

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                                     Appendix A

       Appendix A contains each of the 39 NOD reports, the contents of which are described in
section 4.3 of the main document. Reports are arranged alphabetically, in order of appearance.
The title of each report may be found on the bottom center of each page. The following four
MPCD practicability analyses are also included in this appendix, after the respective NOD
reports:

       •   Distillation and Reverse Osmosis Brine;
       •   Hull Coating Leachate;
       •   Small Boat Engine Wet Exhaust; and
       •   Underwater Ship Husbandry

Refer to section 4.4 for a more detailed discussion of the process used to determine MPCD
practicability.
                                         A-2

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                                   Appendix A
               List of NOD and MPCD Reports (in order of appearance)

Aqueous Film-Forming Foam NOD Report
Boiler Slowdown NOD Report
Catapult Water Brake Tank and Post-Launch Retraction Exhaust NOD Report
Catapult Wet Accumulator Discharge NOD Report
Cathodic Protection NOD Report
Chain Locker Effluent NOD Report
Clean Ballast NOD Report
Compensated Fuel Ballast NOD Report
Controllable Pitch Propeller Hydraulic Fluid NOD Report
Deck Runoff NOD Report
Dirty Ballast NOD Report
Distillation and Reverse Osmosis Brine NOD Report
Distillation and Reverse Osmosis Brine MPCD Report
Elevator Pit Effluent NOD Report
Firemain Systems NOD Report
Freshwater Lay-Up NOD Report
Gas Turbine Water Wash NOD Report
Graywater NOD Report
Hull Coating Leachate NOD Report
Hull Coating Leachate MPCD Report
Mine Countermeasures Equipment Lubrication NOD Report
Motor Gasoline Compensating Discharge NOD Report
Non-Oily Machinery Wastewater NOD Report
Photographic Laboratory Drams NOD Report
Portable Damage Control Drain Pump Discharge NOD Report
Portable Damage Control Drain Pump Wet Exhaust NOD Report
Refrigeration /Air Conditioning Condensate NOD Report
Rudder Bearing Lubrication NOD Report
Seawater Cooling Overboard Discharge NOD Report
Seawater Piping Biofouling Prevention NOD Report
Small Boat Engine Wet Exhaust NOD Report
Small Boat Engine Wet Exhaust MPCD Report
Sonar Dome Discharge NOD Report
Steam Condensate NOD Report
Stern Tube Seals and Underwater Bearing Lubrication NOD Report
Submarine Acoustic Countermeasures Launcher Discharge NOD Report
Submarine Bilgewater NOD Report
Submarine Emergency Diesel Engine Wet Exhaust NOD Report
Submarine Outboard Equipment Grease and External Hydraulics NOD Report
Surface Vessel Bilgewater/Oil-Water Separator Discharge NOD Report
Underwater Ship Husbandry NOD Report
Underwater Ship Husbandry MPCD Report
Welldeck Discharges NOD Report
                                      A-3

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                     NATURE OF DISCHARGE REPORT
                      ;: Aqueous Film Forming Foam (AFFF}
1.0   INTRODUCTION

      The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"..discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)].  UNDS is being developed in three phases.  The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

      A nature of discharge (NOD) report has been prepared for each of the discharges that has
been identified as a candidate for regulation under UNDS. The NOD reports were developed
based on information obtained from the technical community within the Navy and other branches
of the Armed Forces with vessels potentially subject to UNDS, from information available in
existing technical reports and documentation, and, when required, from data obtained from
discharge samples that were collected under the UNDS program.

      The purpose of the NOD report is to describe the discharge in detail, including the system
that produces the discharge, the equipment involved, the constituents released to the
environment, and the current practice, if any, to prevent or minimize environmental effects.
Where existing process information is insufficient to characterize the discharge, the NOD report
provides the results of additional sampling or other data gathered on the discharge.  Based on the
above information, the NOD report describes how the estimated constituent concentrations and
mass loading to the environment were determined. Finally, the NOD report assesses the
potential for environmental effect. The NOD report contains sections on: Discharge
Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data
Sources and References.
                          Aqueous Film Forming Foam (AFFF)
                                          1

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2.0 DISCHARGE DESCRIPTION

This section describes the AFFF and includes information on: the equipment that is used
and its operation (Section 2.1), general description of the constituents of the discharge (Section
2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

AFFF is the primary firefighting agent used aboard U.S. Coast Guard (USCG) and Navy
vessels for flammable liquid fires. A different class of agents, Fluoroprotein foams, are used for
the same purpose on vessels in the Military Sealift Command (MSC). Aqueous Film Forming
Foam (AFFF) is a particular type of synthetic firefighting foam whose performance is governed
by military specification. Fluoroprotein foam is a protein-based material to which fluorinated
surfactants have been added to improve fluidity and surface tension properties, while reducing
the tendency of the protein base to absorb liquids.

These foams control and extinguish flammable liquid fires and help prevent such fires
after spills by spreading a vapor-sealing film over the flammable liquid. The foam layer
effectively excludes oxygen from the surface of the fuel, while the high water content cools the
surface. The foam layer also provides a reservoir that will reseal a disturbed fuel surface and
inhibit reignition. Both foams have excellent "wetting" or penetrating characteristics can be used
against fires involving densely packed wood, wood products, cloth, textile and fibrous materials,
paper, and paper products. Both types of foam concentrates can be stored for indefinite periods
in approved equipment and systems with no degradation hi chemical properties or capabilities.

In use, foam concentrate is mixed with seawater to form a dilute seawater foam solution.
Seawater foam solution is generated in foam proportioning stations or by portable proportioners.1
Each type involves metering foam concentrate into pressurized, firefighting seawater. The
metering accuracy of the proportioning stations is verified by periodic tests.

Foam is applied both manually, with conventional foam or water/fog equipment such as
fire hoses equipped with foam nozzles, and from fixed sprinkler devices. Fixed systems provide
seawater foam solution to sprinklers on flight decks, and to overhead sprinklers in hangars, tank
decks, well decks, weapon elevator pits, fueled vehicle decks or holds, refueling stations, and
fuel pump rooms. If a protected area requires a greater flow rate than can be supplied by a single
proportioning station, the area is subdivided into zones or groups, each independently supplied
from a single proportioning station. Bilge sprinkler systems are installed in machinery spaces
and pump rooms. Firefighting hose reel stations are supplied through a system of proportioners,
pumps, and permanently installed piping.

Foam concentrate is stored hi tanks, 55-gallon drums, and 5-gallori cans. Aircraft
carriers, large amphibious ships, and other large ships can carry more than 20,000 gallons of
AFFF or fluoroprotein foam concentrate.
i
Neither AFFF nor fluoroprotein foam is ever discharged from vessels in concentrated

Aqueous Film Forming Foam (AFFF)
2

-------
form. Only the dilute seawater foam solution is discharged. Incidental discharge of seawater
foam solution occurs during maintenance that is part of the Planned Maintenance System (PMS),
Board of Inspection and Survey (INSURV) underway material inspections (UMI), flight deck
certifications, or biennial tests on MSC vessels by the USCG Office of Marine Inspection.

Regular preventive maintenance of firefighting systems and equipment requiring the
discharge of seawater foam solution aboard ship occurs annually during PMS activities, although
some maintenance is performed at 18 month intervals. Table 1 indicates the frequency of foam
solution discharges on Navy, MSC, and USCG vessels. For Navy vessels, an INSURV UMI
occurs every 3 years and involves the same system checks and resulting seawater foam
discharges as the annual PMS activities. An MSC damage control instruction requires that foam
solution be present at flight deck nozzles before every flight operation (approximately twice per
month per vessel), which is verified by operating the nozzles until foam is sighted.2 For aircraft
carriers, Navy requirements call for a flight deck certification during the first deployment to sea
after a shipyard or repair period (approximately every 1.5 years). Other than aircraft carriers,
ships with flight decks, whether Navy or MSC, receive flight deck certification inspections every
3 years that test for foam solution at all flight deck nozzles and hoses.

2.2 Releases to the Environment

The seawater foam solutions that are discharged onto flight and weather decks as a result
of maintenance, inspection, and certification activities are washed overboard with pressurized
seawater from fire hoses, or by activating the seawater washdown system. Foam that is
discharged into internal ship compartment bilges during system testing and flushing evolutions is
pumped overboard by eductors.

Seawater foam discharge will contain all the constituents from the firemain, in addition to
constituents unique to the foam concentrate. As discussed more fully in the Firemain Systems
NOD Report, the principal constituent of the firemain discharge that could have an adverse water
quality effect is copper, derived from the copper nickel firemain piping. Therefore, copper will
be an expected component of the AFFF solution discharge.

2.3 Vessels Producing the Discharge

All Navy surface ships, all classes of USCG cutters, icebreakers and icebreaking tugs, and
MSC ship classes with the ability to support helicopter operations produce the discharge.
Table 2 shows the vessel classes that produce the discharge.
3.0 DISCHARGE CHARACTERISTICS

Aqueous Film Forming Foam (AFFF)
3

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       3.1    Locality

       The Navy provides instruction on where seawater AFFF solutions can be discharged
during maintenance that tests the proportioning accuracy of AFFF proportioning stations. This
test is commonly conducted by discharging an AFFF hose over the side, when beyond the 12
nautical mile (n.m.) limit. The PMS instructions state:

       "Accomplish maintenance requirements only when ship is beyond 12 nautical miles of
       shore and preferably while underway. When within 3 nautical miles of shore or in port,
       discharge to a tank, barge or to an authorized truck. In other cases, when between 3 and
       12 nautical miles, overboard discharge is permitted with a minimum (ship) speed of 10
       knots."3"9

       Discharges that are part of inspections and certifications are not governed by the
maintenance instruction, and can be discharged anywhere, except that seawater foam solution in
a machinery space bilge is governed by bilge pumping rules, and cannot be discharged within 12
n.m.10 In practice, the maintenance policy applies because a single discharge event will be
scheduled to satisfy simultaneously the requirements for maintenance, inspection, and
certification.

       3.2    Rate

       When testing the proportioning accuracy of proportioning stations, ships typically test one
station at a time by discharging a foam hose over the side.  This discharge rate is 125 gallons per
minute (gpm) or 250 gpm, depending on the flow rate of the hose selected for the test. When
testing or demonstrating flight deck sprinkling, the most common practice is to operate one or
two zones at a time, continuing until all the zones have been tested. The nominal flow rate for
each zone on Navy ships is 1,000 gpm, so the typical discharge rate is 2,000 gpm.

       AFFF concentrate is mixed with seawater from the firemain to form a  6% dilute solution,
that is, 100 gallons of solution contains 6 gallons of AFFF concentrate and 94 gallons of
seawater.1 The WTGB 140 Class of icebreaking tugs operated by the USCG use more
concentrated base stock which is diluted to a 3% solution.  Fluoroprotein foams are mixed on
MSC ships in both 3% and 6% solutions, depending on the design of the installed proportioning
equipment.11  These mixing ratios are used in Table 2 to derive discharge quantities of foam
concentrate and seawater.
       After tests or demonstrations of flight deck sprinkling, the foam blanket is washed off
using fire hoses, or by operating the fixed seawater washdown system. Both techniques result in
a seawater discharge supplied from the firemain.  The flow rate is variable, but a typical range is
250 gpm (two fire hoses on a ship with a helicopter landing platform) to 2,000 gpm (two flight
deck zones on an aircraft carrier).

       Tests or demonstrations of bilge sprinkling do not result in environmental discharges
                           Aqueous Film Forming Foam (AFFF)
                                           4

-------
until bilges are pumped overboard. Bilges can be pumped within 12 n.m. of shore if the
discharge is passed through oil water separators. However, the surfactants in AFFF and
fluoroprotein foam render the oil water separators ineffective, so crews do not discharge seawater
foam solution through their oil water separators. Accordingly, bilges containing seawater foam
solution are pumped only beyond 12 n.m. from shore10. Therefore, this NOD report does not
account for foam discharges attributable to bilge sprinkling, discharge of machinery space bilge
hoses, nor the seawater used to wash and pump bilges.

By ship class, Table 2 shows the discharges of seawater foam solution, foam concentrate
in the solution, seawater hi the solution, and seawater used to wash the solution off the ship. All
discharges are assumed to occur within 12 n.m. of shore. The fleetwide estimates are
summarized in Table 3.

3.3 Constituents

The ingredients in foam concentrate are listed on material safety data sheets (MSDSs)
prepared by the manufacturer. The AFFF concentrate produced by the principal Armed Forces
supplier contains water, 2-(2-butoxyethoxy)-ethanol, urea, alkyl sulfate salts (2 in number),
amphoteric fluoroalkylamide derivative, perfluoroalkyl sulfonate salts (5), triethanolamine, and
methyl- IH-benzotriazole, with fresh water accounting for approximately 80% of the ingredients
by weight (see Table 3).12 Freshwater is the principal ingredient of all the foam concentrates
used by the Armed Forces, comprising approximately 80% - 90% of the product by weight.12"16
The protein base in fluoroprotein foam is nontoxic and biodegradable. The chemical identities
and corresponding weight percents of the surfactants in AFFF and fluoroprotein concentrates are
proprietary, but are stated by the manufacturers to be nontoxic in the quantities present in the
manufactured product, and more benign when diluted with seawater to a 3% or 6% solution.
Fluoroprotein foam and 3% AFFF used on MSC and USCG vessels contribute only 4% of the
total volume of foam discharged annually from vessels.

No priority pollutants nor bioaccumulators are known to be present hi the AFFF product
or fluoroprotein foam concentrates used aboard vessels of the Armed Forces.

The firemain provides the seawater hi the seawater foam solution. Metals and other
materials from the firemain system can be dissolved by the seawater, and particles can be eroded
and physically entrained in the seawater flow. Any wetted material in the firemain system can
become a constituent of the firemain discharge. None of the potential constituents are known
bioaccumulators. The priority pollutants in the discharge are bis(2-ethylhexyl) phthalate, copper,
nickel, and iron, which are found hi the piping of wet firemain systems.

The piping hi Navy AFFF systems is made of copper nickel alloy, the same as used in the
firemain system. Total nitrogen, bis(2-ethylhexyl) phthalate, copper, nickel, and iron from this
source will be constituents of the discharge.

3.4 Concentrations
Aqueous Film Forming Foam (AFFF)
5

-------
Table 3 shows the concentrations of the chemical constituents in AFFF concentrate. The
data are based on the type of concentrate that is most widely used. Table 3 also shows the
concentrations in the seawater foam solution.

Seawater foam discharges have not been part of the sampling program. The
concentrations of total nitrogen, bis(2-ethylhexyl) phthalate, copper, nickel, and iron contributed
from the AFFF system are not known. AFFF concentrate includes corrosion inhibitors.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of constituents in the
discharge are estimated and compared with the water quality criteria. In Section 4.3, the
potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Discharge quantities in Table 2 and constituent concentrations in Table 3 are combined to
estimate mass loadings.

Based on the approximate mass of 366,000 pounds of AFFF concentrate discharged
annually from Navy and USCG vessels, and the weight percentages of AFFF constituents, upper
bound estimates of the annual mass loadings for the constituents range from a maximum of
approximately 38,500 pounds for 2-(2-butoxyethoxy)-ethanol to a minimum of 370 pounds for
methyl-lH-benzotriazole. The mass loadings resulting from 3% AFFF and fluoroprotein foam
discharges aboard MSC vessels do not significantly change the calculated loadings because the
total volume of these concentrates represents 4.0% of the foam discharged annually.

The annual mass loadings of copper, nickel, and iron from the firemain system are shown
in Table 3, based on a total of 4,924,000 gallons of seawater used to produce foam and wash it
off the ship after the test.

4.2 Environmental Concentrations

As listed in Table 2, individual constituent concentrations in foam range from 6,400 mg/L
for 2-(2-butoxyethoxy)-ethanol down to about 61 mg/L for methyl- IH-benzotriazole. The
concentrations presented represent AFFF seawater foam constituent concentrations in the product
as discharged from hose nozzles and sprinkler heads aboard ship. These concentrations do not
take into account the additional diluting effect of any seawater used to wash the AFFF seawater
solution overboard. Thus, the concentration of the constituents in AFFF seawater solutions is
reduced when this additional dilution factor is considered. Further, the ship's motion through the
sea causes the discharge to be distributed along the ship's track, instead of being discharged hi a
single spot. Upon discharge to the environment, AFFF concentrate has been diluted 94:6 (about

Aqueous Film Forming Foam (AFFF)
6

-------
16:1) by the proportioning process, with further dilution during the wash-off procedure, followed
by rapid dispersion in the wake of a moving ship.

AFFF could potentially be discharged from vessels in amounts that cause visible foam
floating on the water surface. Floating foam detracts from the appearance of surface waters and
can violate aesthetic water quality criteria. Several states have standards to prevent "floating
debris and scum."

The bis(2-ethylhexyl) phthalate, copper, nickel, and iron constituents are the only priority
pollutants sampled which exceed acute water quality criteria. Table 4 shows the concentration of
the constituents of firemain water, total nitrogen, bis(2-ethylhexyl) phthalate, copper, nickel, and
iron, that exceed acute water quality criteria. The copper concentration exceeds both the Federal
and most stringent state criteria while the total nitrogen, bis(2-ethylhexyl) phthalate, nickel, and
iron concentrations exceed only the most stringent state criterion.

4.3 Potential for Introducing Non-Indigenous Species

AFFF and fluoroprotein concentrates do not include biota. Seawater foam discharge can
include microbial and invertebrate marine organisms, since biofouling accumulates in firemain
systems, wet and dry types. See the Firemain Systems NOD Report for a discussion of the
potential for introducing non-indigenous species in the firemain discharge.
5.0 CONCLUSION

AFFF discharges from vessels of the Armed Forces have the potential to cause an adverse
environmental impact. There is currently an operational policy and procedure that prohibits any
overboard discharge of AFFF from Navy vessels within 3 n.m. of shore, and stipulates that
discharge could only occur at a minimuni speed of 10 knots between 3 and 12 n.m. from shore.
If this policy were not hi place, the discharge could deposit significant amounts of foam on
surface water. This foam would dimmish the visual quality of the water.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, uiformation from various sources was obtained. Process
information was used to estimate the volume of discharge. Based on this estimate and on the
reported constituent percentages by weight, the concentrations of the AFFF constituents in this
discharge were then estimated. Table 5 shows the sources of the data used to develop this NOD
report.
Specific References

1. Naval Ships' Technical Manual (NSTM), Chapter 555, Vol. 1, Revision 4, pages 1-23,2-

Aqueous Film Forming Foam (AFFF)
7

-------
      6,2-7,4-22, and 4-23, Surface Ship Firefighting. 8 December 1997.

2.     Military Sealift Command (MSC), Damage Control Manual, COMSCINST 3541.5D,
      21 February 1994, page 1-10-2.

3.     Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)
      5551/026-C5, Fire Extinguishing System, Fog, Foam, and AFFF, December 1995.

4.     Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)
      5551/027-C6, Fire Extinguishing System, Fog, Foam, and AFFF, December 1996.

5.     Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)
      5551/029-86, Fire Extinguishing System, Fog, Foam, and AFFF, August 1996.

6.     Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)
      5551/031-C5, Fire Extinguishing System, Fog, Foam, and AFFF, December 1995.

7.     Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)
      5551/034-A4, Fire Extinguishing System, Fog, Foam, and AFFF, October 1994.

8.     Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)
      5551/036-A4, Fire Extinguishing System, Fog, Foam, and AFFF, October 1994.

9.     Naval Sea Systems Command (NAVSEA), Navy PMS Maintenance Index Page (MIP)
      5551/037-37, Fire Extinguishing System, Fog, Foam, and AFFF, March 1997.

10.   Office of Chief of Naval Operations (OPNAV), Environmental and Natural Resource
      Program Manual, OPNAVTNST 5090.IB,  1 November 1994.

11.   Weersing, Penny, Military Sealift Command Central Technical Activity.  Design of Fire
      Protection Systems on MSC Ships, 26 March 1997, David Eaton, M. Rosenblatt & Son, Inc.

12.   3M Material Safety Data Sheet, FC-206CF LIGHT WATER™ Brand Aqueous Film
      Forming Foam, November 13,1995.

13.   Ansul Inc. Material Safety Data Sheet, Ansulite 6% AFFF (AFC-5), May 19,1995.

14.   Chubb National Foam Inc. Material Safety Data Sheet, Aer-0-Water 6EM, March 27,1991.

15.   National Foam Inc. Material Safety Data Sheet, Aer-0-Foam XL-3 3%, October 2,1996.

16.   Ansul Inc. Material Safety Data Sheet, Ansul 3% Fluoroprotein Foam Concentrate, June
      2,1997.

17.   Poidinger, Joe, 3-M Corp; MSDS 6% AFFF Concentrate Density, 18 September 1997,

                         Aqueous Film Forming Foam (AFFF)
                                        8

-------
Anil Giri, M. Rosenblatt & Son, Inc.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
Aqueous Film Forming Foam (AFFF)
9

-------
Coast Guard Uniform Maintenance Card R-A-012, Damage Control, Auxiliary, Fire
      Extinguishing System, AFFF system.

Darwin, Robert, NAVSEA 03G2.  "AFFF Overboard Discharge." M. Rosenblatt & Son, Inc.
      Crystal City, VA. 17 September 1996.

UNDS Ship Database, August 1,1997.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
      House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
      Register, p. 15366. March 23,1995.
                         Aqueous Film Forming Foam (AFFF)
                                        10

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Table 3. Upper Bound Estimates of Annual Mass Loading and Constituent Concentrations
                                    Due to AFFF Discharge
Annual discharge of AFFF/seawater solution, gals
Annual discharge of AFFF concentrate, gals
Annual discharge of AFFF concentrate, Ibs
Annual discharge of seawater in the solution, gals
Annual discharge of cleanup seawater, gals
Annual discharge of seawater, including cleanup, gals
722,500
42,900
366,366
680,000
4,244,000
4,924,000


8.54/lb/gal density




Constituent
Fresh water
2-(2-butoxyenthoxy)-ethanol
urea
alkyl sulfate salts (2)
amphoteric fluoroalkylamide derivative
perfluoroalkyl sulfonate salts (5)
triethanolamine
methyi-lH-benzotriazole
Constituent
Total nitrogen
Bis(2-ethylhexyl) phthalate in seawater
Copper in seawater
Nickel in seawater
Iron in seawater

Wt%
Low
78.0%
9.5%
3.0%
1.0%
1.0%
0.1%
0.1%
0.0%

Wt%
High
81.0%
10.4%
7.0%
5.0%
2.0%
1.0%
1.0%
0.1%
Concentration
500 ug/L
22 ug/L
45.59 ug/L
15.24 ug/L
21.28 ug/L
Mass Loading
Low(lb)
286,000
34,800
11,000
3,700
3,700
370
370
0
High
(Ib)
297,000
38,500
25,600
18,300
7,300
3,700
3,700
370
Mass Loading
16.8 Ib
0.74 Ib
1.87 Ib
0.62 Ib
0.87 Ib
r Concentration
Low
mg/L
47,400
5,800
1,800
610
610
61
61
0






BBgh
mg/L
49,200
6,400
4,300
3,040
1,220
610
610
61






Notes:

1. Conversion: 1 ug/L = 8.345 X 10'9 Ib/gal

2. Concentrations in mg/L are for the diluted AFFF/seawater solution.  The concentrations are accurate for hoses
   discharged over the side, but overstated by about 30% for flight deck discharges which are washed over the side
   with additional seawater. Calculation is pounds of constituent, divided by gallons of discharged solution, and
   converted to mg/L.
3. Data derived from Table 2, and References 12,17.

-------
     Table 4. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituents
Classicals (ug/L)
Total nitrogen
Organics (ug/L)
Bis(2-ethylhexyl)
phthalate
Metals (ug/L)
Copper
Dissolved
Total
Iron
Total
Nickel
Total
Log-normal
Mean .,/,
Effluent .

500

22


24.9
62.4

370

15.2
, Minimum
Concentration
Effluent*



BDL


BDL
34.2

95.4

BDL
Maximum/
Concentration
Effluent-



428


150
143

911

52.1
: Federal
Acute WQG

None

None


2.4
2.9

None

74.6
Most Stringent
State Acute WQC

200 (HI)A

5.92 (GA)


2.4 (CT, MS)
2.5 (WA)

300 (FL)

8.3 (FL, GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
A - Nutrient criteria are not specified as acute or chronic values.

CT = Connecticut                               .   ,. .
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
                                   TableS.  Data Sources
>
NODSectton*
2.1 Equipment Description and
Operation " '
2:2 Releases to tKe Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
33 Constituents
3.4 Concentrations '
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species * '
Data Source
Reported
NSTMCh555

UNDS Database
PMS Cards

X
MSDS Sheets

X

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-------

-------
                        NATURE OF DISCHARGE REPORT
                                   Boiler Slowdowns
1.0   INTRODUCTION

      The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed in three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

      A nature of discharge (NOD) report has been prepared for each of the discharges that has
been identified as a candidate for regulation under UNDS. The NOD reports were developed
based on information obtained from the technical community within the Navy and other branches
of the Armed Forces with vessels potentially subject to UNDS, from information available in
existing technical reports and documentation, and, when required, from data obtained from
discharge samples that were collected under the UNDS program.

       The purpose of the NOD report is to describe the discharge in detail, including the system
that produces the discharge, the equipment involved, the constituents released to the
environment, and the current practice, if any, to prevent or minimize environmental effects.
Where existing process information is insufficient to characterize the discharge, the NOD report
provides the results of additional sampling or other data gathered on the discharge. Based on the
above information, the NOD report describes how the estimated constituent concentrations and
mass loading to the environment were determined. Finally, the NOD report assesses the
potential for environmental effect. The NOD report contains sections on: Discharge
Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data
Sources and References.
                                   Boiler Slowdown
                                           1

-------
2.0 DISCHARGE DESCRIPTION

This section describes boiler blowdown and includes information on: the equipment that
is used and its operation (Section 2.1), general description of the constituents of the discharge
(Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

There are two ways to produce steam for use on ships: conventionally powered boilers
and nuclear powered ship steam generators. Conventionally powered boilers and nuclear
powered ship steam generators are discussed separately hi this report.

2.1.1 Conventionally Powered Ship Boiler Blowdown

Boilers are used to produce steam for the majority of surface vessels that have steam
systems. Aboard conventionally powered steam ships, the main propulsion boilers supply steam
at high pressure and temperature to the main propulsion turbines, ship service turbogenerators,
and a host of auxiliary and hotel services. Many gas turbine and diesel-powered ships have
auxiliary or waste heat boilers that produce steam at relatively low pressure for hotel services.

The water supplied to the boiler system (feedwater) is treated to minimize the formation
of scale and to inhibit corrosion in the boiler and boiler system piping. All main propulsion
boilers in the Navy now use the chelant treatment system, which replaced the coordinated
phosphate (COPHOS) treatment system used hi main propulsion boilers.1 Main and auxiliary
boilers of the Military Sealift Command (MSC) ships use boiler feedwater chemistry prescribed
by the original equipment manufacturer.2 Auxiliary boilers aboard U.S. Coast Guard (USCG)
vessels are treated in accordance with USCG instructions.

The process of boiling water to make steam creates higher concentrations of particulates
(the result of corrosion products and sludge forming minerals in the boiler water) and chemicals
in the boiler water. The feedwater that is added to maintain the water level in the boiler (boiler
water) has a lower concentration of chemicals and dilutes the chemical concentrations that
develop during steam generation. Even with careful boiler water treatment management, water
or a water/steam mixture must be periodically released from the boiler to remove particulates and
sludge and to control boiler water chemical treatment concentrations. This process is referred to
as a "boiler blowdown." Blowdowns are accomplished by releasing controlled amounts of boiler
water through sea connections that exit the ship below the waterline.

There are four types of boiler blowdown procedures: surface blowdown, scum
blowdown, bottom blowdown, and continuous blowdown. Surface blowdowns are used to
remove particulates and dissolved materials in the boiler water and to control boiler water
chemistry. If contamination or boiler water treatment chemical over-addition exist, both are
reduced by a surface blowdown. Scum blowdowns are used to. remove surface scum. Bottom
blowdowns are used to control the amount of sludge in the boiler water. Continuous blowdowns
Boiler Blowdown
2

-------
are used in all chelant treatment systems to rid the boiler of dissolved metal chelates and
suspended matter.1 All boiler blowdowns are performed in accordance with published guidance.

In all cases, except bottom blowdown, blowdowns can be conducted while the boiler is
operating. Bottom blowdowns for propulsion and auxiliary boilers are conducted only when the
boiler is secured.1 Waste heat boiler bottom blowdowns can be conducted while the boiler is
operating. The four boiler blowdown procedures are conducted in the following ways:

• Surface blowdowns discharge approximately five percent of the total volume of
water in the boiler.4'5 During a surface blowdown, the water level in the boiler is
increased three to four inches, the surface blowdown valve is opened and then
closed when the boiler empties to the normal water level.

• Scum blowdowns discharge approximately one percent of the total volume of
water in the boiler.4'5 During a scum blowdown, the water level in the boiler is
increased by one inch and the surface blowdown valve is opened and then closed
when the boiler empties to the normal water level.1

• Bottom blowdowns discharge approximately ten percent of the total volume of
water in the boiler.4'5 For a bottom blowdown, the water level in the boiler is
increased six inches, the bottom blowdown valve is opened and then closed when
the boiler empties to the normal water level.1

• Continuous blowdowns discharge approximately four percent of the total volume
of water in the boiler per day.5'6 This discharge flows to the bilge of the vessel.
Thus, continuous blowdowns are not considered in the total blowdown volume in
this report and are covered by the Surface Vessel Bilgewater/OWS Discharge
NOD Report.

Ships normally receive steam and electrical power from the pier while they are in port
during extended upkeep periods. However, there are occasions when a steam powered ship can
have a main propulsion boiler operating in port or at anchor for the operation of a turbogenerator
set and to provide hotel service steam. Auxiliary boilers can also be operated in port to provide
hotel service steam. When a boiler is secured in port (laid-up), one of six different methods is
used. Only one of these methods, placing the boiler under a steam blanket, results in boiler
blowdowns. A secured boiler is placed under a steam blanket by keeping steam continuously
applied to the boiler. This steam can be from shore or from an operating boiler on the ship. The
steam blanket excludes oxygen, thereby minimizing the potential for corrosion in the boiler.
Boilers under a steam blanket require a blowdown because the steam applied to the boiler
condenses and increases the boiler's water level. A blowdown returns the water to its proper
level.
Boiler Blowdown
3

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2.1.1.1 Chelant Feedwater Treatment

The chelant system adds ethylenediaminetetraacetic acid (EDTA) to the boiler feedwater
in powder form. Only distilled water is used as feedwater in the system. EDTA reacts with
metal ions and forms soluble metal chelates (that do not precipitate) that are removed during
blowdowns.7 This helps reduce boiler scaling by removing calcium and magnesium. Hydrazine
is used to eliminate residual dissolved oxygen in the feedwater, thus inhibiting the corrosive
effects of oxygen in the boiler.

2.1.1.2 Coordinated Phosphate Chemistry

COPHOS systems treat the feedwater to the boiler to reduce boiler scale and corrosion,
thus ensuring boiler system reliability. COPHOS systems also use only distilled water as
feedwater. Chemicals such as trisodium phosphate, disodium phosphate, and sodium hydroxide
are used to precipitate scale forming magnesium and calcium.1

Auxiliary and waste heat boilers on Navy ships use a feedwater chemical treatment
system similar to COPHOS. This system uses disodium phosphate to reduce boiler corrosion
and scale.1

2.1.1.3 Drew Ameroid Chemistry

Drew Ameroid systems treat the feedwater to the boiler with disodium phosphate,
sodium hydroxide, and morpholine to control scale and corrosion in the boiler. Main propulsion
boilers aboard MSC ships, operating at pressures greater than 850 pounds per square inch (psi),
use the Drew Ameroid "Ultra Marine" system of treatment. Main propulsion boilers aboard
MSC ships, operating at pressures less than 850 psi, use the Drew Standard system. Auxiliary
and waste heat boilers on MSC ships use the Drew AKG-100 chemical treatment system.2 Three
different treatment systems are used due to the different operating temperatures of each type of
boiler. The treatment chemicals are the same for all three systems but the proportions of the
chemicals are different depending on the operating temperature of the boiler.

2.1.1.4 USCG Boiler Water Chemistry

There are no steam-powered ships in the USCG; however, many USCG ships have
auxiliary boilers. The preferred method of water treatment in the USCG is a magnetic water
treatment (MWT) system, which does not utilize any chemicals. The MWT system uses a device
that generates a magnetic field in the water stream to help prevent scale formation. Although the
preferred method of treatment is MWT, some USCG ships treat their boiler water with
COPHOS, as defined by Navy guidance.3'8

2.1.2 Nuclear Powered Ship Steam Generator Slowdown

All nuclear-powered ships have steam generators which require periodic blowdowns
(typically about once per week) to maintain safe operation of the system.4 Section 3 and 4

Boiler Slowdown
4

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contain discussions of constituents, concentrations, and mass loadings from nuclear powered
ships steam generators, but further information on the process description is classified.

2.1.3 Safety Valve Testing

Testing is necessary to ensure the proper operation of all main and auxiliary boiler safety
valves. Safety valves are installed on each boiler to prevent a boiler rupture in the event of
excessive pressure buildup. They are installed on the upper portion of the boiler and only
discharge steam. Unlike surface and bottom blowdowns, liquid and particulate matter are not
discharged from safety valves. Main propulsion boilers usually have three or four safety valves,
and auxiliary or waste heat boilers have two valves. Periodic testing results in a very short
discharge of steam at full boiler pressure to the atmosphere through an escape pipe on the ship's
smokestack. This testing must be performed annually for each boiler. Safety valves must also be
tested after each boiler hydrostatic test and whenever a boiler is placed back in service after a
repair.9 For MSC ships, safety valve tests are performed annually during each USCG inspection.
These tests are typically performed in port.

Safety valves are tested to measure the exact pressure at which the safety valves fully lift
and reset. These pressures are defined by the boiler specifications. If the valves do not lift or
reseat at the specified pressure, the test must be repeated after making adjustments to the safety
valves until the exact pressures are met.8 Although steam is discharged at full boiler pressure,
the release is to the atmosphere through an escape pipe on the back of the smokestack and only
small amounts of condensate reach the water. The discharge is in the form of water vapor
released to the atmosphere.

Safety valve testing is also performed on each nuclear powered ship steam generator.
This discharge is identical to safety valve testing on conventionally-powered ship boilers;
however, the discharge exits below the waterline instead of being released to the atmosphere
through an escape pipe. Safety valve testing is performed once every five years on each nuclear
steam generator.

2.2 Releases to the Environment

Boiler and steam generator blowdown discharges are infrequent, of short duration
(seconds), in small volumes (approximately 310 gallons maximum), and at high pressures (up to
1200 psi). The discharge consists of water and steam or sludge-bearing water at elevated
temperatures (above 325° F) and pressures. The discharge can contain metals or boiler water
treatment chemicals. The frequency of the discharge is based on boiler and steam generator
water chemistry and operation and is therefore not predictable. Boiler and steam generator
blowdown discharges are released through hull fittings located below the ship's waterline
(underwater discharge).
Boiler Blowdown
5

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2.3 Vessels Producing the Discharge

Table 1 list the various Navy, MSC, and USCG vessels which generate boiler blowdown
discharge. Ships that use steam for propulsion purposes produce the largest volume of discharge.
These ships use high pressure steam (1200 and 600 psi steam systems) to drive propulsion and
auxiliary equipment. Diesel and gas turbine powered ships can use fuel fired or waste heat
boilers, which operate at pressures up to 150 psi, to generate steam for auxiliary systems.
Vessels that use auxiliary and waste heat boilers are also identified in Table 1. All nuclear
powered ships have steam generators. There are 89 submarines, 3 nuclear powered cruisers, and
8 nuclear powered aircraft carriers that blow down steam generator water.4 Army, Marine Corps,
and Air Force vessels do not utilize steam systems and do not generate this discharge.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Boiler blowdowns can occur when a boiler is operating, after it has been secured, or when
under a steam blanket. Thus, these discharges occur within and beyond 12 nautical miles (n.m.)
from shore. Safety valve testing on nuclear powered ship steam generators only occurs in port.

3.2 Rate

The volume of water hi the boiler while steaming (steaming volume) is used to determine
the amount of water/sludge discharged during surface, scum, and bottom blowdowns. These
volumes are listed in Table 1 for each ship class and a sample calculation is provided below.1
Surface blowdowns discharge five percent of the steaming water volume, scum blowdowns
discharge one percent of the steaming water volume, and bottom blowdowns discharge ten
percent of the steaming water volume.1 The number of blowdowns per year within 12 n.m. were
estimated based on a Naval Ship Systems Engineering Station report on boiler blowdown
discharges and revised based on vessel operation within 12 n.m.5'10 These estimates for each
ship category are listed in Table 2. USCG ships with MWT do not use chemical boiler water
treatments, but are included in the blowdown table to include then: thermal effect and because
their blowdown contains metal constituents.3 USCG ships with COPHOS treated feedwater are
also included in the table. The majority of USCG vessel operations are typically performed
within 12 n.m. of shore; therefore, the total number of bottom and surface blowdowns is higher
than for Navy vessels.10'11
Boiler Blowdown
6

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Boiler Slowdown,Volume, gaLperyear = (dischargeXnmnber of blowdowns) , '„
Where: ^ " •"" : \ ' ." . '. " ' * ?, '' . ,-/,_ .. ' , \
discharge (gal) = (Boiler steaming volume; gal)(perceafvolume discharged per blbwdown), »
number of blowdowns =number;£f Mowdowns with 12 njn. peryear ^ v £

The total blowdown discharge volume within 12 n.m. of shore is 570,860 gallons for
Navy main propulsion boilers and 190,348 gallons for Navy auxiliary and waste heat boilers.
Total blowdown discharge volume within 12 n.m. is 205,800 gallons for MSC main propulsion
boilers and 58,500 gallons for MSC auxiliary and waste heat boilers. The total blowdown
discharge volume from USCG auxiliary boilers is 93,600 gallons. The total boiler blowdown
discharge volume within 12 n.m. for all Navy, MSC, and USCG ships is 1,119,108 gallons.

Blowdowns for nuclear powered ships steam generators results in a total volume of
3,615,000 gallons per year.12

The volume discharged from safety valve testing on nuclear powered ships steam
generators is not available. The safety valves are tested once every five years. The available
information is in the form of mass loadings and is discussed in Section 4.1.

3.3 Constituents

Boiler blowdown for conventionally powered ships (e.g., steam, diesel, and gas turbine)
was sampled under the UNDS sampling program. Samples were taken from five ship classes:
the LHD 1 class, the CG 47 class, the LSD 49 class, the T-AO 187 class, and WHEC 378 class.
LHD 1 class uses chelant water treatment; CG 47 and LSD 49 classes use COPHOS water
treatment; T-AO 187 class uses the Drew Ameroid water treatment; and WHEC 378 uses
magnetic water treatment. Boiler samples were analyzed for metals, organics, and classicals
based on the boiler blowdown process, system designs, and analytical data available, hi addition,
hydrazine, a boiler treatment chemical, was specifically tested for since it was not hi the
aforementioned analyte classes and it was most likely to be present in boiler blowdown. The
results of the sampling are provided in Table 3.

The surface blowdown sample for T-AO-187 class was contaminated at the sampling
station, which is also used by the ship to sample diesel jacket water (a closed loop cooling
system) through common sampling piping.13 The bottom blowdown sample was taken from the
same sampling system, but was completed after the surface blowdown sample was taken and
after additional flushing of the piping system had occurred. The constituent concentrations for
the bottom blowdown sample appear to be similar to other systems sampled. Even though the
surface blowdown constituent concentrations are suspect, they have been used to calculate mass
loadings since no other data is available at this time.

The sampling of nuclear powered ships steam generators was conducted separate from the
sampling performed on conventionally-powered boilers. Constituent data for nuclear powered
ships steam generators is listed in Table 4.12
Boiler Blowdown
7

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Of the constituents detected in boiler and steam generator blowdown and safety valve testing
discharges, antimony, arsenic, cadmium, copper, chromium, lead, nickel, selenium, thallium,
zinc, and bis(2-ethyUiexyl) phthalate are priority pollutants as defined by the EPA. There are no
constituents in boiler or steam generator blowdown that have been identified as bioaccumulators.

3.4 Concentrations

A summary of the analytical results are presented in Table 3.14 This table shows the
constituents, the log-normal mean or concentration value for single sample data, the frequency of
detection for each constituent, the minimum and maximum concentrations for multiple sample
data, and the mass loadings of each constituent. For the purposes of calculating the log-normal
mean, a value of one-half the detection limit was used for non-detected results. The
concentrations of constituents in nuclear powered ships steam generator blowdowns are provided
in Table 4.15 No constituent concentration data are available for safety valve testing discharges.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. hi Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria.
Section 4.3 discusses thermal effects, hi Section 4.4, the potential for the transfer of non-
indigenous species is discussed.

4.1 Mass Loadings

Based on the discharge volume estimates developed hi Tables 1 and 2 and the log-normal
mean discharge concentrations, mass loadings are presented in Table 3. Table 5 is present in
order to highlight constituents with log-normal mean concentrations that exceed ambient water
quality criteria. A sample calculation of the estimated annual mass loading for copper is shown
here:
Mass Loading for Copper (Total)
Mass Loading = (Net Positive Log-normal Mean Concentratkm)(Flow Rate)
(203 ng/L)(3.785 L/gal)(590,343 gal/yr)(g/l,000,000 ng)(lb/453.593 g)s 1ijb/yr
The annual mass loadings are reported for the entire fleet. The total annual discharge of
copper is only 7.2 pounds per year for conventionally powered ships which is discharged over a
large geographical area. The largest metal mass loading discharged is iron at 37.5 pounds per
year for conventionally powered boilers which is discharged over a large geographical area.
These loadings include the constituent concentration data from the T-AO 203 surface blowdown
sample even though this sample has been determined to be contaminated.

The annual mass loadings per ship class are reported for the ship classes that the samples

Boiler Blowdown
8

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were taken. The total loading of copper for the LHD 1 class (Chelant) is 0.063 pounds, for the
CG 47 and LSD 49 classes (COPHOS) is 1.6 pounds, for the WHEC 378 class (MWT) is 0.008
pounds, and for the T-AO 187 class (Drew) is 0.194 pounds. A sample calculation of the
estimated annual mass loading for copper on the LHD 1 is shown here:
Mass Loading on the LHD 1 for Copper (Total)/   ~« ;   ,^              's-;
   = (Surface Slowdown Log-normal Mean,Concentration)(Surface Slowdown Flow Rate), + '^
     (Bottom Slowdown Log-normal Mean Concentration)(Bottoni"Blowdownt Flow Rate)
  ^ = (203 ng/L)(3.7851%d)(32,240 gal/yr)(g/l ,OQO,000$ig)Ob/453.593 g) -K : "        ,  .,
     (40.6 ng/L)(3.78S L/gal)(24,800 gal/yr)(g/l,o6o>000 pg)(lb/453.593g) s 0.063.1b/yr
       Nuclear powered ships steam generator blowdown mass loadings are listed in Table 6.
The annual mass loading of copper from nuclear powered ships steam generators is
approximately 3.2 pounds per year.

       The total annual discharge of copper is only 11.62 pounds for the entire fleet or 0.03
pound per ship per year, which is discharged over a large geographical area. The largest metal
discharge is iron at approximately 38.5 pounds annually for the entire fleet or 0.11 pound per
ship per year.

       Since safety valve testing releases only steam, and not liquid nor particulate matter as hi
surface and bottom blowdowns, the mass of constituents discharged is expected to be much
smaller than that discharged from boiler blowdown.  Table 7 lists the discharges from safety
valve testing from nuclear powered ships steam generators.15  The total mass loadings of all
constituents  for all nuclear powered ships for safety valve testing is approximately 4.38 pounds
per year.

       4.2   Environmental Concentrations

       The constituent concentrations and their corresponding Federal and most stringent state
water quality criteria (WQC) are listed in Tables 8 and 9. These tables include the constituent
concentrations from the T-AO 203. Federal and most stringent state WQC for metals are based
on the dissolved fraction of the metal.
       For conventionally powered boilers, copper concentrations for all feedwater treatment
systems exceeded Federal and most stringent state WQC. Iron concentrations for all feedwater
treatment systems exceeded Florida's WQC. Lead concentrations for all feedwater treatment
systems, except chelant, exceeded Florida's and Georgia's WQC but did not exceed the Federal
WQC except for Drew Chemicals feedwater treatment. Nickel concentrations for the chelant,
Drew Chemicals and COPHOS feedwater treatment systems exceeded Federal and most stringent
state WQC.  Nickel concentrations for the magnetic water treatment system exceeded the most
stringent state (Florida and  Georgia) WQC but did not exceed the Federal WQC. Zinc
concentrations for the chelant, Drew Chemicals and COPHOS feedwater treatment systems
exceeded Federal and most stringent state WQC. Nitrogen (as ammonia, nitrate/nitrite, and total
kjeldahl nitrogen) concentrations for all feedwater treatment systems exceeded most stringent
state WQC.  Phosphorous concentrations for all feedwater treatment systems other than Drew

                                   Boiler Blowdown
                                           9

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Chemicals for Bottom Slowdown exceeded most stringent state WQC. Bis(2-Ethylhexyl)
phthalate for Drew Chemicals feedwater treatment systems and COPHOS Bottom Slowdown
feedwater treatment system exceeded most stringent state WQC.

For nuclear powered ships steam generators, copper concentrations exceed Federal and
most stringent state WQC. Lead concentrations exceed Florida's WQC. Nickel concentrations
for the CVN 65 carrier exceed both Federal and most stringent state water quality criteria; all
other ships are below the Federal WQC for nickel, but are above the most stringent state WQC.
Nitrogen (as ammonia, nitrate/nitrite, and total kjeldahl nitrogen) and phosphorous exceed the
most stringent state WQC.

Although the concentrations of copper from boiler blowdowns are greater than water
quality criteria at the point of discharge, the turbulent mixing, pressure of the blowdown
discharge, and small volumes of the blowdown will cause concentrations to decrease rapidly.
The estimated discharge velocity at boiler pressure (1200 psi) is 422 ft/sec. This translates to
discharge rates of 68 gal/sec for a 2.0 inch diameter discharge fitting and 38.74 gal/sec for a 1.5
inch discharge fitting. As a comparison, at 100 psi (auxiliary boiler pressure) the discharge
velocity is 121 ft/sec, which translates to a discharge rate of 11.22 gal/sec from a 1.5 inch
diameter discharge fitting. The LHA1 class ships have the boilers that produce the largest
volume blowdown of 310 gallons. A bottom blowdown from a boiler on an LHA 1 class ship
will only discharge 0.09 grams of copper. Therefore, it is expected concentrations of copper,
lead, and nickel will fall below WQC briefly after discharge.

4.3 Thermal Effects
i
The potential for boiler blowdown to cause thermal environmental effects was evaluated
by modeling the thermal plume for boiler blowdown generated under conservative conditions and
then comparing the calculated thermal plume to the state thermal plume size requirements. The
thermal effects were modeled by using a batch discharge approach which uses thermodynamic
equations and geometry to estimate the plume size. The steps to estimate the maximum size of
the thermal plume for a given acceptable mixed temperature are given below:16

• calculate the total heat and mass injected in a blowdown;
• calculate the volume of water needed to dilute this mass of water such that the
acceptable mixed temperature is obtained; and
• use geometry to find the region centered on the release point (and assuming a totally
vertically mixed column) that will provide the volume required to reduce the
temperature to the desired temperature criteria.

The discharge is directed downward at a high flow rate and at high velocities. Therefore,
the plume is assumed to expand outward and equally in all directions, thus forming a vertically
cylindrical shape. The velocity of the discharge at the discharge fitting would be 422 ft/sec,
which would put the discharge rate at 68 gal/sec from a 2.0 inch diameter discharge fitting and
38.74 gal/sec from a 1.5 inch diameter discharge fitting. As a comparison, at 100 psig (auxiliary
boiler pressure), the velocity of the discharge would be 121 ft/sec, which would put the discharge

Boiler Blowdown
10

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rate at 11.22 gal/sec from a 1.5 inch diameter discharge fitting.

The bottom blowdown discharges from an LHA 1 Class vessel and an AFS 1 Class vessel
were modeled. The LHA 1 uses the chelant treatment system and has main propulsion boilers
(the largest size) and the AFS 1 uses Drew chemistry with average size boilers. They represent a
large boiler blowdown volume and an average boiler blowdown volume. The LHA was modeled
with a batch discharge of 310 gallons at roughly 504 °F (262 °C) through a 2-inch diameter pipe
at the bottom of the ship. The AFS 1 was modeled with a batch discharge of 150 gallons at 495
°F (257 °C) through a 1.5-inch diameter pipe at the bottom of the ship. A sample calculation is
provided at the end of this report. The plume characteristics were compared to thermal mixing
zone criteria for Virginia and Washington State, which are the only two states with established
thermal plume mixing zone criteria. The Washington State thermal regulations require that when
natural conditions exceed 16 °C, no temperature increases will be allowed that will raise the
receiving water temperature by greater than 0.3 °C. The mixing zone requirements state that
mixing zones shall not extend for a distance greater than 200 feet plus the depth of the water over
the discharge point, or shall not occupy greater than 25% of the width of the water body. The
Virginia thermal regulations state that any rise above natural temperature shall not exceed 3 °C.
Virginia's mixing zone requirements state that the plume shall not constitute more than one-half
of the receiving watercourse. They shall not extend downstream at any tune a distance more than
five times the width of the receiving watercourse at the point of discharge.

The assumptions for all the thermal modeling conducted under the UNDS program are
listed below and the results of the thermal modeling for this discharge are summarized in Table
II.16

• The discharge will occur during a simulated slack tide event, using a minimum water
body velocity (0.03 m/s);
• The discharge would occur during the winter months (largest difference in
temperature between the discharge and receiving water temperatures), which results
in the largest thermal plume; and
• The average depth of water at the pier is 40 feet.

Using these assumptions, boiler blowdown discharges from all Navy ships meet Virginia
and Washington State thermal mixing zone criteria, Table 10.16

Safety valve testing from nuclear powered ships steam generators is discharged in small,
intermittent bursts of steam that condenses when reaching the water. The volume of water
discharged is too small to be effectively modeled and the thermal effects are negligible due to the
immediate mixing with surrounding waters.

4.4 Potential for Introducing Non-Indigenous Species

The potential for introducing non-indigenous species is not significant, since the source
of the water is treated freshwater that is heated to high temperatures (over 325 °F) and high
pressures (up to 1200 psi).

Boiler Blowdown
11

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5.0 CONCLUSIONS

5.1 Boiler and Nuclear Powered Ship Steam Generators Slowdowns

Boiler and nuclear powered ships steam generator blowdowns have a low potential to
cause an adverse environmental effect because:
• Mass loadings of copper, lead, nickel, bis(2-ethylhexyl) phthalate, ammonia, nitrogen,
and phosphorous are small.

• This discharge rapidly dissipates because it occurs at high flow rates (up to 68 gal/sec)
and it is a small volume (310 gallons or less). Modeling the discharge plume shows
the constituent concentrations and temperature will be below water criteria within a
short distance from the ship for all ship classes that discharge boiler blowdown.

• Boiler blowdown is discharged intermittently throughout the U.S. at Armed Forces
ports, and each individual port receives only a fraction of the total fleetwide mass
loading.

5.2 Safety Valve Testing

Safety valve testing discharge from nuclear powered ships steam generators is released to
the water. However, the total mass discharged is small, only 4.38 pounds of all constituents per
year for all nuclear powered ships combined. The small volumes of the discharge cause the
thermal loading to dissipate in the receiving waters almost immediately after entry. Therefore,
safety valve testing has a low potential to cause an adverse environmental effect.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Sampling
data from four surface ships provided concentrations, and mass loadings were calculated from
the rate and the concentrations. Table 13 shows the source of data used to develop this NOD
report.

Specific References

1. Naval Ships' Technical Manual (NSTM), Chapter 220, Volume 2, Revision 7, Boiler
Water/Feed Water Test & Treatment. Pages 21-18 to 21-26, 22-1 to 22-51, 29-1 to 29-
41, 30-9 to 30-25, and 31-1 to 31-36. December 1995.
Boiler Blowdown
12

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2. Drew Ameroid Marine Division, Ashland Chemical Company. Fax Transmission to
George Stewart on Boiler Control Limits. January 1997.

3. Coast Guard Specification, Chapter 220 Boilers and Force Circulation Steam Generators.
COMDTINST M9000.6B.

4. UNDS Equipment Expert Structured Questions - Nuclear Steam Generator Slowdown.
August 16,1996. Amy J. Potts NAVSEA 08U.

5. Boiler Slowdown Discharges, Naval Ship Systems Engineering Station Serial No. 9220,
Ser 044C/4060. August 23,1991.

6. UNDS Equipment Expert Meeting Minutes. Boiler Slowdown. August 16,1996.

7. Chelant Boiler Feedwater Treatment Implementation - Report of Travel. Naval Surface
Warfare Center, Carderock Division, Serial No. 9220, Ser 622/296. March 10,1995.

8. Personal Communication Between LT Joyce Aivalotis, USCG, and Leslie Panek, Versar,
Inc., Information on Boiler Water Treatment. April 9,1997.

9. Naval Ship's Technical Manual (NSTM), Chapter 221, Vol. 1. Boilers. Pages 1 to 6,12
to 30,106 to 124,173,184 to 187, and 205 to 209. September 15,1993.

10. Personal Communication Between Leslie Panek, Versar, Inc., and George Stewart, M.
Rosenblatt & Son, Inc., Boiler Slowdown Frequency Within 12 n.m. February 3,1997.

11. Personal Communication Between LT Joyce Aivalotis, USCG, and Craig Berry, M.
Rosenblatt & Son, Inc., Information on Coast Guard Slowdown Practices. September 12,
1997.

12. NAVSEA Memo Ser. 08U/C97-13818 dated 17 September 1997, Nuclear-Powered Ship
Steam Generator Slowdown Effluent Data for UNDS Discharge Characterization.

13. Personal Communication Between Craig Berry, M. Rosenblatt & Son, Inc., and Paul
Devoe, MSC, on 21 October, 1997.

14. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

15. UNDS Equipment Expert Meeting Action Item Response from Charles Taylor, NAVSEA
08. Provide Information on Safety Valve Testing on Nuclear Ships. May 12,1997.

16. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed
Services. Versar, Inc. July 3,1997.

General References
Boiler Slowdown
13

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USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida, Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
I
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Blank, David A.; Arthur E. Bock; and David J. Richardson. Introduction to Naval Engineering,
Second Edition. Naval Institute Press, 1985.
Boiler Slowdown
14

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Gallic, Ejup N. and Tyler G. Hicks. Essential Engineering Information and Data. McGraw-Hill,
      Inc., 1991.

Memorandum for the Director of Environmental Protection/Occupational Safety and Health,
      SEA-OOT. "Implementation of Vessel Uniform National Discharge Standards for Liquid
      Effluents."  March 29,1996.

Baumeister, Theodore; Eugene A. Avallone; and Theodore Baumeister, EL Marks' Standard
      Handbook for Mechanical Engineers. McGraw-Hill Book Company, 1978.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
      House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A.  Volume 60 Federal
      Register, p. 15366.  March 23, 1995.

UNDS Ship Database, August 1,1997.
                                  Boiler Slowdown
                                        15

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                                 Calculation Sheet # 1
                   Thermal Batch Discharge Screening Calculations
A. Assumptions and Given Conditions:

   1. Saturated liquid heat loss(specific heat, Cp) from 262 °C down to 100 °C emits 0.9 cal/g-°C
   2. Water heat loss (specific heat, Cp) from 100 down to regulation temperature (7.44°C
      Virginia regulation) emits 1 cal/g-°C
   3. Heat transfer will occur under conditions of constant pressure
   4. Maximum rise in water temperature will be assumed to equal the Virginia regulation of
      3°C
   5. Ambient temperature is assumed to be 4.44 °C
   6. Assume plume will disperse in the shape of a vertical cylinder 4 m in depth
   7. Calculations will be based on an LHA 1 blowdown event, therefore:
      •      Blowdown discharge temperature is assumed to be 262 °C
      •      Blowdown discharge volume is assumed to be 310 gallons

The heat required to change temperature without a phase change is given by the following
equation:

                                   Q = (m)(Cp)(AT)

                   where:  Q = heat (calories)
                           m = mass of water (grams)
                           Cp = constant pressure specific heat (cal/g-°C)
                           AT = change in temperature (°C)
B. Determine Mass of Water in Discharge:

 Initial volume of water in steam form is 310 gallons of water (LHA 1 Blowdown):

  Conversion from gallons of water to mass of water:
             (8.343 lbs/gallons)(454 grams/lbs)(310 gallons) = 1.17 x 106 grams


C) High Temperature Water Heat Loss

                                    Q = (m)(Cp)(AT)
                   Q = (1.17 x 106 grams)(0.9 cal/gram/°C)(262 - 100 °C)
                                Q = 170,586,000 calories
                                   Boiler Blowdown
                                          16

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D) Water Heat Loss
                                    Q = (m)(Cp)(AT)
            Q = (1.17 x 106 grams)(l cal/g-°C)(100 - 7.44 °C(Virginia regulation))
                                Q = 108,295,200 calories
E). Determine Volume of Surrounding Water to Absorb Heat

Calculate the volume of surrounding water required to absorb heat in order to obtain completely
mixed water at the regulatory limit (gallons). Assume that the heat lost by the steam and water in
the discharge is the same as the heat gained by the surrounding water.

   i)    Mass of Water Required
       Let X= the mass of water required to obtain the mixture, then
                                       = (m)(Cp)(AT)
            (108,295,200) + (170,586,000) = (X grams of water)(l cal/g-°C)(3 °C)
                                 92,960,400 grams = X

       Converting to gallons:
           , (92,960,400 grams)(l lb/454 grams) (1 gall/8.3431bs) = 24,542 gallons

  ii)   Total Volume of Water Required to Meet Virginia Regulations = 24,542 gallons + 310
gallons
                                                     = 24,850 gallons


F).  Determine Dimensions of Cylinder

The cylinder of water (estimated plume shape) over the water depth to bottom of 4 m (estimated
value based on process knowledge):

Volume = 24,850 gallons x 0.0037854 m3/gallon - 94 m3

Volume = (7i)(d2/4)(h) where d = cylinder diameter and h = cylinder height

             Rearranging:

d2=(vol)(4)/(7t)(h)
                   h=4 m (water depth to bottom)
                   vol=94 m3

d = 5.5m (diameter of plume cylinder)
                                   Boiler Blowdown
                                          17

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-------
Table 2. Estimated Slowdown Frequencies for Calculation of Total Boiler Slowdown
Volume within 12 n.m.
Armed Force Owner and
Softer Type
Navy
Main Propulsion
Auxiliary and Waste Heat

MSC
Main Propulsion
Auxiliary and Waste Heat

USCG*
Auxiliary

Number of Surface
Blowdowns per year per
boiler within 12 n.m.

22
25

; •'- - ;• : Number of Scum 'f^ .
Blowdowns per year per
•;. boiler withinl2 njn: •

20
10

none

Number of Button*
Blowdowns per year per
" boiler within 12 n.m. • •

10
20

Notes:
Information taken from a NAVSSES Memo of 23 August 1991,5 detailing boiler blowdowns per year and revised
based ship operation, time in port, and operation within 12 n.m.
* - The USCG auxiliary boilers conduct surface blowdowns once per day.
Most of their activity is performed within 12 n.m. and therefore the number of bottom blowdowns are elevated to
control boiler water chemistry.
Boiler Slowdown
20
-------
TableS. Summary of Detected Analytes
Constituent < / ,
- Chelant Surface Slowdown
CLASSICALS
Alkalinity
Ammonia As Nitrogen
Biochemical Oxygen Demand
Chloride
Nitrate/Nitrite
Sulfate
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (Toe)
Total Phosphorous
Total Sulfide (lodometric)
Volatile Residue
JS8®J&33B*E '" " - ~" * ' c
Hydrazine
METALS
Aluminum
Dissolved
Total
Antimony
Dissolved
Total
Arsenic
Dissolved
Total
Barium
Dissolved
Total
Boron
Total
Calcium
Dissolved
Total
Cobalt
Total
Copper
Dissolved
Total
Concentration
(mg/LT
38
0.44
8
24
0.23
12
290
2.5
13
0.97
7
184
(mg/L)
0.009
(Hg/L)

630
494

8.3
9.7

1
2.5

1.7
2.2

29.6

51.6
114

10.7

207
203
_ Frequency of
Detection
'
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofi
' " -_:
lofl
_:

lofl
lofl

lofl

lofl
lofl

lofl

lofl
lofl
Mass Loading
(Ibs/vr)
102
1
21
64
1
32
779
7
35
3
19
494

0.03
(lbs/yr>

2
1

0.022
0.026

0.003
0.007

0.005
0.006

0.080

0.1
0.3

0.03

1
1
Boiler Slowdown
21
-------
Constituent
Chelant Surface Slowdown
METALS (Cont'd)
Iron
Dissolved
Total
Magnesium
Dissolved
Total
Manganese
Dissolved
Total
Molybdenum
Dissolved
Total
Nickel
Dissolved
Total
Sodium
Dissolved
Total
Zinc
Dissolved
Total
ORGANICS
Benzoic Acid
Concentration
(Mg/L)

626
884

179
195

93.5
95.5

17.6
18.1

1,860
1,810

40,100
39,300

594
601
• (ug/L}
1,230
Frequency of
Detection

lofl
lofl

lofl
lofl
•^;<^::- -:- " --fe>
lofl
Mass Loading
(Ibs/yr)

2
2

0.5
1

0.3
0.3

0.05
0.05

5
5

108
106

2
2
(Ibs/yi) •
3
Boiler Slowdown
22
-------
Table 3. Summary of Detected Analytes (Cont'd)
Constituents of '9
Chelant Bottom Slowdown
CLASSICALS ,' - ;
Alkalinity
Ammonia As Nitrogen
Biochemical Oxygen Demand
Chloride
Nitrate/Nitrite
Sulfate
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (TOC)
Total Phosphorous
Total Recoverable Oil And Grease
Total Sulfide (lodometric)
Volatile Residue
METALS* , -*
Aluminum
Dissolved
Total
Antimony
Dissolved
Total
Arsenic
Total
Barium
Dissolved
Total
Calcium
Total
Copper
Dissolved
Total
Iron
Dissolved
Total
Manganese
Dissolved
Total
Molybdenum
Dissolved
Total
Concentration
-, \ ~.
/ / —
(mg/P
30
0.11
9
13
0.39
7,830
102
0.47
12
8.4
2.45
4
50
*Oig/L>

430
477

4.5
5.55

1.3

0.75
0.85

94.5

75.9
40.6

L_ 222
344

59.9
61.3

16
18.2
Frequency of
Detection
.. •—,. -"
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl

lofl
lofl

lofl

lofl
lofl

lofl

lofl
lofl

lofl
lofl
Mass Loading
> (Ibs/yr) •*"'„
62
0.2
19
27
1
16,183
211
1
25
17
5
8
103
(Ibs/yr) ,

1
1

0.009
0.011

0.003

0.002
0.002

0.2

0.2
0

0.5
1

0.1
0.1

0.03
0.04
Boiler Slowdown
23
-------
Constituents of
Chelant Bottom Slowdown
METALS (Cont'd)
Nickel
Dissolved
Total
Selenium
Total
Sodium
Dissolved
Total
Thallium
Dissolved
Zinc
Dissolved
Total

ORGANICS
Benzoic Acid
Concentration
(Ug/L)

1,740
1,835

37,700
38,750

377
382

ftwfc)
1,385
Frequency of
Detection

lofl
lofl

lofl

lofl
lofl

lofl

lofl
lofl

lofl
• Mass Loading
(Ibs/yr)

4
4

0.01

78
80

0.002

1
1

r.'-^flos/yrK-: .
3
Boiler Slowdown
24
-------
Table 3. Summary of Detected Analytes (Cont'd)
~ ' Constituents otj * . . >
Magnetic Surface Slowdown •
CLASSICALS '
Alkalinity
Ammonia As Nitrogen
Biochemical Oxygen Demand
Chemical Oxygen Demand (COD)
Chloride
Nitrate/Nitrite
Sulfate
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (TOC)
Total Phosphorous
Total Recoverable Oil And Grease
Total Sulfide (lodometric)
Total Suspended Solids
Volatile Residue
>HYDRAZBSEE
Hydrazine
METALS
Arsenic
Total
Barium
Dissolved
Total
Boron
Dissolved
Total
Calcium
Dissolved
Total
Copper
Dissolved
Total
Iron
Total
Lead
Dissolved
Total
Concentration
(mg/E>
30
0.22
5
13
17
0.78
36
132
1
6
0.05
1.1
16
7
49
'- (mg/L)
0.007
%< (ttg/L) ' -

1.3

41.9
42.8

38.3
39.9

28,900
31,300

15.8
64.9

4,170

22.8
193
^Frequencjrof
- Detection',' -
-
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl

lofl
,

lofl

lofl
lofl

lofl

lofl
lofl
Mass Loading
(Ibs/yr)
8
0.1
1
4
5
0.2
10
37
0.3
2
0.01
0.3
4
2
14
(Ibs/yr)
0.003
" ' (Ibs/yr)

0.0004

0.01
0.01

8
9

0.004
0.02

0.006
0.054
Boiler Slowdown
25
-------
Constituents of
Magnetic Surface Slowdown
METALS (Cont'd)
Magnesium
Dissolved
Total
Manganese
Total
Nickel
Total
Selenium
Total
Sodium
Dissolved
Total
Zinc
Total
Concentration
(Ug/L)

1,270
2,220

27.6

32.4

8,080
5,380

53.1
Frequency of
Detection

lofl
lofl

lofl

lofl
lofl

lofl
Mass Loading
(Ibs/yr)

0.4
1

0.02

0.01

2
2

0.01
Boiler Slowdown
26
-------
Table 3. Summary of Detected Analytes (Cont'd)
Constituents of * , ' ,
~ Magnetic Bottom Slowdown
CLASSICALS ' - ' c "
Alkalinity
Ammonia As Nitrogen
Chloride
Nitrate/Nitrite
Sulfate
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phosphorous
Total Sulfide (lodometric)
Total Suspended Solids
Volatile Residue
METALS ',
Aluminum
Total
Arsenic
Dissolved
Barium
Dissolved
Total
Boron
Total
Calcium
Dissolved
Total
Copper
Total
Iron
Dissolved
Total
Lead
Dissolved
Total
Magnesium
Dissolved
Total
Manganese
Dissolved
Total
Nickel
Total
Sodium
Dissolved
Total
Zinc
Total
Concentration
*-*/,
(ms/L)
34
1.4
13
0.93
108
207
3.2
0.14
11
40
174
'> (ug/L) '

100

1.15

18.4
20.2

26J7

25,750
27,400

63.1

116
1855

2.2
41.7

2,455
3,000

15.3
40.6

14.7

6,385
5,140

49.9
^Frequency of •
* Detection
f t
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
\

lofl

lofl
lofl

lofl

lofl
lofl

lofl

lofl
lofl

lofl

lofl
lofl

lofl
Mass Loading
Ss/ ' ^
(lbs/yr)
10
0.4
4
0.3
30
58
1
0.04
3
11
49
' : (lbs/yr) ,, "

0.03

0.0003

0.005
0.006

0.007

7
8

0.02

0.03
1

0.001
0.012

1
1

0.004
0.01

0.004

2
1

0.01
Boiler Slowdown
27
-------
Table 3. Summary of Detected Analytes (Cont'd)
Constituents of
Drew Surface Slowdown
CLASSICALS
Alkalinity
Ammonia As Nitrogen
Chemical Oxygen Demand (COD)
Chloride
Nitrate/Nitrite
Sulfate
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (TOC)
Total Phosphorous
Total Recoverable Oil And Grease
Total Sulfide (lodometric)
Total Suspended Solids
HYDRAZINE
Hydrazine
METALS
Aluminum
Total
Arsenic
Dissolved
Total
Barium
Dissolved
Total
Boron
Dissolved
Total
Cadmium
Total
Calcium
Dissolved
Total
Copper
Dissolved
Total
Iron
Dissolved
Total
Concentration
(mg/L)
945
1.8
2,030
148
115
66
2,540
10
100
0.26
3.5
10
45
(mg/k)
0.1
;• .VV: '..:.'-
lofl

lofl

lofl
lofl

lofl

lofl
lofl

lofl
lofl
Mass Loading
dbsfoc)
1,030
2
2,213
161
125
72
2,769
11
109
0.3
4
11
49
•• . (16s/yr)« :•
0.11
.^ ,: (Ibs/yr) > : '

0.03
0.03

0.01
0.07

193
191

0.01

28
33

0
3

0.1
27
Boiler Slowdown
28
-------
Constituents of *• „
Drew Surface Slowdown
METALS (Cont'd)
Lead
Dissolved
Total
Magnesium
Dissolved
Total
Manganese
Total
Molybdenum
Dissolved
Total
Nickel
Total
Sodium
Dissolved
Total
Tin
Total
Titanium
Total
Zinc
Dissolved
Total
tH&spacsf %^;in.:,«<: ?ift-;a"v ^Eyfe- *&.
2-(MethyIthio) Benzothiazole
Bis(2-Ethylhexyl) Phthalate
Concentration
(fig/L)-

2.9
463

178
9,140

261

10.6
10.7

125

697,000
660,000

62.4

28.3

47.3
7,850
:&/.(Wi/®^:
213
16
Frequency of
* -. Detection
/- , N

lofl
lofl

lofl

lofl
lofl

lofl

lofl
lofl

lofl

lofl
lofl
W^vimwS*
lofl
lofl
Mass Loading
(lbs/yr)

0.003
1

0.2
10

0.3

0.01
0.01

0.1

760
720

0.1

0.03

0.1
9
mm~($s?ytp :m^
0.2
0.02
Boiler Slowdown
29
-------
Table 3. Summary of Detected Analytes (Cont'd)
Constituents of
Drew Bottom Slowdown
CLASSICALS
Alkalinity
Ammonia As Nitrogen
Biochemical Oxygen Demand
Chloride
Nitrate/Nitrite
Sulfate
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (TOC)
Total Recoverable Oil And Grease
Total Sulfide (lodometric)
Volatile Residue
HYDRAZ1NE
Hydrazine
METALS
Aluminum
Dissolved
Arsenic
Dissolved
Barium
Dissolved
Total
Calcium
Dissolved
Total
Copper
Dissolved
Total
Iron
Dissolved
Total
Lead
Total
Magnesium
Dissolved
Total
Concentration
(mg/P
45
1.5
8
49
0.32
4.8
112
11
24
2.85
10
81
(rng/L)
0.007
(Ug/L)l

63.4

8.3

15.3
19.8

74.3
83.6

127
153

44.8
1,001

7.35

80
82
Frequency of
Detection

lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl

lofl
- -I.,'.- '•' 'V--""::"".;".-,r -•". ' '•-

lofl

lofl
lofl

lofl

lofl
lofl
Mass Loading,
(Ibs/yr)
50
2
9
55
0.4
5
125
12
27
3
11
90
:..„?--•,: •-••.(BJs/yr):'^rs'-:t,
0.01
'.-•• •v:(flfe/^.^:;-;

0.07

0.01

0.02
0.02

0.1
0.1

0.1
0.2

0.05
1

0.01

0.09
0.09
Boiler Slowdown
30
-------
Constituents of ^ "'
Drew Bottom Slowdown v ^
METALS (Cont'd),
Manganese
Dissolved
Total
Nickel
Total
Selenium
Total
Sodium
Dissolved
Total
Zinc
Dissolved
Total
'ORGilMCS .."
Bis(2-Ethylhexyl) Phlhalate
Concentration
v (ug/L)^ ,

2.95
21

12.6

12.7

1,590
1,425

97.8
277
' (veto
13
•Frequency of
Detection '
^-^ t

lofl
lofl

lofl

lofl
lofl

lofl
lofl
,
lofl
Mass Loading
(Ibs/yr) -/

0.00
0.02

0.01

2
2

0.1
0.3
, (Ibs/yr)
0.01
Boiler Slowdown
31
-------
Table 3. Summary of Detected Analytes (Cont'd)
Constituents of
COPHOS Surface Slowdown
CLASSICALS
Alkalinity
Ammonia As Nitrogen
Chloride
Hexane Extractable Material
Nitrate/Nitrite
Sulfate
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (TOC)
Total Phosphorous
Total Recoverable Oil And Grease
Total Sulfide (lodometric)
Total Suspended Solids
Volatile Residue
HYDRAZME
Hydrazine
METALS
Aluminum
Dissolved
Barium
Total
Calcium
Total
Copper
Dissolved
Total
Iron
Dissolved
Total
Lead
Dissolved
Total
Magnesium
Total
Manganese
Dissolved
Total
Log Normal
Mean
(mg/L)
97.3
0.21
1.22
3.87
0.45
3.16
81.0
0.45
0.87
11.5
8.14
4.30
11.5
67.7
(mg/L)
0.01
(ng/L)

53.7

2.01

36.9

103
3,390

440
4,327

2.49
22.4

91.2

3.00
85.7
Frequency of
Detection

2 of 2
2 of 2
Iof2
Iof2
2 of 2
Iof2
2 of 2
2 of 2
1 of 2
2 of 2
2 of 2
Iof2
2 of 2
2 of 2

Iof2

2 of 2
2 of 2

Iof2
2 of 2

Iof2

2 of 2
2 of 2
Minimum
Concentration
(mg/L)
91
0.11
BDL
BDL
0.24
BDL
17
0.28
BDL
2.6
3.4
BDL
6
23
V fmg/L)
BDL
(US/L)

BDL

56.7
1,310

334
2,480

BDL
8.2

BDL

1.7
57.8
Maximum
Concentration
-------
Constituents of < *
COPHOS Surface Slowdown
METALS (Cont'd)
Molybdenum
Dissolved
Total
Nickel
Dissolved
Total
Sodium
Dissolved
Total
Thallium
Dissolved
Tin
Dissolved
Total
Titanium
Total
Zinc
Dissolved
Total
Log Normal
Mean
^CWS/LK

3.46
2.68

12.3
473

22,520
22,505

0.77

3.49
3.69

4.15

26.0
143
Frequency
- - '<£',.<
Detection
*"•

Iof2
Iof2

Iof2
2 of 2

2 of 2
2 of 2

Iof2

Iof2
Iof2

Iof2

2 of 2
2 of 2
Minimum
* /„(' ' - ,
Concentration
- (MSflL) -

BDL
BDL

BDL
253

6,170
6,460

BDL

BDL
BDL

BDL

23.4
67.2
Maximum
Concentration
' ' (ns/L> .

8
4.8

19
883

82,200
78,400

1.2

6.1
6.8

6.9

28.8
304
Mass Loading
/• /*"
(Ibs/yr) •

0.003
0.002

0.009
0.4

17
17

0.001

0.003
0.003

0.003

0.02
0.11
BDL = Below Detection Limit
Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or
more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations
equivalent to one-half of the detection levels were also used to calculate the log-normal mean. For example, if a
"non-detect" sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log-
normal mean calculation.
Boiler Slowdown
33
-------
Table 3. Summary of Detected Analytes (Cont'd)
Constituents of
COPHOS Bottom Slowdown
CLASSICALS
Alkalinity
Ammonia As Nitrogen
Chloride
Hexane Extractable Material
Nitrate/Nitrite
Sulfate
Total Dissolved Solids
Total Kjcldahl Nitrogen
Total Organic Carbon (TOC)
Total Phosphorous
Total Recoverable Oil And Grease
Total Sulfide (lodometric)
Total Suspended Solids
Volatile Residue
HYDRA23NE
Hydrazine
METALS
Aluminum
Dissolved
Total
Antimony
Dissolved
Barium
Total
Calcium
Total
Copper
Dissolved
Total
Iron
Total
Lead
Dissolved
Total
Magnesium
Dissolved
Total
Log Normal
Mean
(mg/L)
44.5
0.13
1.22
3.26
0.44
4.47
110
0.20
1.26
21.8
1.34
3.08
3.46
42,0
(mg/L)
0.01
(VSfL)

58.2
51.8

3.69

1.37

73.5

80.0
1,724

1430

2.12
8.63

40.4
57.1
Frequency
of
Detection

2 of 2
2 of 2
Iof2
Iof2
2 of 2
Iof2
2 of 2
Iof2
Iof2
2 of 2
2 of 2
Iof2
Iof2
2 of 2

Iof2

2 of 2
Iof2

Iof2

2 of 2

2 of 2
2 of 2

2 of 2

2 of 2
2 of 2

Iof2
Iof2
Minimum
Concentration
(mg/L)
30
0.12
BDL
BDL
0.24
BDL
80
BDL
BDL
15.3
0.8
BDL
BDL
22
(mg/L)
BDL
(Wg/L)

56.6
BDL

BDL

0.85

48.9

47.55
662

1210

1.5
4.7

BDL
BDL
Maximum
Concentration
-------
Constituents of ;/, ,
COPHOS Bottom Slowdown
METALS (Cont'd)
Manganese
Dissolved
Total
Molybdenum
Dissolved
Total
Nickel
Dissolved
Total
Sodium
Dissolved
Total
Thallium
Dissolved
Tin
Dissolved
Titanium
Total
Zinc
Dissolved
Total
QRGANICS ,
Bis(2-Ethylhexyl) Phthalate
Log Normal
Mean . -
- (Ifflfc.) -

2.24
36.1

2.81
2.79

15.8
183

32,390
38,737

0.65

2.85

3.61

8.02
58.5
(PS/L)
10.8
Frequency of
Defection

2 of 2
2 of 2

Iof2
Iof2

2 of 2
2 of 2

Iof2

Iof2
2 of 2
f
Iof2
Minimum
Concentration

1.7
30.7

BDL
BDL

12.95
119

19,250
28,500

BDL

BDL
46.9
(HSfc),
BDL
- Maximum
Concentration
.' 6*g/L)

5.4
42.5

5.25
5.2

19.4
280

54,500
52,650

1.2

6.1

7.9

14.3
73
(M?/L> >
42
Mass Loading
(Ibs/yr) •

0.002
0.029

0.002
0.002

0.013
0.1

26
31

0.001

0.002

0.003

0.01
0.05
(lbs/yr)KV-
0.01
BDL = Below Detection Limit
Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or
more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations
equivalent to one-half of the detection levels were also used to calculate the log-normal mean. For example, if a
"non-detect" sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log-
normal mean calculation.
Boiler Slowdown
35
-------
Table 4. Maximum Concentration of Constituents Detected in Nuclear Powered Ship
Steam Generator Slowdown
Analyte
Metals
Aluminum
Antimony
Arsenic
Jarium
Cadmium
Calcium
Chromium
Hopper
ton
Lead
Vfagnesium
Vlanganese
Molybdenum
Nickel
Silver
Sodium
Tin
Titanium
Zinc
Classicals
Ammonia
Chemical Oxygen Demand
Chloride
Nitrate + Nitrite (as N)
Sulfate
Sulfide
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon
Total Phosphorous
Total Suspended Solids
Organics
Hydrazine
SSN&SSBN
Submarines
tfg/L
40
5
3
1
2
4
2
40
50
10
1
1
20
25
1
160,000
2
3
4
rog/L
0.30
30.00
0.05
70.00
300.00
2.00
1000.00
16.00
3.00
100.00
2.00
mg/L
0.10
CVN 68 Class
Carriers
ftg/L
20
U
20
10
10
70
5
150
20
15
15
20
20
30
20
160,000
20
10
10
"• :. /rflg/Lv- .:•••••-
0.30
30.00
0.05
70.00
300.00
2.00
1000.00
16.00
3.00
100.00
2.00
••;. mg/L .
0.10
CVN65
Only
MS/L
20
U
U
U
10
150
50
50
80
50
200
20
U
90
U
360,000
U
U
50
•.••-• :.-• •rijgflL,-;,?,,iv
0.30
30.00
0.05
70.00
300.00
2.00
1000.00
16.00
3.00
100.00
2.00
- . mg/L' '"••
0.10
Note:
U = Analyte analyzed for but not detected
Boiler Slowdown
36
-------
Table 5. Estimated Annual Mass Loadings of Constituents for Conventionally Powered
Steam Boilers and Auxiliary and Waste Heat Boilers
Constituents of
- Chelant Surface Slowdown " „
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*"
Total Phosphorous
METALS ,
Copper
Dissolved
Total
Iron
Dissolved
Total
Nickel
Dissolved
Total
Zinc
Dissolved
Total
Concentration
(mg/L)
0.44
0.23
2.5
2.8
0.97
' "(V&Lr ,

207
203

626
884

1,860
1,810

594
601
Estimated Annual
Mass Loading
(Ibs/yr) ,
1
1
7
8
3
•'.(Ibs/yr) :

1
1

2
2
f
5
5

2
2
Constituents of '
Chelant Bottom Slowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
Total Phosphorous
METALS
Copper
Dissolved
Total
Iron
Total
Nickel
Dissolved
Total
Zinc
Dissolved
Total
- Concentration *
s.
f /•
(mg/L)
0.11
0.39
0.47
0.86
8.4
(u*fc)- ,

75.9
40.6

344

1,740
1,835

377
382
Estimated Annual
Mass Loading
„ (Ibs/yr)
0.2
1
1
2
17
(BwrM£&--..

0.2
0

4
4

1
1
A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Boiler Slowdown
37
-------
Table 5. Estimated Annual Mass Loadings of Constituents for Conventionally Powered
Steam Boilers and Auxiliary and Waste Heat Boilers (Cont'd)
Constituents of
Magnetic Surface Slowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
Total Phosphorous
METALS
Copper
Dissolved
Total
Iron
Total
Lead
Dissolved
Total
Nickel
Total
Concentration
(mg/L)-
0.22
0.78
1
1.8
0.05
..... •• cug/t) ;v-*'.

15.8
64.9

4170

22.8
193

27.6
Estimated Annual
Mass Loading*
(Ibs/yr)
0.1
0.2
0.3
0.5
0,01
*^.-(lb$/yr)~.:,o\ •-

0.004
0.02

0.006
0.054

0.01
Constituents of
Magnetic Bottom Slowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Nitrogen*
Total Phosphorous
METALS
Copper
Total
Iron
Total
Lead
Total
Nickel
Total
Concentration
(fflg/L)
1.4
0.93
0.93
0.14
:••.. C«?/L); ;-'r

63.1

1855

41.7

14.7
Estimated Annual
Msiss Loading
(Ibs/yt)
0.4
0.3
0.3
0.04
f£*' .;. .flbsfys}' -,v::

0.02

0.012

0.004
A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Boiler Slowdown
38
-------
Table 5. Estimated Annual Mass Loadings of Constituents for Conventionally Powered
Steam Boilers and Auxiliary and Waste Heat Boilers (Cont'd)
Constituents of
Drew Surface Slowdown ,
CLASSICAfcS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*'
Total Phosphorous
MjERj^^::^m2?f- , • '. &:• n • ^
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Total
Zinc
Total
ORGANICS " ,
Bis(2-Ethylhexyl) Phthalate
Concentration
"^ "* f y
/ ""
(fflgflL)~ ,
1.8
115
10
125
0.26
::'S%i"S: ^:i?;' v s$'Si&,<:

14.8
2,340

24,800

463

125

7,850
* (pg/L)
16
Estimated Annual
Mass Loading
(ibs/yrr
2
125
11
136
0.3
IS./ :.-(lbW5Tplr«,

0
3

0.1

9
(ibs/jr) >
0.02
Constituents of
Drew Bottom Blowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
METM.S-" .-,
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Total
Zinc
Dissolved
Total
QRGANI6S
Bis(2-Ethylhexyl) Phthalate
Concentration
(mg/L)
1.5
0.32
11
11
(«?/L)

127
153

1,001

7.35

12.6

97.8
277
' fvsfi®-^ ••.:•."•&
13
Estimated Annual
Mass Loading ,
'(lbs/yt)
2
0.4
12
12
(ibs/yr) ,

0.1
0.2

0.01

0.1
0.3
•;-. -::-..(lbS^r):V:,"^-.
0.01
A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Boiler Blowdown
39
-------
Table 5. Estimated Annual Mass Loadings of Constituents for Conventionally Powered
Steam Boilers and Auxiliary and Waste Heat Boilers (Cont'd)
Constituents of
COPHOS Surface Slowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen^
Total Phosphorous
METALS
Copper
Dissolved
Total
Iron
Dissolved
Total
Lead
Total
Nickel
Dissolved
Total
Zinc
Total
, XogNonnal
Mean Concentration
Ctag/L)
0.21
0.45
0.45
0.9
11.5
-" • -^teg/13 , ^:'-<

103
3,390

440
4,327

22.4

12.3
472.7

143
Estimated Annual
Maiss Loading
Obs/yr)
0.2
0.3
0.3
0.6
9
Z-f.- (Ibs/yr) W

0.08
2.60

0.34
3.32

0.02

0.01
0.36

0.11
A - Total Nib
Constituents of
COPHOS Bottom Slowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
Total Phosphorous
METALS
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Dissolved
Total
ORGANICS
Bis(2-Ethylhexyl) Phthalate
• .'::- Log Normal '^.
'Meat Con^ntratfon
(ms/L) *:
0.13
0.44
0.2
0.64
21.8
(ttg/L) :

80.0
1,724

1430

8.63

15.8
183
(U8/D
10.8
Estimated Annual
-.; ;_ B*iss,L6atKng%:;:,
:--Mibs$i;; •'/'>
0.1
0.4
0.2
0.6
17
: P>s/y*> '

0.06
1.38

1.14

0.01

0.01
0,15
(Ibs/yr) ,
0.01
•ogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Boiler Slowdown
40
-------
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Note:
Information taken
-------
Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituents of
Chelant Surface Blowdown
CLASSICAJLS -- > t
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
Total Phosphorous
'METALS ~ - -
Copper
Dissolved
Total
Iron
Dissolved
Total
Nickel
Dissolved
Total
Zinc
Dissolved
Total
Concentration
1 " (Hg/L> . .
440
230
2500
2800
970
(pg/L)-' ,

207
203

626
884

1,860
1,810

594
601
Federal Acute.
WQC
'- '. '
None
None
None
None
None
(HgflL)

2.4
2.9

None
None

74
74.6

90
95.1
Most Stringent State
Acute WQC
(tfg/L) •„
6(ffl)A
8(HI)A
-
200 (ffl)A
25(HI)A
(W/LV :. '

2.4 (CT, MS)
2.5 (WA)

300 (FL)
300 (FL)

74 (CA, CT)
8.3 (FL, GA)

90 (CA, CT, MS)
84.6 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA= California
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
Boiler Blowdown
43
-------
Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria
(Cont'd)
Constituents of
Chelant Bottom Slowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
Total Phosphorous
METALS
Copper
Dissolved
Total
Iron
Total
Nickel
Dissolved
Total
Zinc
Dissolved
Total
Concentration
(ug/L)
110
390
470
860
8400
(UK/D '

75.9
40.6

344

1,740
1,835

377
382
Federal Acute
WQC

None
None
None
None
None
-•^.(Uslto-::^:-.

2.4
2.9

None

74
74.6

90
95.1
Most Stringent State
Acute WQC
(W/W
6(ffl)A
8(HI)A
-
200 (HI)A
25(HI)A
•:-:•,,. .-.:-rft««3l.-:..-,,^-

2.4 (CT, MS)
2.5 (WA)

300 (FL)

74 (CA, CT)
8.3 (FL, GA)

CA- California
CT - Connecticut
FL - Florida
GA = Georgia
HI = Hawaii
MS — Mississippi
WA « Washington
Boiler Blowdown
44
-------
Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria
(Cont'd)
Constituents of ~\
Magnetic Surface Slowdown
CLASSICALS <. -. ,
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen3
Total Phosphorous
^QEgTALS
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Total
Concentration
Cug/P
220
780
1000
1800
50
*' " frgfLY

15.8
64.9

4,170

193

27.6
Federal Acute
WQC

None
None
None
None
None
(U8/L>

2.4
2.9

None

217.2

74.6
Most Stringent State
Acute \VQC /
* - '(VSfti
6(ffl)A
8(ffl)A
-
200 (HI)A
25 (HI) A
(pg/L)

2.4 (CT, MS)
2.5 (WA)

300 (FL)

5.6 (FL, GA)

8.3 (FL, GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
Boiler Blowdown
45
-------
Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria
(Cont'd)
Constituents of
Magnetic Bottom Slowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Nitrogen*
Total Phosphorous
METALS
Copper
Total
Iron
Total
Lead
Total
Nickel
Total
Concentration
(HS/L)
1400
780
780
140
(ng/D

63.1

1855

41.7 _j

14.7
Federal Acute
WQC

None
None
None
None
*:^to&2jr^.

2.9

None

217.2

74.6
Most Stringent State
Acute WQC
(US/L)
6(HI)A
8(HI)A
200 (HI)A
25(HI)A
-•A/--:(U^-:^-:-

2.5 (WA)

300 (FL)

5.6 (FL, GA)

FL = Florida
GA = Georgia
HI = Hawaii
WA = Washington
Boiler Slowdown
46
-------
Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria
(Cont'd)
Constituents of r/
~ Drew Surface Slowdown
CLASSICALS I
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen**
Total Phosphorous
$B£TALS .- '
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Total
Zinc
Total
©KeiNICS
Bis(2-Ethylhexyl) Phthalate
"Concentration
\ s.
- G«fc> .
1800
115,000
10,000
125,000
260
(US/L)

14.8
2,340

24,800

463

125

7,850
" (W?/L>
16
Federal Acute
WQC
-<
None
None
None
None
None
-C(ig/W

2.4
2.9

None

217.2

74.6

95.1
-
None
Most Stringent State
Acute WOC
-' (w/L)
6(HI)A
8(HI)A
-
200 (ffl)A
25(HI)A
" (US/L)

2.4 (CT, MS)
2.5 (WA)

300 (FL)

5.6 (FL, GA)

8.3 (FL, GA)

84.6 (WA)
" %gfc)V
5.92 (GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995) .
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
Boiler Slowdown
47
-------
Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria
(Cont'd)
Constituents of
Drew Bottom Slowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
METALS
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Total
Zinc
Dissolved
Total
ORGANICS
Bis(2-Ethylhexyl) Phthalate
Concentration
(ug/L>
1500
320
11,000
11,000
(ug/L)

127
153

1,001

7.35

12.6

97.8
277
(us/L)
13
Federal Acute
WQC

None
None
None
None
v(ug/tl: vs»

2.4
2.9

None

217.2

74.6

90
' 95.1

None
Most Stringent State
Acute WQC
(ug/L)
6(HI)A
8(HI)A
-
200 (HI)A
• : • (ug/E) ••**

2.4 (CT, MS)
2.5 (WA)

300 (FL)

5.6 (FL, GA)

8.3 (FL, GA)

90 (CA, CT, MS)
84.6 (WA)
•-••• - (ug/t);5 •;;«•-
5.92 (GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CT = Connecticut
FL - Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
Boiler Slowdown
48
-------
Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria
(Cont'd)
Constituents of
/ coraos
Surface Slowdown
CLASSICALS *
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen3
Total Phosphorous
AEETALS
Copper
Dissolved
Total
Iron
Dissolved
Total
Lead
Total
Nickel
Dissolved
Total
Zinc
Total
Log Normal
Mean , i
CUS/L)
210
450
450
900
11,500
(WB^L)

103
3,390

440
4,327

22.4

12.3
473

143
' Minimum"
Concentration
f •>
fcg/L>
110
240
280

2600
(WBflL)

56.7
1,310

334
2,480

8.2

BDL
253

67.2
Maximum
Concentration ,
"* S * "
- WL>
390
850
710

5UOOO
(VSfL) c

187
8,780

579
7,550

61.4

19
883

304
Federal
'- Acute
,WQC
(pg/L) -
None
None
None
None
None
.- (M8&V

2.4
2.9

None
None

217.2

74
74

95.1
Most Stringent
State
Acute WQC
-(pg/L)
6(HI)A
8(HT)A
_
200 (HI)A
25(ffl)A
(pg/L)

2.4 (CT, MS)
2.5 (WA)

300 (FL)
300 (FL)

5.6 (FL, GA)

74 (CA, CT)
8.3 (FL, GA)

84.6 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA= California
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
BDL = Below Detection Limit
Boiler Slowdown
49
-------
Table 8. Mean Concentrations of Constituents that Exceed Water Quality Criteria
(Cont'd)

Constituents of
COPHOS
Bottom Slowdown
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
Total Phosphorous
METALS
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Dissolved
Total
ORGANICS
Bis(2-Ethylhexyl)
Phthalate
Log Normal
Mean
(Mg
130
440
200
640
21,800
(ug/L)

80.0
1,724

1,430

8.63

15.8
183
(ug/L)
10.8
Minimum
Concentration
(ug/L)
120
240
BDL

15,300
(ug/L) -

47.6
662

1,210

4.7

12.95
119
-------
Table 9. Concentrations of Constituents that Exceed Water Quality Criteria for Nuclear
Powered Steam Generators (maximum values) (ng/L)
Analyte
i
Copper
Lead
Nickel
Ammonia
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total
Nitrogen3
Phosphorous
Discharge
Concentration ,
from Submarines
40
10
25
30
70,000
16,000
86,000
100,000
- Discharge
Concentration from
CVN 68 Class,
carriers * "' •
150
15
30
30
70,000
16,000
86,000
100,000
, Discharge
Concentration from
< CVN 65 Class
carrier, -
50
50
90
90
70,000
16,000
86,000
100,000
„ Federal
Acute WQC
2.4
210
74
None
None
None
None
None
Most Stringent
State Acute WQC
2.4 (CT, MS)
5.6 (FL, GA)
8.3 (FL, GA)
6(HI)A
8(HI)A
-
200 (HI)A
25(HI)A
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
Table 10. Summary of Thermal Effects of Boiler Slowdown Discharge
Ship
Modeled
Discharge
Temp (°F)
Discharge
Volume
(gals)/
s ,
Ambient
Water
TempfF)
Predicted
Plume
Width and
Length
Cm)*
Allowable
Plume ;
Width (m)
Allowable
Plume
Length (m)
Predicted
.Plume
Depth (m)
.Washington State (0.3°C AT)
LHA1
AFS1
503
495
310
150
50
50
19.7
13,4
400
400
73
73
4
4
Virginia {3.0°C AT)
LHA1
AFS1
503
495
310
150
40
40
5.5
3.7
3,200
3,200
32,000
32,000
4
4
Note: The discharge was modeled such that the resultant plume is cylindrical shaped, therefore
the plume width and length are equal.
Boiler Slowdown
51
-------
Table 11. Data Sources

NOD Section
2.1 Equipment Description and
Operation
2 JL Releases to the Environment
23 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Thermal Effects
4.4 Potential for Introducing Non-
Indigenous Species
•-- .•'••:-• Data Source ;^',<..~". •'--;•;., '•, •:••-':•.:• •"':-:
Reported

UNDS Database

Sampling

X
X

Estimated

Equipment Expert
X
X
X
X
X

X
Boiler Slowdown
52
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NATURE OF DISCHARGE REPORT
Catapult Water Brake Tank and Post Launch Retraction Exhaust
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed in three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has
been identified as a candidate for regulation under UNDS. The NOD reports were developed
based on information obtained from the technical community within the Navy and other branches
of the Armed Forces with vessels potentially subject to UNDS, from information available in
existing technical reports and documentation, and, when required, from data obtained from
discharge samples that were collected under the UNDS program.

This section describes the catapult water brake tank and post launch retraction exhaust
and includes information on: the equipment that is used and its operation (Section 2.1), general
description of the constituents of the discharge (Section 2.2), and the vessels that produce this
discharge (Section 2.3).

2.1 Equipment Description and Operation

Every Navy aircraft carrier is equipped with four steam catapults for launching aircraft.
High pressure steam from the catapult wet steam accumulator is used to operate each catapult.
Each catapult has a dedicated water brake tank and catapult steam exhaust piping. During each
catapult cycle, lubricating oil is applied to the catapult power cylinder. Different amounts of
lubricating oil are applied depending on catapult model. Mod 2 catapults use more lubricating
oil per catapult cycle than Mod 1 catapults (see Section 3.2.1).

Catapults are operated every time an aircraft is launched and for testing purposes.
Catapults are normally tested after an aircraft carrier is built, before an aircraft carrier is sent out
on deployment, and after major repairs and overhauls. Catapult testing before deployments is
called "no-load" testing because there is no load applied to the catapult. Catapult testing after
building and after major repairs and overhauls is called "dead-load" testing because a weight is
applied to the catapult to simulate the weight of an aircraft. During catapult testing, lubricating
oil is supplied to the catapult's power cylinder in the same fashion as during aircraft launching
operations.

The forward motion of the catapult piston is stopped by means of a water brake that is
supplied by high pressure water from the water brake tank. As the catapult operates, the
lubricating oil is carried into the water brake and subsequently into the water brake tank. During
the retraction of the catapult piston, the steam left in the power cylinder and a small amount of
residual oil are discharged overboard through the catapult exhaust piping. A smaller fraction of
the residual oil also leaks by the catapult cylinder sealing strips and into the catapult trough.
Catapult trough discharge is addressed in a separate NOD report on deck runoff.

2.1.1 Catapult Water Brake Tank

The catapult water brake tank supplies freshwater to the catapult water brake, which is
used to stop the forward motion of the catapult piston. Water from the catapult water brake tank
is injected into the water brake during each catapult cycle at approximately 1,300 gallons per
minute (gpm) using two 650-gpm pumps.1 When the catapult piston enters the water brake, it
forces water from the water brake into the upper portion of the water brake tank. Figure 1
provides an illustration.

The oil used to lubricate the catapult power cylinder conforms to both SAE J1966, Grade
60 and Military Specification MTL-L-6082E grade 1100 standards.2 During each catapult cycle,
oil is sprayed onto the internal surface of the catapult power cylinder. As the catapult piston

Catapult Water Brake Tank and Post Launch Retraction Exhaust
2
-------
travels down the catapult power cylinder, lubricating oil is carried with the catapult piston into
the water brake.1 Over the course of multiple launches, and because water is recirculated through
the catapult water brake and the water brake tank, oil builds up hi the water brake tank. The oil
accumulates on the surface of the water in the water brake tank in the form of an oil-water
emulsion. Heat is added to the water from heat accumulated in the oil, the action of the pistons,
and by conduction from the steam-heated catapult piston. The accumulated oil also inhibits
cooling at the surface of the water brake tank. Consequently, the water temperature rises.
Excessive water temperature adversely affects the catapult water brake performance.

To prevent excessive water temperatures in the water brake tank, the accumulated oil is
periodically skimmed. The water brake tank is equipped with an oil-skimming funnel and a 2.5-
inch pipe for draining the oil from the tank. Fresh cool water is added to the water brake tank via
a freshwater fill line to raise the water level hi the tank, thus causing the floating oil and oil/water
mixture to flow into the skimming funnel. The funnel drain piping discharges the oil and
oil/water mixture overboard above the waterline. The contents of the water brake tank drain
overboard until the liquid level falls below the top of the drain funnel. Oil accumulation hi the
water brake tank is directly related to the number of catapult cycles. During aircraft launch
operations, the water brake tank is skimmed on an as-needed basis.3

As mentioned previously, aircraft carriers perform no-load catapult tests before leaving
port on deployment and dead-load tests after building, major repairs and overhauls. The number
of no-load and dead-load tests, however, do not generate enough lubricating oil in the water
brake tank to require that the tank to be skimmed within 12 nautical miles (n.m.).

2.1.2 Post-Launch Retraction Exhaust

During the post-launch retraction of the catapult piston, the expended steam and residual
oil from the catapult power cylinder walls are discharged overboard below the water line through
copper/nickel piping. The exhaust steam exits the catapult power cylinder at approximately 350
°F (i.e., the operating temperature of the catapults) and cools and condenses as it flows through
the exhaust piping overboard. The temperature of the final discharge is estimated to be 200 %.

2.2 Releases to the Environment

2.2.1 Water Brake Tank

Discharge from the water brake tank is released overboard above the water line and
consists of freshwater, lubricating oil, and small amounts of metals introduced by the catapult
systems.

2.2.2 Post-Launch Retraction Exhaust

Discharge from the post-launch retraction exhaust is released overboard below the water
line and consists of condensed steam with lubricating oil and small amounts of metals from the
catapult.

Catapult Water Brake Tank and Post Launch Retraction Exhaust
3
-------
2.3 Vessels Producing the Discharge

The Navy's aircraft carriers are the only armed forces vessels that generate this discharge.
Of the 11 aircraft carriers that are homeported in the United States, eight are equipped with Mod
1 catapults, and the three newest aircraft carriers are equipped with Mod 2 catapults. There are a
total of 12 aircraft carriers
3.0 DISCHARGE CHARACTERISTICS

3.1.1 Catapult Water Brake Tank

The catapult water brake tank discharge is generated on an as-needed basis during aircraft
carrier flight operations, which occur beyond 12 n.m. from shore.1'4'5 Catapult testing, which
occurs within 12 n.m. does not generate a sufficient quantity of oil hi the water brake tank to
require discharge. In addition, OPNAVTNST 5090. IB prohibits oil from being discharged within
12 n.m. of shore, including the oil contained in this discharge.

Because this discharge does not occur within 12 n.m. of shore, it is not discussed further
in this report.

3.1.2 Post-Launch Retraction Exhaust

The post-launch retraction exhaust discharge is generated during all catapult operations
including aircraft launching and catapult testing. Because catapults are operated within 12 n.m.
of shore during no-load/dead-load testing, the post-launch retraction exhaust discharge occurs on
a limited basis within 12 n.m.

3.2 Rate

The discharge for the post-launch retraction exhaust discharge consists of condensed
steam and the residual oil from lubricating the catapult power cylinders. During each catapult
cycle, approximately 1,000 pounds of water from the wet accumulator are flashed to steam to
drive the catapult piston down the flight deck, and 0.415 gallon of oil is injected onto the catapult
power cylinder wall for Mod 1 catapults, and 0.83 gallon of oil for Mod 2 catapults.6 Based on
operating experience, approximately 890 pounds of water and 0.10 gallon of oil from Mod 1
catapults, or 0.42 gallon of oil from Mod 2 catapults, are discharged overboard during each
Catapult Water Brake Tank and Post Launch Retraction Exhaust
4
-------
catapult cycle.

An aircraft carrier performs approximately 50 no-load catapult tests per year.3 Therefore,
all 11 aircraft carriers homeported in the United States perform approximately 550 no-load test
shots per year. At a fleet-wide average rate of 0.19 gallon of oil (weighted average discharge of
0.10 gallon for Mod 1 catapults and 0.42 gallon for Mod 2 catapults) and 890 pounds of steam
condensate per each catapult test, the annual fleet-wide discharge of oil and condensed steam
from no-load catapult tests within 12 n.m. is approximately 105 gallons of oil and 490,000
pounds of condensed steam.

Major catapult overhauls and modifications are not normal occurrences for aircraft
carriers. In general, one to two aircraft carriers annually undergo a major overhaul or
modification that requires 60 dead-load catapult test shots to recertify the catapult. Assuming
that on average, the catapults on 1.5 carriers are overhauled each year (i.e., six catapults), an
estimated 360 dead-load catapult test shots are performed annually fleet-wide within 12 n.m.
Thus, an estimated 69 gallons of oil (at a rate of 0.19 gallon per test) and 320,000 pounds of
steam condensate (at a rate of 890 pounds per test) are discharged annually from dead-load
catapult testing.

Thus, 174 gallons of oil and 810,000 pounds of condensed steam (-97,000 gallons) are
discharged annually, fieetwide, from post-launch retraction exhaust during no-load and dead-load
catapult testing.

3.3 Constituents

The post-launch retraction exhaust discharge consists of steam and condensed steam with
associated non-organic metal constituents and lubricating oil. The lubricating oils are comprised
primarily of higher chain (Cn and higher) paraffins and olefins.7'8 Another UNDS discharge,
Steam Condensate Discharge, is similar to the condensed steam discharge from the catapult
retraction stroke, with the exception of the oil content. The Steam Condensate NOD Report
analyzes steam condensate originating from shore-based facilities. The steam condensate from
ship healing supplied from shore facilities consists primarily of condensed steam that is generally
collected and pumped or drained overboard. The discharge from the catapult retraction exhaust
is steam, condensed steam, and oil that is vented overboard under pressure. The condensed
steam portion of both discharges will, however, be somewhat similar. Based on the data
presented in that report, nitrogen (as ammonia, nitrate/nitrite, and total nitrogen), phosphorous,
and the priority pollutants antimony, arsenic, benzidine, bis(2-ethylhexyl) phthalate, cadmium,
copper, lead, nickel, selenium, thallium, and zinc can be present in the condensed steam in post-
launch retraction exhaust. There are no known bioaccumulators in this discharge.

3.4 Concentrations

Approximately 890 pounds of catapult condensed steam and 0.19 gallon of oil is
discharged during each catapult cycle. The density of water at 70 °F (i.e., ambient temperature) is
8.32 pounds per gallon (Ibs/gal) or 0.998 kilograms per liter (kg/1) and the oil density is of 7.32
Catapult Water Brake Tank and Post Launch Retraction Exhaust
5
-------
Ibs/gal or 0.878 kg/1. Therefore, the concentration of oil in the exhaust discharge is
approximately 1,560 mg/L. The calculation is presented below:
[(0.19 gal* ) (7.32 Ibs0 /gal,, )(453,590 rag/to)] /[(890 lbv^)(gal/8,32 Ibs* )(3.7851/gal)] «
'•' ' =1560mg/1
Where the subscripts o refer to oil and w refer to water.

Table 1 shows the concentrations of the priority pollutants identified in the Steam
Condensate NOD Report. It is assumed that the same constituents would be found in the
condensed steam from the catapult retraction exhaust in similar concentrations to those found in
steam condensate originating from facilities.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria.
Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of non-
indigenous species is discussed.

4.1 Mass Loadings

As estimated in Section 3.2, approximately 174 gallons of oil are discharged annually
from no-load and dead-load testing in post-launch retraction exhaust. This results hi an annual
fleet-wide mass loading of 1,275 pounds (based on a conversion factor of 7.33 pounds of
oil/gallon).

Of the non-oil constituents hi the 810,000 pounds of catapult condensed steam generated
annually fleet wide from post-launch retraction exhaust (see Section 3.2) less than one pound of
pollutants are estimated to be discharged from no-load and dead-load testing. The mass loadings
were estimated using the following equation:
(log-normal mean cone. p,g/l)(g/l,000,000 yg) (lbs/453.593 g) (annual volume 1/yr) = mass
loading (Ibs/yr)
4.2 Environmental Concentrations

The condensed steam and oil from the post-launch retraction exhaust exits the ship via
the exhaust piping. The estimated concentration of oil in the discharge is approximately 1,560
mg/L. This value exceeds the most stringent state water quality criteria (WQC), which is
Florida's 5 mg/L criterion (Table 2). Concentrations this high are likely to cause a sheen in the

Catapult Water Brake Tank and Post Launch Retraction Exhaust
6
-------
receiving waters.

Assuming the concentrations of the priority pollutants shown in Table 1 are
representative of condensed steam discharged in post-launch retraction exhaust discharge, there
would be four priority pollutants - benzidine, bis(2-ethylhexyl) phthalate, copper, and nickel -
discharged in excess of Federal and/or the most stringent state WQC. Two other constituents,
nitrogen (as ammonia, nitrate/nitrite, and total nitrogen) and phosphorous, exceed the most
stringent state WQC. Table 2 shows the concentrations of these constituents and the applicable
WQC.

4.3 Thermal Effects

The thermal effects of the post-launch retraction exhaust were screened for potential
adverse effects to determine if the resulting thermal plume exceeded water quality criteria for
temperature.9 Based upon the evaluation of the exhaust discharge, the thermal effects rapidly
dissipate within a short distance of the point of discharge.9 Under the most stringent criteria
(e.g., Washington State), the resulting plume from the post-launch retraction exhaust is estimated
to be approximately 20 feet in diameter and extends to approximately 12 feet in depth.9 These
dimensions are within limits established for Washington.9

4.4 Potential for Introducing Non-Indigenous Species

During catapult launch operations, seawater is not transported. Therefore, there is no
potential for transporting non-indigenous species.
5.0 CONCLUSIONS

The catapult water brake tank discharge does not occur within 12 n.m. because flight
operations are not conducted within this zone. Therefore, this discharge has no potential to cause
an adverse environmental effect within 12 n.m.

The post-launch retraction exhaust has a potential for adverse environmental effect
because significant amounts of oil are discharged at high concentrations during the short duration
of the discharge event. The high concentrations exceed water quality criteria and discharge
standards. The high concentrations of oil are likely to cause an oil sheen.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained, process
information and assumption were used to estimate the rate of discharge. Based on this estimate
and on the reported concentration of oil constituents, the concentration of the oil constituents in
the environment resulting from this discharge were then estimated. Table 3 shows the source of
the data used to develop this NOD report.
Catapult Water Brake Tank and Post Launch Retraction Exhaust
7
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Specific References

1. UNDS Equipment Expert Meeting Minutes - Catapult Discharges. July 26,1996.

2. Commander, Naval Sea Systems Command. Memorandum Ser PMS312B/1760.
Pollution of Coastal Waters Attributed to Catapult Lube Oil. December 16,1997.

3. Commander Naval Air Forces, U.S. Atlantic Fleet. Responses to TYCOM Questionnaire.
M. Rosenblatt & Son, Inc. May 20,1997.

4. UNDS Equipment Expert Meeting Minutes - Catapult Trough, Water Brake Tank, Jet
Blast Deflector and Arresting Cables. August 22,1996.

5. UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Steam
Slowdown Discharge. August 20,1997.

6. Steve Opet, NAWCADLKE. Information on Volume of Water and Temperature for
Catapult Shots. April 11,1997. Clarkson Meredith, Versar, Inc.

7. Perry and Chilton. Chemical Engineers' Handbook. Fifth Ed. McGraw Hill. 1953

8. Patty's Industrial Hygiene and Toxicology, 3rd Ed., Volume UJB. G.D. and F.E. Clayton,
Editors. New York: 1981.

9. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed
Services. Versar, Inc. July 3,1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Catapult Water Brake Tank and Post Launch Retraction Exhaust
8
-------
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for rntrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

U.S. Navy Technical Manual NAVAIR 51-15ABD-3, Illustrated Parts Breakdown Catapults.
December 1,1986.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, pg 15366. March 23,1995.

Committee Print Number 95-30 of the Committee of Public Works and Transportation of the
House of Representatives, Table 1.

Jane's Information Group, Jane's Fighting Ships. Capt. Richard Sharpe, Ed. Sentinel House:
Surrey, United Kingdom, 1996.

UNDS Phase I Sampling Data Report, Volumes 1-13. October 1997.
Catapult Water Brake Tank and Post Launch Retraction Exhaust
9
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Table 1. Estimated Post-Launch Retraction Exhaust Discharge Constituents,
Concentrations, and Mass Loadings Based Upon Steam Condensate Sampling Data
Constituents
From Steam Condensate1
Antimony
Total
Arsenic
Total
Cadmium
Total
Copper
Dissolved
Total
Lead
Dissolved
Total
Nickel
Dissolved
Total
Selenium
Total
Thallium
Dissolved
Zinc
Dissolved
Total
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Phosphorous
Benzidine
Bis{2-ethylhexyl) phthalate
Concentrations (ng/L)
Log Normal
Mean2 Range

7.13

0.74

2.86

13.4
20.1

3.58
4.38

10.3
11.6

2.87

1.18

13.94
11.35
180
440
1240
90
32.8
19.4

DDL -26.8

BDL-2.3

BDL-6.1

BDL-49.0
BDL - 91.0

BDL-12.7
BDL -18.9

BDL - 22
BDL -34.7

BDL- 3.5

BDL - 13.3

7.15-21.9
BDL -23.0
120 - 370
300-810
NA .
BDL - 270
BDL - 73.5
BDL -112
Rate of Wet
„ Accumulator
Discharge (I/yr)3

367,OOiO

367,000

367,000
367,000

367,000

367,000
367,000
367,000
367,000
367,000
367,000
367,000
367,000
Fleet- Wide Mass
Loading
(pounds/yr)

5.8 x 10-3

6.0 x Iff4

2.3 x lO'3

1.1 x 10-2
1.6 x 10'2

2.9 x 10'3
3.5 x 10'3

8.3 x 10'3
9.4 x 10'3

2.3 x 10'3

9.5 x 10"4

1.1 x 10'2
9.2 x 10-3
1.4 xlO'1
3.4 x 10'1
9.6 x 10'1
7.1 x 10'2
2.7 x 10'2
1.6 xlO'2
The constituents listed above are those expected to be found in the wet accumulator discharge. BDL denotes below
detection limit.

1. Constituents listed are the priority pollutants detected in steam condensate samples.
2. Highest of the dissolved and total log average values.
3. This value is the product of the annual condensed steam released from no-load and dead-load testing (810,000
pounds combined) cited in Section 3.2.1 and the conversion factors 0.0175 cubic foot/pound (inverse density of
water at 200 °F), 7.4805 gallons/cubic foot, and 3.785 liters/gallon.

Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or
more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations
equivalent to one-half of the detection levels were also used to calculate the log-normal mean. For example, if a
"non-detect" sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log-
normal mean calculation.
Catapult Water Brake Tank and Post Launch Retraction Exhaust
10
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Table 2. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Post-Launch Retraction Exhaust Condensed Steam Discharge
Constituent -
Oil
Ammonia as
Nitrogen
Nitrate/Nitrite
Total Nitrogen
Total Phosphorous
Benzidine
Bis(2-Ethylhexyl)
Phthalate
Copper*
Dissolved
Total
Nickel*
Dissolved
Total
, Log-Normal Mean
Concentration (ue/L)
1,560,000
180
440
1240
90
32.8
19.4

13.4
20.1

10.3
11.6
Federal Acute WQCfttg/L)
visible sheen l /15,0002
None
None
None
None
None
None

2.4
2.9

74
74.6
, Most Stringent State
Acute WQCOtg/W
5,000 (FL)
6(HI)A
8(ffl)A
200 (ffl)A
25 (ffl)A
0.000535 (GA)
5.92 (GA)

2.4 (CT, MS)
2.5 (WA)

74 (CA, CT)
8.3 (FL, GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
A - Nutrient criteria are not specified as acute or chronic values.

Discharge of Oil. 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen on
receiving waters.
2 International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as
implemented by the Act to Prevent Pollution from Ships (APPS).
Assumes the constituents and their concentrations in this discharge are similar in concentration to the constituents
found in steam condensate that originates from shore facilities.

CA = California
CT = Connecticut
FL = Florida
GA = Georgia
HI= Hawaii
MS = Mississippi
WA = Washington
Catapult Water Brake Tank and Post Launch Retraction Exhaust
11
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TableS. Data Sources

NOD Section
2. 1 Equipment Description and
Operation
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Thermal Effects
4.4 Potential for Introducing Non-
Indigenous Species
. . • . ••"•:.--• IJatas Source ...t. -..• ••/... v;?/-:.^.-., •.
Reported
X

UNDS Database

Sampling

Estimated

X
X
X
X
X
X

Equipment Expert
X
X
X
X

•X
Catapult Water Brake Tank and Post Launch Retraction Exhaust
12
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WATER
SUPPLY
-ANNULUS RING

-STRIKER RING
•SPEAR
WATER-BRAKE CYLINDER
Fig. 1 Water Brakes

Catapult Water Brake Tank and Post Launch Retraction Exhaust
13
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NATURE OF DISCHARGE REPORT
Catapult Wet Accumulator Discharges
1.0 INTRODUCTION

This section describes the catapult wet accumulator discharges and includes information
on: the equipment that is used and its operation (Section 2.1), general description of the
constituents of the discharge (Section 2.2), and the vessels that produce this discharge (Section
2.3).

2.1 Equipment Description and Operation

Aircraft are launched from aircraft carriers using a steam driven catapult piston. Steam is
supplied to a catapult from a 16,000-gallon pressure vessel known as a catapult wet accumulator.
The wet accumulator contains a mixture of steam and saturated water at a high temperature and
pressure. As steam is released from the accumulator for a launch, the pressure drops in the
accumulator and water flashes to steam producing additional steam. The pressure from the steam
against the catapult piston forces the piston to accelerate rapidly, providing sufficient force and
velocity to launch the aircraft.1 Each aircraft carrier has four catapults.

Approximately 8,000 gallons of boiler feedwater are used when initially filling an
accumulator on conventionally-powered aircraft carriers. Similarly, 8,000 gallons of steam
generator feedwater are used when initially filling an accumulator on nuclear-powered aircraft
carriers. Feedwater from boilers and steam generators contain similar constituents. Feedwater is
distilled fresh water from the ship's water generating plant. Steam from the ship's main steam
plant is used to maintain the water level and to pressurize the accumulator to between 450 and
520 pounds per square inch (psi).2 The steam is provided to the accumulator through a manifold
that distributes the steam below the water level in the accumulator. Figures 1 and 2 show a
schematic of a wet accumulator and its associated external and internal piping.

The continuous addition and condensation of steam during flight operations, while
standing by for flight operations, or during catapult testing causes the water level in an
accumulator to rise. Slowdowns are required to keep water level within operating limits,
normally 40 to 50 niches of water.2 Slowdowns to control water levels release up to 5 inches
(750 gallons) of water from the accumulator.3 The water is blown down through a pipe that is
connected to the bottom of the accumulator and discharged overboard approximately 18 to 24
inches below the waterline through a seachest.1

Slowdowns also can be performed using a steam blowdown valve that is connected at the
top of the accumulator. This valve can also be used to control the water level in the accumulator;
however, its primary function is to reduce the pressure in the accumulator to atmospheric
pressure prior to emptying the accumulator. Wet accumulators are emptied before major
maintenance or if an aircraft carrier will be in port for 72 hours or longer.2'4 To empty the wet
accumulator, multiple blowdowns are performed over an extended period of time (up to 12
hours) to slowly reduce pressure and to minimize noise.
Catapult Wet Accumulator Discharges
2
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2.2 Releases to the Environment

Aircraft carrier catapult wet accumulators are initially charged with boiler or steam
generator feedwater and fed with steam from the steam plant as the catapult is operated. The
feedwater is treated with chemicals at specified rates to prevent scaling and corrosion, including
oxygen scavengers and chelating agents. Unlike boilers, wet accumulators are unfired pressure
vessels and scale and corrosion are not significant problems. Therefore, the treatment chemicals
in the initial charge of boiler feedwater are expected to be unreacted and discharged from the wet
accumulator during flight operations and blowdowns.5'6'7'8 With each blowdown, the
concentration of feed chemicals is reduced in the accumulator, and the concentration in the
accumulator tank approaches that of steam condensate.

Some of the steam supplied to the accumulator is used directly to drive the catapult, while
some condenses to distilled water, diluting the initial charge of boiler feedwater in the wet
accumulator. The steam supplied to the wet accumulator is pure water with very minor amounts
of constituents derived from the materials of construction of the steam generating and handling
systems (e.g., copper nickel piping). In addition, there may be small amounts of water treatment
chemicals. The constituents are expected to be similar to those found in steam condensate based
on process knowledge of similarities in the materials of construction. The amounts of these
constituents in steam directed to the wet accumulator are expected to be less than the amounts
contained hi steam condensate discharge because steam condensate discharge is produced from
steam that has longer contact times with piping and equipment of the shore steam system. For
the purposes of this NOD report, condensed wet accumulator steam was considered similar to
steam condensate. Steam condensate is a separate UNDS discharge and is described in detail in
the Steam Condensate NOD report.

2.3 Vessels Producing the Discharge -

Only the Navy's aircraft carriers produce this discharge. There are 12 aircraft carriers in
the Navy, one of which is homeported in Japan. All of the remaining 11 aircraft carriers are
homeported in the United States.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Wet accumulator blowdowns occur as a result of flight operations and catapult testing.
Blowdowns resulting from flight operations occur outside 12 nautical miles (n.m.). Blowdowns
resulting from catapult tests occur within 12 n.m.

Catapult Wet Accumulator Discharges
3
-------
Wet accumulators are emptied before major maintenance or when a ship will be in port
for greater than 72 hours. In both cases, aircraft carriers empty the accumulator outside 12 n.m.
when returning to port. However, after major maintenance has been performed on a wet
accumulator or catapult, the wet accumulator is refilled and the entire catapult system tested in
port. If the aircraft carrier will be in port for more than 72 hours after testing is complete,, the
accumulator will be emptied in port.4

3.2 Rate

Before each test, the wet accumulator is filled with approximately 8,000 gallons of boiler
or steam generator feedwater. Based on process knowledge, approximately 50 catapult shots are
performed during each test. Wet accumulators are emptied before major maintenance of the
catapult system or if an aircraft carrier will be hi port for 72 hours or longsr. After catapult
testing, the wet accumulator is blown down or drained of the original 8,000 gallons of feedwater
and approximately 1,100 gallons of condensed steam accumulated from the catapult shots. To
empty the wet accumulator, multiple blowdowns are performed over an extended period of tune
(up to 12 hours) to reduce pressure slowly and minimize noise. A blowdown of 5 inches of water,
which is equivalent to approximately 750 gallons of water, typically takes about 5 minutes to
complete.

Each of the 11 aircraft carriers in the fleet has four wet accumulators, which are tested as
described above approximately once every 1.5 years. Thus, fleetwide, approximately 235,000
gallons of water are discharged within 12 n.m. each year from wet accumulators:
Wet Accumulator Annual Blowdown Volume (gallons per year) = (Wet accumulator feedwater
capacity) (4 accumulators per carrier) (11 carriers) / (Frequency of test) = (8,000 gallons/accumulator)(4
accumulators/carrier)(l 1 carriers) / (1.5 years) - 235,000 gallons per year
Similarly, approximately 33,000 gallons of condensed steam are discharged annually:
33,000 gallons/year = (1,125 gallons/accumulator)(4 accumulators/canier)(31 carriers) / (1.5 years)..
3.3 Constituents

The constituents in the feedwater that is used to fill a wet accumulator include disodium
phosphate, emylenedUaminetetraacetic acid (EDTA), and hydrazine. None of these constituents
are priority pollutants. Based on the analysis of steam condensate samples, the priority pollutants
antimony, arsenic, benzidine, bis(2-ethylhexyl) phthalate, cadmium, copper, lead, nickel,
selenium, thallium, and zinc can be present in the condensed steam in the wet accumulator.
There are no known bioaccumulators in this discharge.
Catapult Wet Accumulator Discharges
4
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3.4 Concentrations

Table 1 shows the concentrations of the constituents identified in Section 3.3. The table
is divided into two sections. The first section shows the concentrations of the pollutants detected
in steam condensate. As explained in Section 2.2, the steam supplied to the wet accumulator is
expected to contain lower concentrations of these constituents than measured in steam
condensate samples. Nevertheless, to be conservative, the concentrations of these constituents in
steam condensate were used to estimate the mass loadings from the condensed steam portion of
wet accumulator discharge.

The second section of Table 1 shows specified concentrations of boiler feedwater
treatment chemicals. As stated in section 2.2 and to be conservative, these chemicals were
assumed to be discharged at these concentrations in the boiler feedwater portion of wet
accumulator discharge.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented hi Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. hi Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality standards, hi
Section 4.3, the thermal effect of this discharge is discussed, hi Section 4.4, the potential for the
transfer of non-indigenous species is discussed.

4.1 Mass Loading

Table 1 shows the estimated mass loadings of the constituents in wet accumulator
discharge that were identified in Section 3.3. Fleet-wide annual mass loadings (in pounds/year)
were estimated by multiplying the concentration of the constituents (hi micrograms per liter
(jj,g/L)) by the discharge rates from Section 3.2 (converted to liters per year) and the appropriate
conversion factors using the following equation:
(log-normal mean cone. {xg/l)(g/l,OQO,OQG ^tg) (lbs/453.593 g) (annual volume 1/yr)
„ - - s mass loading (Ibs/yr)
The annual volume for this discharge is a combination of the volume of steam condensed
per year (33,000 gallons) and the volume of feedwater (235,000 gallons) charged into the wet
accumulator.

As shown hi Table 1, the amounts of priority pollutants discharged annually from the
condensed steam portion of wet accumulator discharge are significantly less than one pound.
Because the constituent concentrations used to calculate the mass loadings are actually from
steam condensate discharge — thought to overestimate pollutant concentrations in wet

Catapult Wet Accumulator Discharges
5
-------
accumulator steam — the actual mass loadings in the condensed steam portion of wet
accumulator discharge are probably lower. The annual, fleet-wide mass loadings of the boiler
feedwater chemicals in wet accumulator discharge are estimated to be 195,49, and 49 pounds for
disodium phosphate, EDTA, and hydrazine, respectively.

4.2 Environmental Concentrations

Wet accumulator discharge is released directly to the environment. The estimated
concentrations of the constituents hi the discharge are shown in Table 1. The constituent
concentrations for the condensed steam portion of the discharge shown hi Table 1 are considered
to be maximums for the reasons previously cited.

Based upon a comparison of the concentrations of all constituents in Table 1 to Federal
and most stringent state water quality criteria (WQC), the concentrations of nitrogen (as
ammonia, nitrate/nitrite, and total nitrogen), phosphorous, benzidine, bis(2-ethylhexyl) phthalate,
copper, and nickel shown hi Table 1 are discharged in excess of Federal and/or the most stringent
state WQC. Table 2 shows the comparison of concentrations of those constituents that exceed
WQC to their WQC.

The discharge will not significantly increase concentrations of pollutants near the ship.
To empty the wet accumulator, multiple blowdowns are performed over an extended period of
time (up to 12 hours) to reduce pressure slowly and minimize noise, so concentrations near the
ship will be lower because the incremental discharges allow concentrations to dissipate.

4.3 Thermal Effects

The potential for catapult wet accumulator discharge to cause thermal environmental
effects was evaluated by modeling the thermal plume using mixing conditions that would
produce the largest plume and then comparing the thermal plume to state thermal discharge
requirements. Thermal effects of catapult wet accumulator discharge were modeled using
thermodynamic equations to estimate the plume size and temperature gradients in the receiving
water body.9 The model was run under conditions that would estimate the maximum plume size
(e.g., minimal wind, slack water) for a wet accumulator on an aircraft carrier. The plume
characteristics were compared to thermal mixing zone criteria for Virginia and Washington
State.9 Of the five states that have a substantial presence of Armed Forces vessels, only Virginia
and Washington have established thermal mixing zone dimensions. Other coastal states require
that thermal mixing zones be established on a case-by-case basis. Based upon this analysis, the
discharge of a wet accumulator pierside does not cause thermal effects that exceed any known
state criteria.9

4.4 Potential for Introducing Non-Indigenous Species

Given that the water in wet accumulators is condensed steam at a temperature of 460°F,
and the charging feedwater to the wet accumulators is distilled fresh water from the ship's water
generating plant, there is no potential for the transport of non-indigenous species.
Catapult Wet Accumulator Discharges
6
-------
5.0 CONCLUSION

Catapult wet accumulator discharge has a low potential to cause an adverse
environmental effect because:

• Mass loadings of benzidine, bis(2-ethylhexyl) phthalate, nitrogen, phosphorous,
copper, and nickel within 12 n.m. are small, less than a pound per year combined
fleetwide, discharged at concentrations near WQC;

• The discharge contains small quantities of water treatment chemicals;

• Resulting contributions to environmental concentrations from the discharge are
expected to be insignificant because the discharge event is spread out over
multiple blowdowns that allow concentrations to dissipate; and

• The discharge of a wet accumulator pierside does not cause thermal effects that
exceed known state thermal mixing zone criteria.
6.0 DATA SOURCES AND REFERENCES

Specific References

1. UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Discharges,
Round Two Meeting. March 14,1997.

2. UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Steam
Slowdown. August 20,1996.

3. Joe Hungerbuhler, NSWCCD-SSES 9223. Information on Catapult Wet Accumulator
Slowdown. November 1,1996. Clarkson Meredith, Versar, Inc.

4. Commander, Naval Air Force, U.S. Atlantic Fleet. Responses to TYCOM Questionnaire.
M. Rosenblatt and Son, Inc. May 20,1997.

5. Naval Ship Systems Engineering Station, Memorandum - Boiler Slowdown Discharges.
August 23,1991.
Catapult Wet Accumulator Discharges
7
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6. UNDS Equipment Expert Meeting Structured Questions - Nuclear Steam Generator
Slowdown/Safety Valve Testing Effluents. NAVSEA 08U, August 16,1996.

7. NSWC, Carderock Division, Memorandum - Chelant Boiler Feedwater Treatment
Implementation. March 18,1995.

8. Naval Ships' Technical Manual (NSTM), Chapter 220, Volume 2, Revision 7, Sections
21 and 22. Boiler Water/Feed Water Test & Treatment. December 1995.

9. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed
Services. Versar, Inc. July 3,1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
!
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. 62, Number 150. August 5, 1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
i
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

Catapult Wet Accumulator Discharges
8
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The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 -307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Steve Opet, NAWCADLKE. Information on Average Number of Shots per Catapult. April 4,
1997. Clarkson Meredith, Versar, Inc.

UNDS Equipment Expert Meeting Minutes - Aircraft Launch Equipment and Recovery
Equipment Discharge Meeting. August 22,1996.

Jane's Information Group, Jane's Fighting Ships, Capt. Richard Sharpe, Ed. Sentinel House:
Surrey, United Kingdom, 1996.

Patty's Industrial Hygiene and Toxicology, 3rd Edition, George D. and Florence E. Clayton, Ed.
John Wiley & Sons: New York, 1981.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A.. Volume 60 Federal
Register, p. 15366. March 23,1995.
Catapult Wet Accumulator Discharges
9
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Figure 1. Wet Accumulator Steam, Feed, and Slowdown Piping
Catapult Wet Accumulator Discharges
10
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o.
b.
'o
tu
D
~ I
o
DD
c

•a
JO)

Q
to
JO
a

f
o
'x
LJLl

(d
(D
+-*
C/D

c
c

I
LL
Figure 2. Wet Accumulator Internal Steam Charging Manifold
Catapult Wet Accumulator Discharges

11
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Table 1. Estimated Catapult Wet Accumulator Discharge Constituents, Concentrations,
and Mass Loadings Based Upon Steam Condensate Sampling Data
1
Constituents
From Steam Condensate1
Antimony
Total
Arsenic
Total
Cadmium
Total
Copper
Dissolved
Total
Lead
Dissolved
Total
Nickel
Dissolved
Total
Selenium
Total
Thallium
Dissolved
Zinc
Dissolved
Total
Ammonia as Nitrogen
Nitrate/Nitrite
Total Nitrogen
Total Phosphorous
Benzidine
Bis(2-ethylhexyl) phthalate
Concentrations (ug/I)
Log Normal Concentration,
Mean2 Range

7.13

0.74

2.86

13.4
20.1

3.58
4.38

10.3
11.6

2.87

1.18

13.94
11.35
180
440
1240
90
32.8
19.4

DDL -26.8

BDL - 2.3

BDL-6.1

BDL -49.0
BDL -91.0

BDL -12.7
BDL -18.9

BDL -22
BDL -34.7

BDL- 3.5

BDL - 13.3

7.15-21.9
BDL - 23.0
120 - 370
300 - 810
NA
BDL - 270
BDL - 73.5
BDL -112
RateoCWe*^;
fv Accumul ator
"Discharge {l/yr)3

125,000

125,000
125,000

125,000

125,000
125,000
125,000
125,000
125,000
125,000
125,000
125,000
Fleet-Wide Mass
Loading
' (pounds/yr)

2.0 xlO'3

2.0 x Iff4

7.9 x Iff4

3.7 x 1Q-3
5.5 x 1Q-3

9.9 x Iff4
1.2 x 10'3

2.8 x Iff'3
3.2 x 1Q-3

7.9 x Iff-4

3.3 x Iff-4

3.8 x 10'3
3.1 x 10'3
4.9 x 10'2
1.2 x 10'1
3.4 x 10'1
2.5 x 10'2
9.0 x 10'3
5.3 x 10"3
From Boiler Feedwater Treatment Chemicals4
Disodium phosphate
Ethylenediaminetetraacetic
acid(EDTA)
Hydrazine
100,000
25,000
25,000
NA
NA
NA
888,000
888,000
888,000
196
49
49
The constituents listed above are those expected to be found in the wet accumulator discharge. BDL denotes below detection
limit.
1. Constituents listed are the priority pollutants detected in steam condensate samples.
2. Highest of the dissolved and total log average values.
3. This value is the product of the annual wet accumulator discharge cited in section 3.2 and the conversion factor of 3.785
liters per gallon.
4. These concentrations are based on the specified rates of application of these constituents to boiler feedwater to inhibit
scaling and corrosion.
Log-normal means were calculated using measured analyte concentrations. When a sample set contained one or more samples
with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations equivalent to one-half of the
detection levels were also used to calculate the log-normal mean. For example, if a "non-detect" sample was analyzed using a
technique with a detection level of 20 mg/L, 10 mg/L was used in the log-normal mean calculation.
Catapult Wet Accumulator Discharges
12
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Table 2. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Catapult Wet Accumulator Discharge
Constituent
Ammonia as Nitrogen
Nitrate/Nitrite
Total Nitrogen
Total Phosphorous
Benzidine
Bis(2-Ethylhexyl)
Phthalate
Copper '
Dissolved
Total
Nickel1
Total
LogrNormal Mean ;
Concentration (ng/L)
180
440
1240
90
32.8
19.4

13.4
20.1

11.6
Federal Acute WQC (Hg/L)
< ,/• „ ,
None
None
None
None
None
None

2.4
2.9

74.6
- Most Stringent State
Aeute WQC ftis/L) -
6(HI)A
8(HI)A
200 (HI)A
25(ffl)A
0.000535 (GA)
5.92 (GA)

2.4 (CT, MS)
2.5 (WA)

8.3 (FL, GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
. 1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.

Assumes the constituents and their concentrations in this discharge are similar in concentration to the constituents
found in steam condensate that originates from shore facilities.
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
Table 3. Data Sources
"- "
, NOD Section
2. 1 Equipment Description, and;
Operation
2.2 Releases to the Environment
2,3 Vessels Producing theDiscnarge
3.1 Locality
3.2 Rate
3.3 Constituents
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Thermal Effects
4.4 Potential for Introducing Non-
Indigenous Species
Data Sources
Reported

UNDS Database
X
X

Sampling

Estimated

Equipment Expert
X
X
X
X

X
Catapult Wet Accumulator Discharges
13
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NATURE OF DISCHARGE REPORT
Cathodic Protection
1.0 INTRODUCTION

This section describes the discharge associated with cathodic protection and includes
information on: the equipment that is used and its operation (Section 2.1), general description of
the constituents of the discharge (Section 2.2), and the vessels that produce this discharge
(Section 2.3).

2.1 Equipment Description and Operation

Nearly all vessels use some form of cathodic protection to prevent metal hulls and
underwater structures from corroding. The Armed Forces (Navy, Air Force, Army, Military
Sealift Command (MSC)) and the U.S. Coast Guard (USCG) use cathodic: protection, in
conjunction with corrosion-resistant coatings, to protect their vessels. This combination provides
an optimal corrosion control system which utilizes the advantages of each individual system.
While coatings are the primary means of controlling corrosion, nearly all coatings have some
defects (whether from wear or damage) and some components are uncoated by design (e.g.,
propellers). Cathodic protection could, in theory, be used alone to protect a hull and other
external underwater structures, but the number of anodes for sacrificial-anode-based systems or
power requirements for Impressed Current Cathodic Protection (ICCP)-bEised systems would
increase greatly. When used in conjunction with coatings, cathodic protection reduces the effects
of wear and failure of the paint systems and reduces the associated required repairs and
maintenance. Without cathodic protection systems, vessels would be subject to severe corrosion
(i.e., dissolution and discharge of hull material) of the underwater hull and appendages resulting
in either increased underwater repairs and maintenance or more frequent dry-docking of the
vessels for renewal of underwater hull paint systems.

The two types of cathodic protection used by the Armed Forces — sacrificial anodes and
ICCP systems — are illustrated schematically in Figure 1. Small boats and craft which have
wood, aluminum, fiberglass or rubber (inflatable) hulls do not require cathodic protection to
protect these materials from corrosion (but may have small anodes located near the propellers for
their protection). Also, many of the small boats and craft with steel hulls that utilize sacrificial
anodes are stored out of the water on trailers or blocks.

2.1.1 Sacrificial Anodes

When sacrificial anodes are used, the anodes are physically connected (e.g., by bolts or
welding) to ship components and structures. As shown in Figure 2, an electrochemical cell is
formed between the anode and the cathode (the structure to which the anode is connected)
through the surrounding electrolyte (usually seawater). The anode is preferentially corroded or
"sacrificed", producing a flow of electrons to the cathode which results in. a reduction or
elimination of corrosion at the cathode. Large ships with mandatory dry-dock inspection and
overhaul intervals of less than three years, as well as the most boats and small craft, use
sacrificial anodes to protect the underwater hull. The numbers and sizes of the anodes are
determined by the wetted surface area of the hull, the planned replacement cycle of the anodes,
and the corrosion history of the vessel.

Cathodic Protection
2
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Sacrificial anodes continually corrode when immersed and require routine replacement to
maintain sufficient mass and surface area for adequate cathodic protection. On average, zinc
anodes are estimated to be completely consumed every six years.152'3'4 The consumption rate
depends on the service environment, the condition of the hull coating, and the location of the
anode on the hull.

Zinc anodes are used almost exclusively by DoD and USCG vessels for sacrificial
cathodic protection of hulls,5 with aluminum anode usage limited to a few (less than 5) Navy
submarines. Naval Sea Systems Command (NAVSEA) continues to evaluate aluminum anodes
for use on other Navy ships and their use requires prior NAVSEA authorization and design
review.5

Aluminum anodes have 3.4 times the current capacity" of zinc anodes due primarily to
differences in valence (3 for aluminum vice 2 for zinc) and density.5 The lower density of
aluminum anodes also results in aluminum anodes occupying more volume than zinc anodes of
the same weight. Development of the military specification6 for aluminum anodes has only
recently been completed although commercial aluminum anodes have been available for many
years. Aluminum anodes are not as readily available as zinc anodes and are more prone to
passivate (become inactive) than zinc anodes, but may be considered for use where the benefits
of increased current capacity and reduced weight offset the disadvantages of increased volume.

Sacrificial anodes used to prevent corrosion of heat exchangers, condensers, evaporators,
sewage collection, holding and transfer tanks, ballast tanks, bilges, sea chests, sonar domes, or
other non-hull areas or components are not addressed in this NOD report, but in NOD reports
describing these discharges (e.g. Seawater Cooling Discharge and Clean Ballast).

2.1.2 ICCP Systems

The Armed Forces also use ICCP systems (see Figure 3) to protect hulls in lieu of
sacrificial anodes. ICCP systems are employed when the wetted surface of the hull and other
underwater components requiring cathodic protection is large or a controllable system is
required.5 ICCP systems protect against corrosion using direct current (DC) from a source within
the ship in lieu of current provided by a sacrificial anode. Except for the source of current, the
mechanism of protection is identical for sacrificial anode cathodic protection and ICCP (see
Figure 1). The current is passed through platinum-plated tantalum anodes designed for a 20-year
service life. A silver/silver chloride (Ag/AgCl) reference electrode (control reference cell)
measures the electrical potential of the hull and is used to determine how much current is
required from the ICCP system to provide adequate cathodic protection.
1 Current capacity, a sacrificial anode material property, is the total current available per unit mass over the life of
the anode, commonly expressed as (amp-hr/kg) or (amp-yr/lb). The current capacity for zinc and aluminum anodes
is 812 amp-hr/kg and 2759 amp-hr/kg, respectively. Current capacity should not be confused with the maximum
output current of an anode, which is a function of the anode material, anode surface area, system resistance, and
driving potential. For most common types of zinc anodes used on underwater hulls, the maximum output current is
approximately 0.4 amps per anode.5

Cathodic Protection
3
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2.2 Releases to the Environment

2.2.1 Sacrificial Anodes

As the zinc or aluminum anode is consumed (oxidized), ionized zinc or aluminum is
released into the receiving waters. Water at the cathode (such as the steel hull) is reduced
forming hydroxyl (OH") ions which combine with the zinc or aluminum ions to form zinc or
aluminum hydroxide if excess oxygen is present. Another possible reaction produces hydrogen
at the cathode, especially in deaerated seawater.

In addition, oxidants (primarily chlorine and bromine) could also be produced in
secondary reactions because of the electrical potential of the anode. Precise reactions and
probabilities will vary with conditions in the seawater environment. However, the relatively low
electrical potential of the sacrificial anode (-1.05 volts average) compared with ICCP systems (-
15volts Ag/AgCl reference electrode) will result in less oxidant being formed. Those oxidants
which are formed will rapidly react with the surface of the sacrificial anode to form zinc or
aluminum chloride, or react with oxidant-demanding substances in the water. Due to the
relatively low electrical potential of sacrificial anodes and the rapid reactive nature of the anode
surface, the possible generation of oxidants by sacrificial anodes will not be considered further.

2.2.2 ICCP Systems

ICCP systems operate at higher electrical potentials than sacrificial anodes and
consequently can generate more oxidants. Precise primary and secondary reactions of oxidants
will vary with seawater conditions such as salinity, temperature, ammonia content, pH, etc., but
will primarily consist of various chlorinated and brominated substances. These substances
include: hypochlorous and hypobromous acids, hypochlorite and hypobromite, chloro- and
bromo-organics, chloride, bromide, chloramines, and bromamines. These substances are
commonly called Chlorine-Produced Oxidants (CPO) when associated with brackish or
seawater.7

The general reactions related to CPO are initiated when chlorine (Cb) is generated by the
reduction of chloride ions (Cl~) in seawater. The chlorine reacts to form hypochlorous acid
(HOC1) and the hypochlorite ion (OC1~) in the water. These two compounds, along with the
chlorine, are referred to as free chlorine. Free chlorine, the standard disinfection agent used hi
water treatment facilities, undergoes four important types of reactions in natural waters: (1)
oxidation of reduced substances arid subsequent conversion to chloride; (2) reaction with
ammonia and organic amines to form chloramines, collectively called combined chlorine; (3)
reaction with bromide to form hypobromous acid (HOBr) and hypobromite (OBf), called free
bromine; and (4) reaction with organics to form chloro-organics. Free bromine reacts in a
manner similar to free chlorine, oxidizing reduced substances or forming bromamines (combined
bromine) or bromo-organics. Most common analytical methods for quantifying CPO measure
the sum of all free and combined chlorine and bromine hi solution, but do not measure the
chloro- and bromo-organics.

Cathodic Protection
4
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Human health issues are a concern for some of these chlorinated hydrocarbons, which are
suspected carcinogens and pose a concern when found in significant quantities in drinking water.
However, these small quantities of chloro- and bromo-organics are produced only in brackish or
seawater. These materials are not generated by ICCP systems in freshwater ports due to the low
concentrations of chlorides and bromides. Most drinking water is drawn from groundwater or
freshwater sources. Armed Forces vessels that are homeported in seawater or brackish water
ports are not docked near drinking water intakes. Given the limited quantity and the location of
discharge, exposure to drinking water intakes is unlikely. These chlorinated hydrocarbons are
not separately addressed further in this NOD report.

2.3 Vessels Producing the Discharge

Table 1 shows the vessels that produce this discharge.1'8'9'10 The table identifies whether
vessels use sacrificial anodes or ICCP systems. Boats and craft of the Navy, Naval Auxiliary,
USCG, MSC, Army, and Air Force use sacrificial anodes for cathodic protection. Of the
approximately 5000 miscellaneous small boats and craft, approximately 30% are expected to
have steel hulls and therefore cathodic protection. The remaining 70% are assumed to have hulls
constructed of fiberglass, wood, aluminum, or other non-ferrous materials which do not require
cathodic protection.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Discharge from cathodic protection systems associated with a vessel's hull occurs
continuously whenever the vessel is waterborne. This discharge occurs both within and beyond
12 nautical miles (n.m.).

3.2 Rate

3.2.1 Sacrificial Anodes

The discharge from sacrificial anodes is characterized by a mass flux instead of a
volumetric flow rate because the "constituents" enter the receiving water directly (via corrosion
and dissolution). The following factors were used to calculate the average mass flux (also called
corrosion/dissolution) of sacrificial anodes while pierside and underway:

1. Based on underwater hull inspections and maintenance records one-half of an

Cathodic Protection
5
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anode is consumed after three years.
2. The corrosion/dissolution rate while underway is approximately three- to five-
times the pierside rate based on field studies.3'11 A factor of four is used for
calculations. Probable explanations for this phenomenon are: (1) the fully aerated
seawater produced by a moving hull increases reaction rates; and (2) more
corrosion products and other deposits and surface films are removed due to the
erosion forces of the seawater.

3. Based on the actual vessel movement data available, the average Navy vessel
spends approximately 176 days in port (pierside) and transits to or from port
(underway) approximately 11 times each year.12 The average MSC vessel spends
approximately 94 days in port and performs approximately six transits. Vessel
movement estimates for the Air Force, Army, and USCG vessels were made
based on operational knowledge (see Table 2). The vessel movement data for the
Navy was used in dissolution calculations since it results in the highest period of
time that vessels are in port.

Using the above factors, the corrosion/dissolution rates were calculated for zinc anodes as
shown in Calculation Sheet 1. At pierside, the rate was calculated to be 7.4 x 10~6 (Ib zinc/lb
anode)/hr, and underway, it was 3.0 x 10"5 (Ib zinc/lb anode)/hr. These rates can also be
expressed as a function of wetted hull area using a conversion factor based on information
presented in Table 2 which lists the vessels incorporating sacrificial anode cathodic protection.
This relationship is stated as follows:

Average density of zinc anodes = (total amount of anodes) / (total wetted surface area)

= (1,860,000 Ib) / (10,826,000ft2) = 0.17Ib/ft2

This results in average pierside and underway zinc generation rates of 1.3 x 10"6 and 5.1 x
10"6 (Ib zinc/square foot of underwater surface area)/hr.

Shipboard experience with aluminum anodes is limited, but as with zinc anodes the
corrosion/dissolution rate of the anode is primarily determined by factors such as the area of bare
metal requiring protection. Rates for aluminum anodes can therefore be calculated based on
process knowledge and the previously calculated generation rates for zinc anodes. Using the
ratio of current capacity of aluminum to zinc anodes, generation rates for aluminum anodes a
2.2 x 10"6 (Ib aluminum/lb anode)/hr pierside, and 8.8 x 10"6 (Ib aluminum/lb anode)/hr
underway.
are
Current capacity ratio = (aluminum anode current capacity) 7 (zinc anode current capacity)

=(27^amp-^r/k^/(812amp4ir/kg) ^ 3.4
Cathodic Protection
6
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3.2.2 ICCP Systems

Oxidant discharges from operating ICCP systems are also characterized by mass flux
instead of flow rate because the constituents are created from the surrounding water due to
electrolysis. Precise reactions and probabilities depend on a variety of conditions as described in
Section 2.2.2.

In order to estimate the rate that CPOs are formed from ICCP systems, a sample of ICCP
system logs was reviewed and the average current output for Navy vessels in port was found to
be approximately 35 amperes (amps).13 Using the assumption that 100% of ICCP system current
goes into producing chlorine, an hourly pierside chlorine generation rate of 46.3 grams (g) per
vessel was calculated using Faraday's Law:
(35 amps) (1 coulorab/amp-sec) (3,600 sec/far), (35.45 g chlorine/raole) (mole/96;484 coulomb)

_ = 46.3 g chlorine/hr ' ' .. -" - • - \, _•'
Since ICCP systems are designed (i.e., anode design and system operating voltage) to
maximize cathodic protection provided to the hull, and generation of chlorine or CPO is a
secondary reaction, actual CPO generation rates are expected to be significantly lower.

ICCP anode deterioration rates have been measured at 4.4 to 6.1 milligrams/ampere per
year by the manufacturer.14 For a vessel operating an ICCP system at 35 amps in port for 176
days per year, the resulting dissolution rate of platinum using 6.1 milligrams/ampere per year is:
214 mg/(sbip-year)
3.3 Constituents

3.3.1 Sacrificial Anodes

Zinc anodes are approximately 99.3% zinc and contain small amounts of cadmium and
aluminum (for activation).15 Table 3a lists the chemical composition of zinc anodes according
to military specifications.15 Zinc and cadmium are priority pollutants. None of the materials in
zinc anodes are bioaccumulators.

Aluminum anodes are approximately 95% aluminum, 5% zinc, and contain small
amounts of silicon and indium (for activation).6 Table 3b lists the chemical composition of
aluminum anodes according to military specifications.6 Zinc is a priority pollutant in aluminum
anodes. Aluminum anodes could possibly contain up to 0.001% mercury as an impurity;
mercury is a known bioaccumulator.
Cathodic Protection
7
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3.3.2 ICCP Systems

The deterioration of ICCP anodes (see Section 3.2.2) produces 214 mg/yr per ship of
platinum. ICCP systems also produce by-products (oxidants) when they operate. In addition to
the reduction reactions at the hull, ICCP systems can also produce chlorine, bromine and other
oxidants (CPO) through secondary reactions at the anode because of the electrical potential
(voltage) of the anode (see Section 2.2). These constituents are the primary concern for the ICCP
portion of this discharge. Chlorine or CPOs are neither priority pollutants nor bioaccumulators,
though EPA has developed water quality criteria for chlorine/CPO.

3.4 Concentrations

The discharge due to cathodic protection is a mass flux rather than a flow. The resultant
concentration of constituents in the environment are discussed in Section 4.2.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

4.1.1 Sacrificial Anodes

The number of sacrificial anodes installed on a vessel is related to the area of wetted
surface needing protection and the area that is available for placing the anodes. The discharge
from sacrificial anodes is therefore proportional to vessel size (except for submarines because the
anodes only protect the propeller and stem appendages and not the hull). The amount of anodes
installed is based on:

1. One 23-pound zinc anode per 115 ft2 of total wetted area for large vessels (with
more than 3,000 fl2 of wetted area).3'5

2. One 23-pound anode per 400 ft2 of total wetted area for smaller vessels, boats, and
craft.3

3. 2,024 pounds (88 anodes) of zinc anodes per submarine.3

Using the large vessel criteria for all vessels with over 3,000 ft2 of wetted surface is a
conservative assumption because this criteria was written for large, high value vessels that have
long periods between drydockings (and thus, less opportunity for anode replacement). Vessels

Cathodic Protection
8
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with wetted surface areas between 3,000 ft2 and 10,000 ft2 are drydocked more frequently,
increasing the opportunity for repainting and anode replacement, and therefore could use fewer
zinc anodes than the large vessel criteria. If the actual wetted surface area of a vessel was
unavailable, it was approximated using a formula in the Naval Ships' Technical Manual
(NSTM), Chapter 633:5
where
& = wetted surface area of the hull and appendages, in square feet
l = lengtKbetweett perpendiculars, in feet
d = molded mean di^ atliiH dispkcement, in feet " : , , „
V = molded volume of displacement in cubic feet
Where available, data on actual vessel movements were used to determine the number of
days in port, number of transits, and days underway operating within 12 n.m. for Navy, MSC,
USCG, and Army vessels. Where actual vessel movement data were not available, movement
data for vessels with similar missions were used. This information is shown in Table 2 and
Table 4. Using these data, the numbers of anodes installed on vessels, and anode
corrosion/dissolution rates, the mass flow rate of this discharge was calculated." When vessels
are in port, the pierside dissolution rate is used to calculate the constituent mass flow rate. When
vessels are operating within 12 n.m. of shore, the applicable dissolution rate is derived by
summing 66.7% of the pierside dissolution rate and 33.3% of the underway dissolution rate.
This applicable dissolution rate is then used to calculate the constituent mass flow rate. Total
constituent-specific mass flow rates are calculated by summing the pierside constituent mass
flow rate and the constituent mass flow rate when the vessel is operating within 12 n.m. An
example of the calculation for determining total constituent-specific mass loading is provided
below.
(305 days in port/yr) (24 hrs/day) (417 ft* anode/class) (7.4x10* Ib zinc/lb anode/hr) +
(60 days operating within 12 n.m./yr) (24 hrs/day) (417 Ib anode/class), [(0.667) (7.4X10"4 Ib
zmc/lbanode/hr);+(0.333) (3.0xlO'5lb zinc/lb anode/hr)] = ,- y
(22.59 Ib zinc/yr/class) + (S.96 Ib zinc/yr/class) » 31.55 Jb zmc/yr/class '
For the 89 submarines in the Navy fleet that use sacrificial anodes, the total estimated
annual loading of zinc within 12 n.m. is 6,360 pounds. Zinc anodes on submarines are required
to protect propellers and stern appendages, which are similar in surface area for all submarine
classes. Fifty-six of the Fleet's 89 submarines are Los Angeles Class submarines. A Los
Angeles Class submarine has eighty-eight 23-pound zinc anodes (2,024 pounds total) to protect
propellers and stern appendages.3 The number of anodes on a Los Angeles Class submarine (88)
was used for all submarine classes because the surface areas of the propellers and stern
appendages are similar among submarine classes.
11 Most DOD vessels will be at anchor or otherwise stationary 2/3 of the time and conducting transits or otherwise
moving 1/3 of the the time when operating within 12 n.m. of shore. For mass loading calculation purposes, a
combination of the pierside and underway dissolution rates was used, weighted 66.7% and 33.3% respectively.
These percentages are based on fleet provided information.

Cathodic Protection
9
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For surface vessels, an estimated 113,201 pounds of zinc is discharged annually within 12
n.m. The wetted surface areas and total amount of anodes used to calculate the zinc discharged
by vessels within 12 n.m. are presented in Table 2. The estimated mass loading was based on
1,805 surface vessels with a total wetted surface area of approximately 11 million square feet.

Mass loading for the approximately 5,000 small boats and craft of the Armed Forces was
estimated using the following information:

1. 30% have steel hulls, and therefore sacrificial anodes (the remaining have wood,
fiberglass, or aluminum hulls which do not require cathodic protection);

2. The average wetted surface area is 1,000 ft2 (the approximate wetted surface area
of a 65 ft tug boat), which is protected by approximately 58 pounds of zinc anodes
(23 pounds per 400 square feet);1"

3. Each vessel spends 100% of the time in the water (a conservative estimate since
many spend considerable time out of the water on trailers or blocks);

The resulting zinc discharged was then calculated using the static dissolution rate.
(5,000 vessels) (30%) (58 Ib anodes/vessel) (100%) (7.4 x 10"6 Ib zinc/lb anode/hr) (365 days/yr)
(24br/day) = 5.640Ibzinc/yr ,: : [
Based on conservative assumptions, this calculation presents the maximum magnitude of
the discharge from small boats and craft, which represents approximately only 5% of the
previously estimated total annual discharge of 119,561 pounds of zinc (surface ships and
submarines combined) for a maximum combined total of 125,201 pounds of zinc per year. This
discharge could contain up to 626 pounds per year of aluminum and up to 88 pounds per year of
cadmium, based on the potential concentration of minor constituents in zinc anodes.

Aluminum anodes are currently used on no more than 5 submarines. Using the
information in Table 4, each submarine with zinc anodes discharges approximately 71.5 pounds
zinc/year within 12 n.m. This zinc loading was scaled for aluminum anodes using the current
capacity ratio derived in Section 3.2.1 and the maximum number of vessels with aluminum
anodes, resulting in a total fleetwide annual consumption (discharge) of 105 pounds of aluminum
anodes as shown below.
RI Small boats and craft are non-standard vessels with wetted surface areas ranging from under one hundred square
feet to one thousand square feet. Because adequate information is not available to characterize the surface area of
specific small boats and craft, the upper bound of this range, one thousand square feet, is used as a conservative
estimate of the average wetted surface area.

Cathodic Protection
10
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(71.5 Ib zinc anode/submarine)/ (3.4) = 21.0 Ib alummmn anode/submarine
(21.0Ib aluminum anode/submarine) (5 submarines) = 105 Ib-aluminum anodes consumed,
'fleetwide " ' ^' .N',\__, .:,.. - "* ' . _ _ .'....' ^. .'' • _ !_ ' • "'

Based on the composition of aluminum anodes, this discharge is comprised of 100 pounds
aluminum, 5 pounds zinc, and could contain up to 0.21 pound per year of silicon and 0.02 pound
per year of indium. The maximum potential loading of mercury from aluminum anodes was
estimated to be 0.001 pound fleetwide, assuming that all aluminum anodes contain the highest
allowable amount of mercury.

4.1.2 ICCP Systems

The mass loading due to deterioration of ICCP anodes was calculated using the
previously discussed anode deterioration rate and the number of vessels with ICCP systems. For
the 267 vessels with ICCP systems, this results in a total fleet-wide platinum loading of:

(214 mg/yr) (273 vessels) = 57,138mg/yr = 57 g/yrs2 ounces/yr . '' ' - .-.

Annual CPO loadings were calculated using the estimated CPO generation rate of 46.3
g/hr per vessel (see Section 3.2). This rate was applied to the 273 vessels with ICCP systems
(see Table 1) and time spent in port for each class to calculate the mass loadings presented in
Table 5. The estimated annual loading of CPO based on the 273 vessels with ICCP systems is
98,000 pounds.

4.2 Environmental Concentrations

Two approaches were used to estimate the concentration of zinc and CPO in receiving
waters from cathodic protection systems. The first uses a simplified dilution model, based on
tidal flow in three major Armed Forces ports and is hereafter referred to as the "tidal prism"
approach. The second approach was based on a mixing zone proximate to the hull of a typical
Navy vessel. Each approach used the hourly zinc corrosion/dissolution rates and CPO
production rate developed in Section 3.2 (i.e., for zinc: a pierside rate of 1.3 x 10"6 (Ib zinc/ft^/hr
and an underway rate of 5.1 x 10'6 (Ib zinc/ft2)/!*, and for CPO: 46.3 (g/vessel)/hr).

Tidal Prism. The tidal prism approach uses the mass of the constituent generated by
vessels and mixes this mass with a volume of water. The mass is calculated by determining the
number of vessels in a particular homeport, the type of cathodic protection system utilized, and
the number of hours each vessel spends in port (both pierside and in transit) along with the
aforementioned zinc and CPO generation rates. Together, these factors are used to calculate an
annual loading to the harbor. The water volume used is the sum of all outgoing tides over a year
times the surface area of the harbor. The sum of outgoing tides is called the "annual tidal
excursion" which is defined as the difference between mean high water and mean low water over
the course of a year. Annual tidal excursion data is readily available from the National
Oceanographic and Atmospheric Agency (NOAA), and the 1996 data17 was used for these
calculations.

Cathodic Protection
11
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The tidal prism model assumes steady-state conditions, where zinc and CPO are
completely mixed with the harbor water and are removed solely by discharge from the port
during ebb tides. The outgoing tidal volumes are assumed to be carried away by long-shore
currents (i.e., those moving parallel to shore) and do not re-enter the harbor. The tidal prism
model also does not assume removal or concentration by other factors such as river flow,
precipitation, evaporation, sediment exchange, or natural decay. By not accounting for removal
or dilution due to river flow, precipitation, sediment exchange, and natural decay, the
calculations result in a higher constituent concentration. The effect of evaporation could be to
increase concentration due to water loss, or the effect could be neutral since water loss by
evaporation is replaced by (additional) water inflow from the sea. While the model assumes
complete mixing, there will be areas in the harbors with higher concentrations, primarily near the
source vessels, along with areas of lower concentration.

The three ports that are used for the tidal prism model shown hi Tables 6a, 6b, and 6c
include Mayport, FL, San Diego, CA, and Pearl Harbor, HI. These ports were selected because
they have minimal river inflow, small but well-defined harbor areas, and a high number of
vessels of the armed forces. Each of these factors will tend to overestimate concentrations of
zinc and CPO, either due to less volume of water or high numbers of potential sources. Other
major ports, such as Norfolk (VA) and Bremerton (WA), were considered, but not included
because of large river effects and very large harbor areas. The 1996 annual tidal volumes (annual
tidal excursion times the harbor surface area) for the three ports (calculations provided in
Calculation Sheet 2) are shown below:

• San Diego, CA: 3.77 x 1013 liters;
• Mayport, FL: 6.67 x 1011 liters; and
• Pearl Harbor HI: 3.41 x 1012 liters.

Mixing Zone: For the mixing zone approach, the previously calculated zinc and CPO
generation rates were used for each discharge, but the resultant environmental concentrations
were calculated based on various volumes of water around a typical Armed Forces vessel (i.e., a
"mixing zone") instead of the entire port, as above. A vessel with 19,850 ft2 of wetted surface
area (i.e., a FFG 7 Class frigate size vessel) was selected for modeling the environmental
concentration from sacrificial anodes since precise information was available for the number of
zinc anodes installed on that ship class. A vessel with 37,840 ft2 of wetted surface area (i.e., a
CG 47 Class cruiser size vessel) was selected for modeling ICCP system discharges because of
the large number of vessels in this ship class and it's hull size is typical of most vessels with
ICCP systems.

The model assumes the hull to be a half immersed cylinder (see Calculation Sheets 3 and
4). The zinc and CPO generation rates were then applied to various sizes of mixing zones
(volumes of water surrounding the vessel), ranging from 0.1 to 100 feet from the hull, and
mixing rates (the time required for the mixing zone contents to be exchanged with a new volume
of clean seawater), ranging from 0.1 to 1 hour, to calculate resultant incremental zinc and CPO
concentration increases shown in Table 7. The maximum time of exchange of 1 hour

Cathodic Protection
12
-------
corresponds to a realistic duration of slack tide, and is also the time required for a volume of
water flowing at 0.1 knots to flow past a 600 foot long vessel longitudinally. Actual exchange
times will usually be much less. For example, water flowing at 2 knots (typical for tidal flow)
past the same 600 foot long vessel results in a time of exchange of 3 minutes.

4.2.1 Sacrificial Anodes

The in-port (static) and transient (dynamic) zinc corrosion/dissolution rates of 7.4 x 10"6
and 3.0 x 10"5 pounds of zinc per pound of anode per hour, respectively, (see Calculation Sheet
1) were used for the tidal prism model. Only the static rate was used for the mixing zone model
since the highest potential concentrations would occur while the vessel is pierside.

Tidal prism. Based on the number and types of ships located in each of the three
1 o
harbors and the type of cathodic protection, the numbers of sacrificial anodes installed on each
of the vessels in each ship class were estimated, based on the information in Section 3.2.1. The
number and types of vessels using zinc sacrificial anodes at each port are listed in Table 6a.
Using the annual zinc loadings and annual tidal excursion volumes, the average zinc
concentrations caused by these vessels were calculated for each port (also shown in Table 6a).
The average zinc concentration estimated by the tidal prism model and the ambient zinc
concentrations19 are summarized below.
Port
Ambient
Zinc from Anodes
• San Diego, CA:
• Mayport, FL:
5.0 ug/L
• Pearl Harbor, HI: 12.8 ug/L
0.09jig/L
1.35 ug/L
0.31 ug/L
As shown above, the contribution of zinc from sacrificial anodes makes up only a small
portion of the ambient concentration, except for Mayport, where almost 30 percent of the
ambient concentration can be attributed to the dissolution of zinc anodes. In each case, the
ambient concentrations are well below the Federal and most stringent state water quality criteria
(between 76 and 85 ug/L) as shown in Table 8. Resultant incremental concentration increases of
minor constituents (aluminum and cadmium) are shown in Table 6a and are at least 40,000 times
lower than the most stringent Federal or state WQC.

A similar tidal prism analysis can be performed for aluminum anode usage on
submarines. Assuming that Pearl Harbor and San Diego each have the maximum five
submarines with aluminum anodes, Table 6b shows the concentrations resulting from aluminum
sacrificial anodes to be 0.02 ug/L of aluminum and 2xlO"7 ug/L of mercury for Pearl Harbor, and
much less for San Diego. These concentrations are significantly less than the most stringent state
WQC of 1,500 ng/L of aluminum (FL) and 0.025 ug/L of mercury (CT, FL, WA, and VA).
Incremental concentration increases for other minor constituents (zinc, silicon, and indium) are
also shown in Table 6b and are nearly 1,000,000 times lower than the most stringent Federal or
state WQC.
Cathodic Protection
13
-------
Mixing zone. The mixing zone model calculated zinc concentrations within "envelopes"
or mixing zones of uniform size and shape around a vessel's hull, assuming various exchange
rates. For calculation purposes, the mixing zones ranged from 0.1 foot to 100 feet from the hull,
and the exchange rates ranged from 0.1 hour to 1 hour. Actual exchange rates are rarely more
than one hour as discussed previously. Tabulated mixing zone calculations are presented in
Table 7 and do not include ambient concentrations of zinc in the water. Ambient zinc
concentrations for each port were then added to the mixing zone concentrations and compared to
ambient WQC.

Federal and state WQC exist for zinc (see Table 8). The Federal WQC is 81 ug/L for
chronic exposure. Washington state's WQC of 76.6 ug/L for chronic exposure is the most
stringent state criteria.19 For exchange rates of one hour or less, any mixing zone of six niches or
more results in zinc concentrations (including the contribution of zinc from ambient water in
each port) less than the most stringent state WQC of 76.6 ug/L for chronic exposure. Ambient
zinc concentrations for Mayport, FL and Pearl Harbor, HI were obtained from EPA's STORET
system. The Navy had more recent data on San Diego Bay and used this data rather than the data
from the STORET system.9'19 These concentrations are assumed to include any contributions of
zinc from sacrificial anodes.

The results of the mixing zone analysis developed for sacrificial zinc anodes (Table 7)
can be scaled to provide similar results for aluminum anodes using the current capacity ratio (3.4)
developed in Section 3.2.1 and the maximum allowable concentration of mercury (0.001%). The
sample calculation below was performed for the scenario from Table 7 that would produce the
highest estimated concentrations of aluminum and mercury (a time of exchange of one hour, and
a mixing zone of 0.1 foot):
Zinc concentration at radius of 0.1 ft = 236 ug/L ,

Aluminum concentration at same radius: — (236 ug/L)/(3.4) ~ 69.4 pg/L

Maximum potential mercury concentration at same radius = (69.4 ug/L)/( 100,000)
= 0.0007 ug/L -
The estimated concentration for aluminum (69.4 ug/L) is twenty times less than the most
stringent state chronic WQC of 1,500 ug/L (Fl), and there are no federal WQC for aluminum.
The estimated concentration for mercury (0.0007 ug/L) is 35 times less than Federal and most
stringent state chronic WQC (0.025 ug/L). Similar calculations can be performed for other
minor constituents of sacrificial anodes. In all cases, the resultant concentration increase is at
least 50 times less than the most stringent Federal and state WQC at a distance 0.1 feet from the
hull.

4.2.2 ICCP Systems

This discharge consists of various chlorinated and brominated substances (CPOs). As
discussed in Section 3.2.2, these generation rates assume that 100% of the current passed by the

Cathodic Protection
14
-------
ICCP system creates CPOs, while in actuality, the current also produces metal complexes,
oxygen, hydrogen, and other compounds in addition to CPOs with each collateral reaction
consuming a portion of the total current. Seawater conditions have a strong influence on the type
and magnitude of secondary reactions at the hull and sacrificial anodes. Because seawater
conditions vary with geographic location, the extent of secondary chemical reactions cannot be
accurately predicted. Therefore, a conservative assumption that 100% of the current produces
CPOs is used.

In order to estimate the amount of CPOs generated by ICCP systems, ships' logs for a
variety of vessels were reviewed to determine the average current produced by ICCP systems in
port (35 amps).13 From this information and Faraday's Law, an hourly, pierside CPO generation
rate of 46.3 g/hr was calculated (see Section 3.2.2). This rate was used for both the tidal prism
and the mixing zone models.

Tidal prism. Using the same approach as described in Section 4.2.1 and CPO generation
rates, annual CPO loading due to the Armed Forces vessels in each of the three ports were
calculated as shown in Table 6c. The chronic criteria and concentrations estimated from the tidal-
prism model are summarized below:
Port
Criteria CPO from ICCP
• San Diego, CA:
• Mayport, FL:
• Pearl Harbor, HI:
N/A*
10.0 p,g/L
7.5ug/L
0.17 ug/L
3.43 ug/L
0.75 ug/L
* San Diego discharge limits are set on a case-by-case basis

This model assumes complete mixing and does not consider any decay or secondary
reactions. However, CPO is known to rapidly decay hi seawater. In the first stage of CPO decay,
a portion of the CPO disappears within one minute, consumed by the instantaneous oxidant
demand. The rate of this first-stage reaction is related to temperature. One study, for example,
found that the percentage of CPO that disappeared within one minute varied from 4% at 0 °C to
40% at 32-33 °C.20 Other factors that influence the initial rate of decay include ammonia
concentration and the nature of the oxidant demand. In the second stage of CPO decay, the CPO
remaining after the first stage is reduced more slowly. Second stage decay half-lives of between
1 and 100 minutes have been observed.20 In most cases, however, the majority of CPO will
disappear within an hour of being added to seawater.20>21

If these decay rates were incorporated into the tidal prism model, the average CPO
concentrations shown above for the three ports would be lower. For example, the average CPO
concentration of 3.43 jj,g/L in Mayport, FL was calculated assuming zero CPO decay for the
duration of a tidal excursion. Using average decay estimates (i.e., 25% first stage decay after one
minute, 50% second stage decay per hour) provides a 98.8% reduction in CPO for the 12 hour
duration of a tidal excursion, resulting in CPO concentrations orders of magnitude below WQC.
Cathodic Protection
15
-------
Mixing zone. Using the mixing zone approach described for sacrificial anodes, CPO
concentrations within "envelopes" or mixing zones around a vessel's hull were calculated. For
calculation purposes the mixing zones ranged from 0.1 foot to 100 feet from the hull, and the
mixing rates ranged from 0.1 hour to 1 hour. As stated previously, actual exchange rates are
rarely more than 1 hour, and may be as low as a few minutes.

Tabulated calculations of CPO mixing zone calculations are included in Table 7. For
exchange rates of 1 hour or less, any mixing zone of 5.5 feet or more results in CPO
concentrations below the most stringent state chronic WQC of 7.5 ng/L. EPA's STORET system
does not contain monitoring data for chlorine; therefore, ambient conditions can not be
determined.

As for the tidal prism model calculations, these figures assume no decay of CPO. Using
the CPO decay rates discussed above, a 47.0% reduction in the CPO concentrations listed in
Table 6b for a 1 hour mixing zone exchange rate would be expected. Applying this decay rate to
the mixing zone model and assuming a time of exchange of one hour, any mixing zone with a
radius of 3 feet or more results in CPO concentrations caused by ICCP systems less than the most
stringent state chronic WQC of 7.5 jug/L.

4.3 Potential for Introducing Non-Indigenous Species

There is insignificant potential for transport of non-indigenous species by this discharge
because no water is retained nor transported.
5.0 CONCLUSIONS

5.1 Sacrificial Anodes

Cathodic protection discharges from sacrificial anodes have a low potential for causing
adverse environmental effects for the following reasons:

• the loadings from sacrificial zinc and aluminum anodes do not result in zinc or aluminum
concentrations, or concentrations of minor constituents, above ambient water quality
criteria in any of the harbors based on the results of the tidal prism model;

• zinc, aluminum, and mercury concentrations are below WQC within a distance of 0.5,
0.1, and 0.1 feet, respectively, during periods of slack water (little water movement in the
harbor); and

• loadings of mercury are small (less than 0.001 pound per year fieetwide).

This conclusion is based on corrosion/dissolution rates estimated from the average anode
replacement intervals for Navy vessels. The number of anodes per vessel class was based on
actual numbers or, in lieu of such data, estimated using the vessel's wetted surface area. This

Cathodic Protection
16
-------
approach was also applied to other Armed Forces vessels.

5.2 ICCP Systems

Cathodic protection discharges from Impressed Current Cathodic Protection (ICCP)
systems have a low potential for causing adverse environmental effects for the following reasons:

• the loadings from ICCP systems do not result in CPO concentrations above ambient water
quality criteria in any of the harbors based on the results of the tidal prism model; and

• CPO concentrations drop below WQC within a distance of 5.5 feet during periods of
slack water without considering CPO decay (which would reduce concentrations even
lower).

This conclusion is based on a review of ICCP system logs and the assumption that 100%
of the current passed from the ICCP system anodes generates CPO.

6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 9
shows the sources of data used to develop this NOD report.

Specific References

1. Commander, Submarine Force, U.S. Atlantic Fleet (Ser N451 A/4270), UNDS Data Call
Package Submission: Encl: 688 & 726 Class Submarine Discharge Data Packages.
December 13,1996.

2. Potential Impact of Environmental and Worker Health Laws on the Sacrificial Anode Life
Cycle. Ocean City Research Corp. June 1993.

3. M. Rosenblatt & Son, Inc., Zinc Anode Usage Guidance, April 23,1997.

4. Commander, Naval Air Forces, U.S. Atlantic Fleet. Responses to TYCOM
questionnaire. M. Rosenblatt & Son, Inc. May 20,1997.

5. Naval Ships' Technical Manual (NSTM) Chapter 633, Cathodic Protection. Sections
2.3.2 to 2.3.5,4.2.1,4.3.1,4.4 to 4.4.2, and Tables 3 and 4. August 1992.

6. Military Specification MEL-A-24779, Anodes, Sacrificial Aluminum Alloy, 1992

7. White, G.C., 1992, The Handbook of Chlorination and Alternative Disinfectants. Van
Nostrand Reinhold, New York, p. 1308.
Cathodic Protection
17
-------
8. UNDS Equipment Expert Meeting-Cathodic Protection, Sacrificial Anodes, Action Item
No. 124. November 14,1996.

9. UNDS Cathodic Protection Evaluation. The Marine Environmental Support Office,
Naval Command, Control and Ocean Surveillance Center, San Diego, CA. February 13,
1997.

10. Dan Kailey, M. Rosenblatt & Son, Inc., Master UNDS Vessel List, Conrad Bernier,
Malcolm Pirnie, Inc., April 23,1997.

11. Seelinger, Andrew; Shirnko, LCDR Michael J., Impressed Current Cathodic Protection
and Physical Scale Modeling, CORROSION, CAUSES AND CONTROL Short Course,
Naval Postgraduate School, Monterey, CA. June 1992.

12. Kailey, Dan, M. Rosenblatt & Son, Inc., Vessel Schedule Data, Clarkson Meredith,
Versar, Inc., April 23,1997.

13. M. Rosenblatt & Son, Inc., Summary of U.S. Navy Impressed Current Cathodic
Protection (ICCP) System Output, June 16,1997

14. Electocatalytic, Inc. Shipboard Impressed Current Anodes. February, 1992.

15. Military Specification MIL-A-18001, Anodes, Sacrificial Zinc Alloy. 1993.

16. Dunstan Mensah, SEA 91T131, September 30,1997, Inquiry on Aluminum Anode Usage
on Submarines, M. J. Shirnko, M. Rosenblatt & Son, Inc.

17. The National Oceanic and Atmospheric Administration Homepage,
www.olld.nos.noaa.gov/long wl.html, 1997.

18. The United States Navy, List of Homeports, Effective April 30,1997.

19. U.S. Environmental Protection Agency, Office of Wetlands, Oceans and Watersheds,
Assessment and Watershed Protection Division, Retrieval from STORET Database.
1997.

20. Davis, M.H., and Coughlan, J., 1983. A Model for Predicting Chlorine Concentrations
Within Marine Cooling Circuits and its Dissipation at Outfalls. In Jolley, R.L., Brunds,
W.A., Cotruvo, J.A., Gumming, R.B., Mattice, J.S., and Jacobs, V.A. (eds.), Water
Chlorination: Environmental Impact and Health Effects, Vol. 4, Book 1, Ann Arbor
Science, p. 347-357.

21. NAVSEA. Chlorination Report, Malcolm Pirnie. July 14,1997.
Cathodic Protection
18
-------
General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

UNDS Equipment Expert Meeting Minutes- Protection, Sacrificial Anodes. August 6,1996.
Cathodic Protection
19
-------
Fontana, Mars G., Corrosion Engineering, Third Edition, McGraw Hill, Inc., New York, 1986.

Jones, Denny A., Principles and Prevention of Corrosion, Macmillan Publishing Company, New
York, NY, 1992.

Uhlig, Herbert H. and Revie, R. Winston, Corrosion and Corrosion Control an Introduction to
Corrosion Science and Engineering, Third Edition, John Wiley & Sons, New York, 1985.

Van der Leeden, et. al. The Water Encyclopedia, 2nd Ed. Lewis Publishers: Chelsae, Michigan,
1990.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register,?. 15366. March23,1995.

Jane's Information Group, Jane's Fighting Ships. Capt. Richard Sharpe, Ed. Sentinel House:
Surrey, United Kingdom, 1996.

General Specifications for Ships of the United States Navy (GENSPECS), Section 633, Cathodic
Protection. 1995.

Ciscon, David, M. Rosenblatt & Son, hie., Vessel Transit Time, May 1,1997,. Clarkson
Meredith, Versar, Inc., Soule, R.E., M. Rosenblatt & Son, Inc., Response to Inquiry on
ICCP Systems, May 8,1997, Lee Sesler, Versar, Inc.

Aivalotis, LT Joyce, U.S. Coast Guard, Inquiry on Cathodic Protection of USCG Vessels, May
27,1997, Lee Sesler, Versar, Lie.

UNDS Shipcheck of U.S. Army Watercraft, Fort Eustis, VA, January 1998.

M. Rosenblatt & Son, Inc., Environmental Loading Due To Cathodic Protection, June 13,1997.

Malcolm Pimie, Lie., Estimate of Zinc Concentrations Contributed by Hull Mounted Sacrificial
Anodes in Selected Naval Ports:, June 2,1997.

Bonner, Frederick A., Malcolm Pirnie, Lie. Written Correspondence on Chlorine Discharge from
Freshwater Layup, Submarine Heat Exchangers. April 9,1997.
Cathodic Protection
20
-------
Table 1. Listing of Vessels,
Navy, MSC, Army, and USCG using Cathodic Protection
^£&S£^&^^**^°3S£&.

ATC
AT
CM
cu
CV59
CVN65
CV63
CVN68
CG47
CGN38
CGN36
DDG 993
DDG51
DD963
FFG7
FFG7
LCC19
LCM3
LCM6
LCM8
LCU 1610
LHD1
LHA1
LPD4
Navy Combatants
River Raider Class Mini Armored Troop Carriers
Armored Troop Carriers
Landing Craft, Mechanized
Landing Craft, Utility
Forrestal Class Aircraft Carrier
Enterprise Class Aircraft Carrier
Kitty Hawk Class Aircraft Carrier
Nimitz Class Aircraft Carrier
Ticonderoga Class Guided Missile Cruisers
Virginia Class Guided Missile Cruiser
California Class Guided Missile Cruiser
Kidd Class Guided Missile Destroyers
Arleigh Burke Class Guided Missile Destroyers
Spruance Class Destroyers
Oliver Hazard Perry Guided Missile Frigates
Oliver Hazard Perry Guided Missile Frigates
Blue Ridge Class Amphibious Command Ships
Mechanized Landing Craft
Mechanized Landing Craft
Mechanized Landing Craft
Utility Landing Craft (LCU 1600)
Wasp Class Amphibious Transport Docks
Tarawa Class Amphibious Assault Ships
Austin Class Amphibious Transport Docks
LPD 7 j Amphibious Transport Docks
LPD14
LPH2
LSD 36
LSD 41
LSD 49
MCM1
MHC51
PB
PER
PCI
SSBN726
SSN 637
SSN 688
SSN 671
SSN 640

AFDB4
AFDB8
AFDL1
AFDM14
AFDM3
AGF3
Amphibious Transport Docks
Iwo Jima Class Assault Ships
Anchorage Class Dock Landing Ships
Whidbey Island Class Dock Landing Ships
Harpers Ferry Dock Landing Ships
Avenger Class Mine Countermeasure Vessels
Osprey Class Coastal Minehunter Vessels
Mk HI and Mk IV Patrol Boats
Mk n River Patrol Boats
Cyclone Class Coastal Defense Ships
Ohio Class Ballistic Missle Submarine
Sturgeon Class Attack Submarine
Los Angeles Class Attack Submarine
Narwhal Class Submarines
Benjamin Franklin Class Submarines

Navy Auxiliary
Large Auxiliary Floating Dry Dock
Large Auxiliary Floating Dry Dock
Small Auxiliary Floating Dry Docks
Medium Auxiliary Floating Dry Dock
Medium Auxiliary Floating Dry Docks
Raleigh Class Miscellaneous Flagship

20
21
151
40
1
1
3
7
27
1
2
4
18
31
1
42
2
2
60
100
40
4
5
3
3

Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
ICCP
ICCP
ICCP
ICCP
ICCP
ICCP
ICCP
ICCP
ICCP
ICCP
ICCP
Sacrificial Anodes
ICCP
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
ICCP
ICCP
ICCP
ICCP
2 | ICCP
-2
5
8
3
14
12
31
25
13
17
13
56
1
2

1
1
2
1
4
1
Sacrificial Anodes
Sacrificial Anodes
ICCP
ICCP
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
ICCP
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes

ICCP
ICCP
ICCP
ICCP
ICCP
Sacrificial Anodes
-------
Table 1. Listing of Vessels,
Navy, MSC, Army, and USCG using Cathodic Protection
^tfggjjMf;
Mtf0k^ lrc*H
AGF11
AGOR21
AGOR23
AO177
AOE6
AOE1
ARD2
ARDM
ARS50
AS 39
AS 33
TR
YC
YD
YDT
YFN
YFNB
YFNX
YFP
YFRT
YFU
Y065
YOGS
YOGN
YON
YOS
YP
YR
YRB
YRBM
YRR
YRST
YSD 11
YTB 752
YTB 756
YTB 760
YTL 422
YTT

T-AE26
T-AE26
T-AFS1
T-AFS1
T-AG 194
T-AG 194
T-AGM22
T-AGOS 1

' '," ' ^ •.^^^^ji^^^^^'i^^^m^^kff^.
Austin Class Miscellaneous Flagship
Gyre Class Oceanographic Research Ships
T.G. Thompson Class Oceanographic Research Ships
Jumboised Cimarron Class Oilers
Supply Class Fast Combat Support Ships
Sacramento Class Fast Combat Support Ship
Auxiliary Repair Dry Docks
Medium Auxiliary Repair Dry Docks
Safeguard Class Savage Ships
Emory S Land Class Submarine Tenders
Simon Lake Class Submarine Tenders
Torpedo Retrievers
Open Lighters (nsp) ;
Floating Cranes (nsp)
Diving Tenders
Covered Lighters (nsp)
Large Covered Lighters (nsp)
Lighter - Special Purpose (nsp)
Floating Power Barges (nsp)
Covered Lighters - Range Tender (self propelled)
Harbor Utility Craft ( YFU 83 & 91 )
Fuel Oil Barges
Gasoline Barges
Gasoline Barges (nsp)
Fuel Oil Barges (nsp)
Oil Storage Barges (nsp)
Patrol Craft ( YP 654 & 676 )
Floating Workshops (nsp)
Repair and Berthing Barges (nsp)
Repair, Berthing and Messing Barges (nsp)
Radiological Repair Barges (nsp)
Salvage Craft Tenders (nsp)
Seaplane Wrecking Derrick (self propelled)
Large Harbor Tug (self propelled)
Large Harbor Tugs (self propelled)
Large Harbor Tugs (self propelled)
Small Harbor Tug (self propelled)
Torpedo Trials Craft
Miscellaneous Boats and Craft

Military Sealift Command (MSC)
Kilauea Class Ammunition Ships
Kilauea Class Ammunition Ships
Mars Class Combat Stores Ships
Mars Class Combat Stores Ships
Mission Class Navigation Research Ship
Mission Class Navigation Research Ship
Compass Island Class Missle Instrumentation Ship
Stalwart Class Ocean Surviellance Ship
Qaantity of Vessels

1
1
2
5
3
4
1
3
4
3
1
22
254
63
3
157
11
8
2
2
2
3
2
12
48
14
28
25
4
39
9
3
1
1
3
68
1
3
-5,000

5
3
6
2
1
1
1
5

Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
ICCP
ICCP
ICCP
Sacrificial Anodes
ICCP
ICCP
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes
Sacrificial Anodes

ICCP
Sacrificial Anodes
ICCP '
Sacrificial Anodes
ICCP
Sacrificial Anodes
ICCP
Sacrificial Anodes
-------
Table 1. Listing of Vessels,
Navy, MSC, Army, and USCG using Cathodic Protection
tr&m. •y* ^-B- *•»'*> *,!~ *&* \, "" #*, t~&*#-Ja**' " ^ ^^W^ x * ^ ^ "saSli-& "" y
^ ;%
^ >- £,*r^" - v^'v>^"5*'/,7 V, & 2?' < >
-------
Table 1. Listing of Vessels,
Navy, MSC, Army, and TJSCG using Cathodic Protection
K«
WLI65303
Inland Buoy Tender
Sacrificial Anodes
WLI 65400
Inland Buoy Tender
Sacrificial Anodes
WYTL65A
65 ft. Class Harbor Tugs
Sacrificial Anodes
WYTL65B
65 ft. Class Harbor Tugs
Sacrificial Anodes
WYTL65C
65 ft. Class Harbor Tugs
Sacrificial Anodes
WYTL65D
65 ft. Class Harbor Tugs
Sacrificial Anodes
Army
BCDK
Coversion Kit, Barge, Deck Cargo, Deck Enclosure
Sacrificial Anodes
BD
Barges, Derrick
12
Sacrificial Anodes
BK
Barges, Deck Cargo (nsp)
Sacrificial Anodes
BPL
Pier, Barge Type, Self-Evaluating (nsp)
Sacrificial Anodes
FMS
Floating Machine Shops
Sacrificial Anodes
J-Boat
Picket Boats
Sacrificial Anodes
LARC-LX i Lighter Amphibious Resupply Cargo (formerly B ARC)
23
Sacrificial Anodes
LCM-8
Landing Craft Mechanized
104
Sacrificial Anodes
LCU
Landing Craft Utility
48
Sacrificial Anodes
LSV
Frank S. Besson Class Logistic Support Vessels
Sacrificial Anodes
LT
Inland and Coastal Tugs
19
Sacrificial Anodes
LT
Inland and Coastal Tugs
ICCP
Q-Boat
Picket Boat
Sacrificial Anodes
ST
Small Tugs
13
Sacrificial Anodes
T-Boat
Boat, Passenger and Cargo
Total
2167
Sacrificial Anodes
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Table 3a. Chemical Composition, Zinc Anodes
(Galvanic Protectors)
Cadmium
(range)
Percent /
0.025-0.07
Aluminum
(range)
- Percent
0.1-0.5
Zinc. -*\ '
Percent
approx. 99.3
Table 3b. Chemical Composition, Aluminum Anodes
(Galvanic Protectors)
Indium
(range)
Percent
0.014 - 0.020
Zinc ,
(range)
Percent
4.0 - 6.5
^ Silicon j -
(range)
~ .' Percent
0.08-0.20
Aluminum
r- *
Percent
approx. 95.2
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Table 5. Vessels Estimated Annual ICCP Discharges
£ *" "^ ^ ™~/" *" "**• x *"""'' '**^ J"&*' ^*" ^ % ^ ^ /&$ " j'1*' x"^^^ -%,-!*Hi ^ ,1 "h^? *" f~s "* /^ fti "-~-™*^ J^puFfc
>— & ^ ^ ^^ *;, 3$"2-"- fZHtd^fS^^G?^ $*•*•+ -t * /* t* ^ ""^ ^-^ •^ Qjiii3i3Rw@l!3r 0^ SNiys- iyyi T tifirt ^ ^^~ *^ ^ ^
Navy Combatant
CV59
CVN65
CV63
CVN68
CG47
CGN38
CGN36
DDG 993
DDG51
DD963
FFG7
LCC19
LHD1
LHA 1
LPD4
LPD7
LPD14
LSD 41
LSD 49
PCI
Forrestal Class Aircraft Carrier
Enterprise Class Aircraft Carrier
Kitty Hawk Class Aircraft Carrier
Nimitz Class Aircraft Carrier
Ticonderoga Class Guided Missile Cruisers
Virginia Class Guided Missile Cruiser
California Class Guided Missile Cruiser
Kidd Class Guided Missile Destroyers
Arleigh Burke Class Guided Missile Destroyers
Spruance Class Destroyers
Oliver Hazard Perry Guided Missile Frigates
Blue Ridge Class Amphibious Command Ships
Wasp Class Amphibious Transport Docks
Tarawa Class Amphibious Assault Ships
Austin Class Amphibious Transport Docks
Amphibious Transport Docks
Amphibious Transport Docks
Whidbey Island Class Dock Landing Ships
Harpers Ferry Dock Landing Ships
Cyclone Class Coastal Defense Ships
1
1
3
7
27
1
2
4
18
31
1
2
4
5
3
3
2
8
3
13
143
76
137
147
166
161
143
175
101
178
167
179
185
173
178
188
192
170
215
105
350
186
1,007
2,520
10,978
394
701
1,715
4,453
13,516
409
877
1,813
2,119
1,308
1,381
941
3,331
1,580
3,344
Navy Auxiliary
AFDB4
AFDB8
AFDL1
AFDM 14
AFDM3
AO 177
AOE6
AOE1
ARDM
ARS50
Large Auxiliary Floating Dry Dock
Large Auxiliary Floating Dry Dock
Small Auxiliary Floating Dry Docks
Medium Auxiliary Floating Dry Dock
Medium Auxiliary Floating Dry Docks
Jumboised Cimarron Class Oilers
Supply Class Fast Combat Support Ships
Sacramento Class Fast Combat Support Ship
Medium Auxiliary Repair Dry Docks
Safeguard Class Savage Ships
1
1
2
1
4
5
3 .
4
3
4
365 e
365 e
365 e
365 e
365 e
188
114
183
365 e
208
894
894
1,788
894
3,576
2,302
838
1,793
2,682
2,038
Military Sealift Command
T-AE26
T-AFS 1
T-AG 194
T-AGM 22
T-AGS 45
T-AGS 51
T-AGS 60
T-AH 19
T-AKR295
T-AKR287
T-AO 187
T-ARC7
T-ATF 166
Kilauea Class Ammunition Ships
Mars Class Combat Stores Ships
Mission Class Navigation Research Ship
Compass Island Class Missle Instrumentation Ship
Waters Class Surveying Ships
John McDonnel Class Surveying Ships
Pathfinder Class Surveying Ships
Mercy Class Hospital Ships
Maesrk Class Fast Sealift Ships
Algol Class Vehicle Cargo Ships
Henry J Kaiser Class Oilers
Zeus Class Cable Repairing Ship
Powhatan Class Fleet Ocean Tugs
5
6
1
1
1
2
4
2
2
6
13
1
5
26
148
151
133
7
96
96
184
59
109
78
8
127
318
2,175
370
326
17
470
941
901
289
1,602
2,484
20
1,555
U.S. Coast Guard
WAGE 399
WPB 110 A
WPB HOB
WPB 1 IOC
Polar Class Icebreakers
Island Class Patrol Craft
Island Class Patrol Craft
Island Class Patrol Craft
2
16
21
12
148
72
137
157
725
2,822
7,047
4,615
U.S. ARMY
LT
Inland and Coastal Tugs
6
60
882

TOTALS
267

98,182
Estimates based on 100 % ICCP anode efficiency at a cuurent of 35 Amps producing 46.3 g/hr. of Chlorine.
(e) Denotes an estimate of days in port
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Table 9. Data Sources

NOD Section
2.1 Equipment-Description and "
Operation ~ > ,„ - "
2.2 Releases-to the Environment
2.3 Vessels Producing- the Discharge
3.1 Locality
3.2 Rate ,
3,2 Constituents ,
3.4 Concentrations-,- " * x
44 Mass Loadings
" 4.2 Environmental Concentrations
, 4.3 Potential fat Introducing Non- ' *
Indigenous Species . *< " ::
Data Source - , , .- -
~- Reported , r
X
X
UNDS Database
X

Sampling

Estimated

X
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Equipment Expert
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X
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Figure 1. Sacrificial Anode and Impressed Current Cathodic Protection
-------
(*)
CURRENT
FLOW
I ELECTRON
I FLOW
SEAWATER
(ELECTROLYTE)
CATHODE
•'M->M*n
4OHT
2H'+2e" ->
ANODE:

-CONSUMED IN THE
ELECTROCHEMICAL REATION

- SITE OF OXIDATION
REATION(S)
CATHODE:

- PROTECTED SURFACE

- SITE OF REDUCTION REACTION(S)

- OTHER REDUCTION REATIONS ARE
POSSIBLE.
Figure 2. Electrochemical Cell
-------
Figure 3. Impressed Current Cathodic Protection System
-------
1. Observed Zinc Consumption Rate:
(aggregate of in-port and underway)
Per 23-lb Anode

50% of 23 lb/3 years

= 3.83 Ib zinc/yr
Per Pound of Anode

3.83 (Ib zinc/yr)/ 23 Ib anode

= 0.167 Ib zinc/yr/lb of anode
2. Fraction of Year Vessel is:
In Port
365 days/yr

= 0.48
Underway

189 days/yr
365 days/yr

= 0.52
3. Annual Zinc Corrosion/Dissolution Rate:
let x = in port corrosion/dissolution rate,
and 4x = underway corrosion/dissolution rate
0.48 (x) + 0.52 (4) (x) = 0.167 (Ib zinc/yr)/lb of anode
x = 0.065 (Ib zinc/yr)/lb of anode
4x = 0.261 (Ib zinc/yr)/lb of anode
note: the underway corrosion/dissolution rate is 4 times the in port rate as discussed in section 3.2.1
and reference 3 and 10.
4. Hourly zinc corrosion/dissolution rate: In-Port
(per Ib anode)
0.065 (Ib zinc/lb anodeVvr
8760hr/yr
Underway
0.261 (Ib zinc/lb anode)/yr
8760 hr/yr
= 7.4 x 10"6 (Ib zinc/lb anode)/hr = 3.0 x 10"5 (Ib zinc/lb anode)/hr
5. Unit conversion:
Average density of zinc anodes (Table 2) = (1,862,000 Ib) / (10,861,000 ft2) = 0.17 Ib/ft2

In-Port: (7.4 x W6 (Ib zinc/lb anode)/hr)( 0.17 Ib/fl2) = 1.3 xlO^lb zinc/ft2)/^
Underway (3.0 x 10'5 (Ib zinc/lb anode)/hr) ( 0.17 Ib/ft2) = 5.1 x W6 (Ib zinc/ft2)/^
Calculation Sheet 1. Calculation of Corrosion/Dissolution Rates from Sacrificial Anodes
-------
Vertical tidal excursions for 1996 is based on the summation of the daily outgoing tides (i.e., high-high
water to low-low water and high water to low water).
San Diego

• Surface Area = (10,532 acres) (4046.2 m2/acre) = 4.26 x 107 m2

* Total annual vertical tidal excursion for 1996 = 884.5 m
Average tidal excursion = (884.5 m/yr)/((365 days/yr)(2 tides/day) = 1.2 m

• Tidal prism volume for 1996 = (4.26 x 107 m2) (884.5 m) = 3.77 x 1010 m3
= 3.77xlOl3L
Mayport

• Surface Area = (169.8 acres) (4046.2 m2 /acre) = 6.87 x 10s m2

• Total annual vertical tidal excursion for 1996 = 970.3 m
Average tidal excursion = (970.3 m/yr)/((365 days/yr)(2 tides/day) = 1.3 m

• Tidal prism volume for 1996 = (6.87 x 10s m2 ) (970.3 m) = 6.67 x 108 m3
= 6.67xlOuL
Pearl Harbor

• Surface Area = (3,031 acres) (4046.2 m2/acre) =1.23 x 107 m2

• Total annual vertical tidal excursion for 1996 = 278.2 m
Average tidal excursion = (278.2 m/yr)/((365 days/yr)(2 tides/day) = 0.38 m

• Tidalprismvolumeforl996 = (1.23xl07m2)(278.2m) =3.41xl09m3
= 3.41 x!012L
Calculation Sheet 2. Calculation of Tidal Prism Volumes for San Diego, CA; Mayport,
FL; and Pearl Harbor, HI
-------
1. Concentration = (Mass of Zinc) / (Volume)
2. Volume modeled as a half-immersed cylinder:
Ship Class: FFG7
Length = 415 ft
Underwater Wetted Area = 19,850 ft2 = 72(2)(7r)(R,Xlength)
= = (I)
=>R! = 15.225 ft(
Volume(modci) = V2 -V,
Vt = '/^(RO^length) = 151,1 10 ft3
V2 = '/27i(R, + d)2(length)
d = variable (1 ft for this sample calculation)

Volume = V2 - V, = ['/2TC(15.225 ft + 1 ft)2(415 ft)] - (151,1 10 ft3)
= 20,500 ft3
3. Mass of zinc:
Mass = (generation rate)(mass of anode installed)(time between water exchanges)
Generation rate = 7.4 x 10"6 (Ib zinc/lb anode-hr)
Mass of installed anodes = (172 anodes)(23 Ib/anode) = 3,956 Ib
Time between water exchanges = variable (1 hr for this sample calculation)

Mass of zinc generated = (7.4 x Iff6 (Ib zinc/lb anode-hr))(3,956 Ib)(l hr)
= 0.029 Ib zinc
4. Concentration:
Concentration = (Mass of Zinc)/(Volwae)(required conversion factors)
= (0.029 Ib 2inc)(454 g/lb)(l(f}ig/g)l\(2Q,5W f?)(28.32 L/f?)]
= 22.7 ug/L s 23 ug/L
notes:
(1) Additional significant figures recommended in this step due to subsequent squaring operation.
Calculation Sheet 3. Zinc Concentration (Mixing Zone Model) Sample Calculations
-------
1. Concentration = (Mass of CPO) / (Volume)
2. Volume modeled as a half-immersed cylinder:
Ship Class: CG47
Length = 533 ft
Underwater Wetted Area = 37,840 ft2 = '/2(2)(7t)(R,)(length)
=>Rj= 22.598 ft(1)
V, = '/27i(R,)2(length) = 427,558 ft3
V2 = '/2rcR, + d)2(length)
d = variable (1 ft for this sample calculation)

Volume = V2 - V, = ['/27i(22.598 ft + 1 ft)2(533 ft)] - (427,558 ft3)
= 38,677 ft3
3. Mass of CPO:
Mass = (generation rate)(efficiency)(time between water exchanges)
Generation rate = 46.g/hr
Efficiency =100%
Time between water exchanges = variable (1 hr for this sample calculation)

Mass of CPO generated = (46.3 g/hr)(100%)(l hr)
= 46.3g
4. Concentration:
Concentration = (Mass of CPO)/(Volwns)(required conversion factors)
- (46.3 g CPO)f/0Ws>/[(38,677 tf)(28.32 L/ft3)}
= 42.3ng/L = 4
notes:
(1) Additional significant figures recommended in this step due to subsequent squaring operation.
Calculation Sheet 4. CPO Concentration (Mixing Zone Model) Sample Calculations
-------
NATURE OF DISCHARGE REPORT
Chain Locker Effluent '
1.0 INTRODUCTION

This section describes the chain locker effluent and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Surface vessels of the Armed Forces have one to three anchors, depending on vessel
class.1 Each surface vessel's anchor is attached to at least 810 feet (135 fathoms) of steel chain
that is stored below decks in the chain locker when not in use. The chain is constructed in 90-foot
(15-fathom) lengths, called "shots," which are connected together by detachable links. A diagram
of a typical detachable link is provided in Figure 1. The inside of each detachable link is greased
to prevent binding and corrosion, and to permit easy disassembly of the detachable parts. The
chain locker is an enclosed compartment used only to store the anchor chain. The bottom of the
locker has a grating on which the chain is stowed. Below the grating is a sump. The chain locker
sump contains multiple zinc sacrificial anodes to prevent corrosion. The anodes are physically
connected (e.g. by bolts or welding) to the steel surface of the chain locker sump. The zinc
anode is preferentially corroded or "sacrificed" instead of the chain locker sump's steel surface.

The chain moves through the chain pipe and the hawse pipe as the anchor is raised or
lowered. The chain pipe connects the chain locker to the deck and the hawse pipe runs from the
deck through the hull of the ship. When recovering the anchor, the anchor and chain are washed
off with a fire hose to remove mud, marine organisms, and other debris picked up during
anchoring. Seawater from the fire hose is directed either through the hawse pipe or directly over
the side onto the chain while recovering the anchor.

The top of the chain pipe has a canvas sleeve to keep water from entering the chain locker
through the chain pipe. Under rare circumstances, like heavy weather, rain or green water
(seawater that comes over the bow during heavy weather) gets under the chain pipe canvas cover
and into the chain locker. A diagram of a typical chain locker is provided in Figure 2.

Any fluid that accumulates in the chain locker sump is removed by either a drainage
eductor for discharge directly overboard or by draining the chain locker effluent into the bilge.
As the fluid in the chain locker sump is being drained for overboard discharge, the locker is
sprayed with firemain water to flush out sediment, mud, or silt. An eductor is a pumping device
that uses a high velocity jet of seawater from the firemain system to create a suction to remove
the accumulated liquids and solids. The seawater supply from the firemain system is referred to
as motive water for the eductor. OPNAVTNST 5090.1B, Section 19-10 requires chain lockers of
Navy vessels to be washed down outside of 12 n.m. to prevent the transfer of non-indigenous
species and to flush out any sediment, mud, or silt.2 Chain locker effluent which is drained into
the bilge becomes bilgewater and is covered by the Surface Vessel Bilgewater/OWS Discharge
NOD report.

2.2 Releases to the Environment

Chain Locker Effluent
2
-------
Chain locker effluent has the potential to contain living plants and animals, including
microorganisms and pathogens, that are native to the location where the water was brought
aboard during anchor retrieval. Chain locker effluent can also contain paint, rust, grease, and
zinc. The chain locker and eductor operations are performed using water from the firemain.
Therefore, the chain locker effluent can contain any constituents present in firemain water (see
Firemain NOD report).

2.3 Vessels Producing the Discharge

Cham locker discharges occur in surface ships equipped with a wet firemain, including
vessels belonging to the Navy, U.S. Coast Guard, Military Sealift Command, Army, and Air
Force.3 Submarine chain lockers are always submerged, open to the sea, and do not collect
effluent to produce this discharge.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

The Navy has an instruction for chain locker effluent discharge.2 This instruction states
that following anchor retrieval, chain lockers shall be washed down outside 12 miles from land to
flush out any sediment, mud, and silt. This guideline also helps prevent the transfer of unwanted
pathogens and marine organisms present hi chain locker effluent.

3.2 Discharge Rate

Rated capacities of the eductors used to pump out chain locker sumps range between 50
and 150 gallons per minute. The chain locker effluent is mixed directly with the motive water
from the firemain system before going overboard. The eductor uses 1/2 to 1 gallon of motive
water for every gallon of effluent. Therefore, the total discharge ranges between 75 and 300
gallons per minute, of which 25 to 150 gallons per minute is motive water. The amount of
effluent discharged yearly cannot be measured because the discharge is infrequent and little
effluent is discharged.

3.3 Constituents

The small amount of water that is washed into the chain locker drains through the bottom
grating and into the sump where it contacts paint chips, rust, grease, and sacrificial zinc anodes.
This water has the potential to contain marine organisms.

Chain Locker Effluent
3
-------
The chain locker is painted using epoxy polyamide, epoxy, and zinc primer. '''

The detachable links and other anchor chain components are periodically lubricated with
Termalene #2, a water-resistant grease (Commercial Item Description (CID) A-A-50433).
Termalerie #2 is a compound that includes mineral oil, an aluminum complex, a calcium-based
rust inhibitor, an antioxidant, and dye.7 The grease was tested for resistance to washout.8'9 This
test measures the water washout characteristics of lubricating greases under elevated
temperatures and mechanical operating conditions. Termalene #2 experienced "nil" washout
when tested.9 Because the grease is not exposed outside the link and due to the wash-resistant
nature of the grease, it is unlikely grease would be released to the environment.

The zinc anodes in the chain locker can be in contact with seawater for extended periods
of time. Zinc can leach continuously into the chain locker sump. The water that collects in the
chain locker is a combination of seawater and water from the firemain. Also, firemain water is
used as motive water when chain locker effluent is discharged. Therefore, the water could
contain the constituents present in the firemain water. A more complete discussion of these
constituents is found in the Firemain Systems NOD report.

The chain locker effluent might contain the priority pollutants bis(2-ethylhexyl) phthalate,
copper, iron, nickel, and zinc. This effluent does not contain any bioaccurnulators.

3.4 Concentrations

The concentrations of constituents present in the chain locker cannot be easily measured.
Chain lockers are kept dry on most vessels to reduce maintenance. Zinc anodes are present in the
bottom of the chain locker. Because the chain locker is often dry, it is unlikely that these anodes
significantly affect the concentration of zinc hi the effluent. The average measured
concentrations of firemain water constituents that exceed the Federal and/or most stringent water
quality criteria are presented hi Table I.10 Firemain is used as the motive water for drainage
eductors.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. Mass loadings are
discussed in Section 4.1 and the concentrations of discharge constituents after release to the
environment are discussed in Section 4.2. In Section 4.3, the potential for the transfer of non-
indigenous species is discussed.

4.1 Mass Loadings

Mass loadings were not calculated because constituent concentrations were not estimated.
Chain locker effluent is not anticipated to result in significant loads within 12 n.m. because of the

Chain Locker Effluent
4
-------
infrequency of discharge and because of the management practices in place which pump this
discharge overboard when the vessel is beyond 12 n.m. of shore. Chain locker effluent is
discharged infrequently because only small volumes of water accumulate in the chain locker
sump over time. This determination was made after inspections of chain lockers aboard several
ships.10'11

4.2 Environmental Concentrations

Chain locker effluent is expected to contain zinc, rust, paint, grease, and any constituents
from the firemain water. Because of the intermittent nature of this discharge, acute toxicities are
the primary concern. There is no concentration data available for chain locker effluent. Table 1
shows the concentration of constituents of firemain water that total nitrogen, bis(2-ethylhexyl)
phthalate, copper, iron, and nickel, exceed the Federal and/or the most stringent state acute water
quality criteria.

4.3 Potential for Introduction of Non-Indigenous Species

Inspections of chain lockers aboard several ships revealed that only small amounts of
water actually accumulate within the chain locker. Therefore, there is little potential for
introducing non-indigenous species into the chain locker. The process of washing down the
anchor as it is taken aboard and discharging the effluent beyond 12 n.m. further reduces the
possibility of transferring species via the chain locker.2
5.0 CONCLUSIONS

The small volume of chain locker effluent results in small mass loadings and provides
little opportunity for the transfer of non-indigenous species. The discharge volume is expected to
be small even if the discharge was not controlled. Therefore, this discharge has a low potential
for causing adverse environmental effects.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 2
shows the source of the data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Anchor Chain Washdown and Chain Locker
Effluent. July 30, 1996.

2. OPNAVINST 5090.IB, Environmental and Natural Resources Program Manual,
November 1 1994.
Chain Locker Effluent
5
-------
3. UNDS Round 2 Equipment Expert Meeting Minutes. March 11,1997.

4. Military Specification MIL-P-24441, Epoxy polyamide. July 1991.

5. Performance Specification MCL-PRF-23236, Epoxy. April 1990.

6. Naval Ships' Technical Manual (NSTM). Chapter 631, Paragraph 8.23.2.1. Preservation
of Ships in Service. December 1996.

7. Bel Ray Company, Inc., Material Safety Data Sheet for Termalene #2. 1996.

8. The American Society for Testing and Materials (ASTM) test method D-1264. June
1996.

9. Bel Ray Company, Inc., Product Data Sheet for Termalene #2. 1993.

10. UNDS Phase 1 Sampling Data Report. Volumes 1-13, October 1997.

11. Navy Fleet Technical Support Center Pacific (FTSCPAC) Inspection Report Regarding
Elevator Pit and Anchor Chain lacker Inspection Findings on Six Navy Ships, March 3,
1997.
General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.
Chain Locker Effluent
6
-------
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
.*

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

Van der Leeden, et al. The Water Encyclopedia, 2nd Ed. Lewis Publishers: Chelsea, Michigan,
1990.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. 23 March 1995.
Chain Locker Effluent
7
-------
MATCH MARKS
NOTCH
Figure 1. Schematic Diagram of a Typical Detachable Chain Link
Chain Locker Effluent
8
-------
Figure 2. Schematic Diagram of a Typical Chain Locker
Chain Locker Effluent
9
-------
Table 1. Concentrations of Constituents of Wet Firemain Discharge
that Exceed Water Quality Criteria
Constituents
Classicals (ug/L)
Total Nitrogen
Organics (ue/L)
Bis(2-ethyJhexyl)
phthalate
Metals (ug/L)
Copper
Dissolved
Total
Iron
Total
Nickel
Dissolved
Total
Log-normal
Mean
Effluent

500

24.9
62.4

370

13.8
15.2
Minimum
Concentration
Effluent

BDL

BDL
34.2

95.4

BDL
BDL
Maximum
Concentration
Effluent

428

150
143

911

38.9
52.1
Federal Acute
WQC

None

2.4
2.9

None

74
74.6
Most Stringent
State Acute WQC

200 (HI)A

5.92 (GA)

2.4 (CT, MS)
2.5 (WA)

300 (FL)

74 (CA, CT)
8.3 (FL, GA)
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 13 1 .36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
A - Nutrient criteria are not specified as acute or chronic values.
CA ~* California
CT •* Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA * Washington
Table 2. Data Sources

NOD Section
2. 1 Equipment Description and Operation
2.2 Releases to the Environment
23 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Data Source
Reported

UNDS Database

PMS Cards (a)

Sampling

Estimated

unknown
unknown
unknown

Equipment Expert
X
X
X
X

X
(a) PMS - Navy planned maintenance system
Chain Locker Effluent
10
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NATURE OF DISCHARGE REPORT
Clean Ballast
1.0 INTRODUCTION

This section describes the clean ballast discharge and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Ballast water is carried by many types of vessels and is held in a variety of tanks. The
relative complexity of ballast operations depends on the size, configuration, and requirements of
the vessel and on the complexity of its pumping and piping systems.

Clean ballast water is seawater which is introduced into dedicated ballast tanks to adjust a
vessel's draft, buoyancy, trim and list, and to improve stability under various operating
conditions. For example, ballast water is used on various vessel classes to replace the weight of
off-loaded cargo or expended fuel oil. Generally, seawater is directed to the ballast tanks from
the firemain, by flooding, and/or from dedicated ballast pumps. Ballast intake systems are
usually covered with a grate; suction strainers can be used to protect the pumping system from
debris. Ballast water is discharged through valves by gravity or pressurized air, or is pumped out
by eductors. Clean ballast tanks are dedicated to ballasting operations and their contents are not
mixed with fuel or oil.

Amphibious assault ships also flood clean ballast compartments during landing craft
operations to lower the ship's stem, allowing the well deck to be accessed. This ballast water is
subsequently discharged at the end of the operation. Figure 1 depicts a typical amphibious ship
ballast and deballast tank system.

U.S. Navy submarines have main and variable ballast systems. The main ballast system
controls the submarine's overall buoyancy while the variable ballast system controls the
submarine's trim and list, and adjusts for variations in the submarine's buoyancy while operating
submerged.

2.2 Releases to the Environment

Ballast water has the potential to contain plants and animals, including microorganisms
and pathogens, that are native to the location where the water was brought aboard. When the
ballast water is transported and discharged into another port or coastal area, the surviving
organisms have the potential to impact the local ecosystem. Ballast water also has the potential
to contain metals and chemical constituents from contact with piping systems and ballast tank
coatings. Releases to the environment occur when ballast water is discharged.

2.3 Vessels Producing the Discharge

Ballast water collection and discharge practices depend on vessel class and mission
characteristics. Most surface vessels in the Navy have clean ballast systems, including the

Clean Ballast
2
-------
following vessel classes: amphibious assault ships (LHD, LHA, LPH), aircraft carriers
(CV/CVN), amphibious transport docks (LPD), frigates (FFG), dock landing ships (LSD), oilers
(AOE), and amphibious command ships (LCC). All U.S. Navy submarines (SSNs and SSBNs)
have main and variable ballast systems.

U.S. Coast Guard (USCG) vessels that have designated seawater ballast tanks include the
following classes: medium endurance cutters (WMEC), sea going buoy tenders (WLB), and ice
breakers (WAGE).

Most Military Sealift Command (MSC) have clean ballast systems, including the
following vessel classes: fleet-support auxiliary ships (T-AFS, T-AE, and T-AO), point-to-point
supply ships (T-AKR) and other ships (T-AH, T-AGS, T-AGOS, T-AGOR, T-AG, T-AGM, and
T-ATF).1

Army ships designed for intra-theater cargo transport (LCU-2000 and LS V) take on and
discharge clean ballast when loading and unloading cargo and equipment. Vessels of the Air
Force also discharge ballast water within 12 nautical miles (n.m.) of shore.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

The mode and location of ballast water discharge differs for Navy, USCG, MSC, Army,
and Air Force vessels, and also varies among individual ship classes depending on the mission or
design of the vessel. Discharge of ballast water is intermittent for vessels of each service.
Discharges can occur in port or at sea depending upon service policies and the individual vessel's
operational requirements. Ballast water is normally released at sea (outside of 12 n.m.) or in the
same general vicinity from which it was taken aboard.

hi order to adopt the intent of guidelines established by the International Maritime
Organization (IMO), the Navy has instituted a "double-exchange" policy for surface vessels.2
All Navy surface vessels completely offload ballast water originating in a foreign port outside of
12 n.m. from shore and take on and discharge 'clean sea water' two times prior to entry within 12
n.m. of shore. The seawater then can be discharged within 12 n.m. of shore whenever ballast is
no longer needed.

All submarines submerge by filling externally mounted main ballast tanks (MBTs) and
surface by emptying them. Discharges from MBTs happen mainly during surfacing when
seawater in MBTs is displaced overboard by air forced into the tanks. The majority of

Clean Ballast
3
-------
submarines submerge and surface outside of 12 n.m. of shore, however, submarines on occasion
do surface and submerge within 12 n.m. of shore at selected ports where ocean depth and vessel
traffic permit this practice. While transiting on the surface from port, variable ballast water can
be discharged to make small adjustments to the ship's trim. Once the submarine submerges, the
variable ballast system is used as necessary to maintain trim and stability. In port, both main and
variable ballast can occasionally be taken on or discharged to support maintenance activities or to
compensate for weight changes. Any ballast water taken on by the MBTs in port is discharged
prior to leaving port. While visiting foreign ports, submarines avoid taking water into the
variable ballast system. If additional variable ballast water is required, submarines take on
freshwater to prevent fouling of systems and equipment.

Amphibious ships take on ballast water in coastal waters (within 12 n.m.) during landing
craft operations and discharge it at the conclusion of those operations in the same general
location.

USCG vessels do not discharge ballast water collected near one coastal area into another
coastal area. Coast Guard vessels are required to exchange their ballast water twice beyond 12
n.m. of shore, if the water originated from within 12 n.m.3'4

MSC vessels may discharge clean ballast both at sea and in port. The location of the
discharge varies by vessel category. Fleet-support auxiliary ships typically load ballast at sea
when discharging cargo and unload ballast near shore when taking on cargo. Point-to-point
supply ships typically ballast to replace the weight of consumed fuel, not to compensate for off
loaded cargo, and deballast occurs after a voyage, usually in port. The remaining ships of the
MSC fleet typically ballast to bring the ship to an appropriate draft and trim for mission
requirements. Some of these ships may hold ballast for long periods and others may use
freshwater ballast only.1 Although an official MSC policy has not yet been approved, many
MSC vessels currently abide by IMO guidelines, which recommend exchanging ballast water in
waters 2,000 meters or more in depth before entering coastal zones.5

Navy, USCG, and IMO policies for surface vessels are summarized in Table 1.

3.2 Rate

The volume of seawater discharged during deballasting operations varies by vessel class
and activity. Typical ballasting operations on surface ships only use a portion of the total ballast
capacity. For example, the average maximum ballast carried by a T-AO 187 Class ship has been
reported to be around 50% of capacity, although the actual quantity of ballast varies significantly
depending on the quantity of cargo carried.1

Total capacity of individual ballast systems varies significantly by vessel class. The LSD
41 Class and T-AO 187 Class ships have ballast tanks with a capacity of three million gallons.
T-AKR 287 Class ships have a total ballast capacity of approximately 1.2 million gallons, while
the MSC oceanographic research ship, USNS Vanguard (T-AG 194), carries approximately 1.7
million gallons of freshwater ballast that is only emptied in dry dock during tank inspections.1'6
Clean Ballast
4
-------
Other ship capacities for Navy and USCG vessels are as shown in Table 2.

Deballasting flow rates also vary significantly by vessel class. Deballasting methods
include gravity fed systems, eductor systems, or compressed air pumps with associated drain
valves. Typical air compressors that pressurize and empty ballast tanks on board amphibious
ships are rated for 2,000 standard cubic feet per minute (scfrn) air flow which is sufficient to
displace an equivalent of 14,960 gallons per minute (gpm) of ballast water. Main ballast tanks
on submarines are typically evacuated within 30 minutes using pressurized air.7

3.3 Constituents

Constituents of clean ballast may include material from piping and piping components,
coatings, and additives.

Rust inhibitors containing aliphatic petroleum distillates are commonly applied to some
MSC ballast tanks. Additional constituents may include flocculant chemicals, composed of 95%
water and 5% salts and polymers.8 Flocculant chemicals are introduced in ballast tanks of some
MSC vessels to facilitate the discharge of suspended silts during deballasting operations.
Sediments frequently accumulate on the bottom and on many horizontal surfaces of ballast tanks
and may be discharged during deballasting operations. Lead-block ballast are also present in the
ballast tanks on some MSC vessels.

Metals and chemical constituents can be introduced to ballast water through contact with
piping systems and ballast tank coatings. Constituent loadings are expected to increase with
increased residence time of water in the clean ballast systems. The composition of piping and
components that contact ballast water includes iron, copper, nickel, bronze, titanium, chromium,
and composites. These composites are a linen reinforced graphite phenolic compound and
reinforced epoxy matrix. Fitting and valve materials include aluminum, copper, nickel, and
silver-brazed materials. Synthetic and cloth-rubber gaskets, nitrile seals, and ethylene propylene
rubber O-ring seals may also be wetted parts of the ballast system.9'10

The interiors of tanks of Navy vessels are typically coated with epoxy coatings, and the
tanks can contain zinc or aluminum anodes for cathodic protection.11'12 Ballast tank coating
specifications list the following constituents: polyamide, magnesium silicate, titanium dioxide, a
solvent, naphtha, and epoxy resin. Specifications also dictate the maximum allowable
concentrations of solvents in epoxy coatings.

Firemain systems are used to fill many clean ballast tanks. Although concentrations in
firemain discharge cannot be directly correlated with constituent concentrations in clean ballast
water, analytical data obtained from sampling of shipboard firemain systems could serve as an
indicator of potential constituents introduced to clean ballast water. Based on the make up of
clean ballast systems and the analytical results of firemain discharge sampling, the following
priority pollutants could be present within the discharge: copper, nickel, and zinc. No
bioaccumulators are known or suspected to be present in clean ballast discharge.
Clean Ballast
5
-------
3.4 Concentrations

Although suspected constituents in clean ballast discharge have been identified,
constituent concentrations were not estimated.
4.0 NATURE OF DISCHARGE ANALYSIS

4.1 Mass Loadings

Using known tank volumes and numbers of vessels in specific classes, an estimate of the
total ballast capacity is presented in Table 2. Most surface vessels are required to conduct double
exchanges outside of 12 n.m. of shore unless the discharge of the clean ballast is located in the
same geographical region as the intake, or operational conditions prevent the double flush from
being performed. Additional ballast exchanges occur within 12 n.m. Although total ballast
capacity estimates have been made, mass loading of chemical constituents were not estimated
due to the uncertainty in the frequency of ballasting operations and the lack of chemical
constituent data.

4.2 Environmental Concentrations

Although water quality criteria are available for suspected constituents, no analyses have
been completed and constituent concentrations are not available. A comparison of
concentrations with water quality criteria was not made.

4.3 Potential for Introducing Non-indigenous Species

Discharged clean ballast water from vessels of the Armed Forces has potential for
introducing non-indigenous species into receiving waters. This can be inferred from studies of
commercial vessels.

Studies of foreign ballast water commonly introduced into the Chesapeake Bay found that
more than 90% of the commercial vessels carried live organisms. Forty percent of the sampled
vessels had organisms within their ballast tanks including dinoflagellates and diatoms. Such
organisms are suspended in both water and sediments within ballast tanks. Organisms also may
attach to tank walls and be dislodged during deballasting.13 One study characterized a variety of
non-indigenous species in 159 cargo vessels arriving in Coos Bay, Oregon, from 25 different
Japanese ports. The study found 367 distinctly identifiable taxa, representing 16 animal phyla, 3
protist phyla, and 3 plant divisions. Organisms present in most vessels included copepods (99%

Clean Ballast
6
-------
of vessels), polycheate worms (89%), barnacles (83%), clams and mussels (71%), flatworms
(65%), crabs and shrimp (48%), and chaetognaths (47%).13

The preliminary conclusion of a Smithsonian Environmental Research Center (SERC)
study of three Navy surface ships' ballast water during transit of the Atlantic is that the double-
exchange of ballast water can be a 'Very effective" method of preventing the introduction of non-
indigenous species. The SERC study performed a double-exchange of clean ballast water
containing a known number/concentration of microbials and found that 95% to 100% of the
microbials were removed.14 The SERC study noted that a "large number" of the microbials
would not have survived the transit even if the double exchange of ballast water had not been
performed. Therefore, the percentage reduction of the number or type of non-indigenous species
transported in the ballast water of Navy surface vessels achieved by double-exchange has not
been determined.

Although the presence of non-indigenous species has been verified by previous studies of
commercial vessels, exact densities of individual species introduced through deballasting
operations of vessels of the Armed Forces have not been evaluated.
5.0 CONCLUSION

Clean ballast discharges have a potential to cause an adverse environmental effect
because clean ballast water has the potential for transferring non-indigenous species between
ports.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information, equipment specifications, and research concerning non-indigenous species was
used. Table 3 shows the sources of data used to develop this NOD report.

Specific References

1. Weersing, Penny, Point Paper - Supplemental Information about Ballast Water - MSC
Ships. 31 October 1996.

2. Department of the Navy, Office of the Chief of Naval Operations. Summary Matrix of
OPNAVINST 5090.IB, Environmental and Natural Resources Program Manual, Chapter
19-10 (Ship Ballast Water and Anchor System Sediment Control Requirements). 1
November 1994.

3. Directive Order. COMLANTAREA COGARD, Portsmouth, VA to LANT CUTTER
FLT. Ballast Water Exchange Program, 14 August 1996.
Clean Ballast
7
-------
4. Directive Order. COMPACAREA COGARD, Alameda, CA. PACAREA Aquatic
Prevention Program, 12 November 1996.

5. Weersing, Penny, Attachment 4, Point Paper - Supplemental Information about Ballast
Water - MSC Ships. Summary Matrix of OPNAVINST 5090.1B. 31 October 1996.

6. UNDS Equipment Expert Meeting Minutes - Clean Ballast. 18 September 1996.

7. Letter from Commander Submarine Force, U. S. Atlantic Fleet to Commander, Naval Sea
Systems Command (GOT); SerN451 A/4270 dated 13 Dec 1996; COMSUBLANT
Response to UNDS Data Call; 688 Class and 726 Class Submarine Discharge Data
Package.

8. Ashland Chemical Company. Material Safety Data Sheets - Magnakote Rust
Preventative and Mud Conditioner. 8 February 1995 and 10 February 1995.

9. Mil. Spec. M3L-P-83461, "Packings, Preformed, Petroleum Hydraulic Fluid Resistant,
Improved Performance at 275°F (135°C)".

10. Mil. Spec. MEL-G-22050, "Gasket and Packing Material, Rubber for Use With".

11. Mil. Spec. MEL-P-24441, "Paint, Epoxy-Polyamide, General Specification For".

12. Mil. Spec. MIL-PRF-23236, "Paint Coating Systems, Fuel and Salt Water Ballast Tank".

13. Chesapeake Bay Commission. The Introduction of Nonindigenous Species to the
Chesapeake Bay Via Ballast Water - Strategies to Decrease the Risks of Future
Introductions through Ballast Water Management. 5 January 1995.

14. Ruiz, Greg. Non-Indigenous Species Presentation - Notes by Dan G. Mosher, Malcolm
Pirnie, Inc. 18 September 1996.

15. International Maritime Organization (IMO). Guidelines for Preventing the Introduction
of Unwanted Aquatic Organisms and Pathogens from Ships' Ballast Water and Sediment
Discharges, 10 May 1995

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for rntrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 3 07.2-3 07.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

National Research Council. Stemming the Tide, Controlling Introductions of Nonindigenous
Species by Ship's Ballast Water. National Academy Press, 1996.

Aivalotis, LT Joyce. UNDS Info, 18 February 1997, Doug Hamm, Malcolm Pirnie, Inc.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9CVN-CD-SIB-020, CVN
70 Vol. 2, Pt. 1, Bk 1, Chapter 11, Drainage and Ballasting Systems, Section 3, Sea Water
Ballasting System.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9LHA-AA-SJJB-020, LHA
1, Section 7-41, Ballast/Deballast System.
Clean Ballast
9
-------
Naval Sea Systems Command (NAVSEA). Ship Information Book, 0905LP-123-6010, LCC 19,
Section 2, Chapter 1, Fuel Oil Tank Stripping and Clean Ballast Systems.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9LHD-AA-SIB-060, LHD
1, Chapter 14, Ballast/Deballast System.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9LPD-AD-SIB-020, LPD
4, Vol. 2, Pt. 1, Table 7-2, Approximate Time to Ballast & Deballast Tanks.

Naval Sea Systems Command (NAVSEA). Ship Information Book, S9LSD-BH-SIB-100, LSD
41, Vol. 7, Ballasting/Deballasting.

Columbia/HCA Healthcare Corporation. Epidemic Cholera in the New World:
Translating Field Epidemiology into New Prevention Strategies. 2 October 1996.

Krotoff, Oleg, Ashland Chemical. Conversation with Oleg Krotoff, Env. Engineer, Ashland
Chemical, 13 May 1997, Doug Hamm, Malcolm Pirnie, Inc.

UNDS Equipment Expert Meeting Round Two - Clean Ballast. 15 April 1997.

Weersing, Penny, MSC. UNDS: Clean Ballast, 15 May 1997, Doug Hamm, Malcolm Pirnie, Inc.
UNDS Equipment Expert Meeting - Clean Ballast. 18 September 1996, M. Rosenblatt &
Son, Inc.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Clean Ballast
10
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-AIR MAIN
BELOW WTR LINE
BALLAST TANK
VENT VALVE
BELOW WTR LINE
BALLAST TANK
BLOW VALVE
HYDRAULIC
DIRECTIONAL
CONTROL VALVE
MANIFOLD
ABOVE WATER LINE
BALLAST TANK AIR ESCAPE
ABOVE WATER LINE
BALLAST TANK OVERFLOW
BELOW WATER LINE
' BALLAST TANK VENT
ABOVE WATER LINE
BALLAST TANK
RLL VALVE
ABOVE WATER LINE
BALLAST TANK
AIR ESCAPE/OVERFLOW
• FIREMAIN
V ABOVE WATER LINE
^-BALLAST TANK
ABOVE WATER LINE
•BALLAST TANK
DRAIN VALVE
BELOW WTR LINE
BALLAST TANK
SEA VALVE
ABOVE WATER LINE
BALLAST TANK
DRAIN
BELOW WATER LINE
BALLAST TANK
Figure 1. Typical Amphibious Ship Ballast and Deballast Tank Piping Composite
Clean Ballast
11
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Table 1. Summary of IMO, USCG, and Navy Exchange Policies for Clean Ballast Water
From Surface Vessels
NAVYZ
USCG'
IMO1
Requires potentially polluted ballast
water to be offloaded outside of 12
run. from shore and clean sea water
taken on and discharged twice prior
to entry within 12 n.m. from shore.

Requires entering records of ballast
water exchanges and their
geographical location in ship's
engineering log.
Requires potentially polluted ballast
water to be offloaded outside of 12
n.m. from shore and clean sea water
taken on and discharged twice prior
to entry within 12 n.m. form shore.

Requires entering records of ballast
water exchanges and their
geographical location in ship's
engineering log.
Recommends ballast water
exchange to take place in areas with
a depth of 2000 meters or more to
minimize the introduction of non-
indigenous invasive species.

Recommends record keeping of
ballast water exchange, sediment
removal, procedures used, and
appointment of responsible officer
on board ships to ensure procedures
are followed and records
maintained.
Table 2. Estimate of Total Ballast Capacity
Vessel Class
T-AO 187
T-AKR287
T-AG 194
WMEC270A&B
WLB225
WAGE 399
LHA1
CVN68
LCC19
LPD4
LSD 41
LHD1
AOE6
SSBN 726
SSN 688
LSV
LCU-2000

Service
MSC
MSC
MSC
USCG
USCG
USCG
Navy
Navy
Navy
Navy
Navy
Navy
Navy
Navy
Navy
Army
Army

Ballast Capacity (Gallons)
3,000,000
1,200,000
1,700,000
42,250
92,300
115,300
3,445,867
278,533
593,383
3,700,000
3,090,000
4,000,000
209,941
668,904
229,225
403,000
111,369

.#- Vessels :'.
12
8
1
13
2
2
5
7
2
8
8
4
3
17
56
6
35
Total:
Total Capacity (Gallons)
36,000,000
9,600,000
1,700,000
549,250
184,600
230,600
17,229,335
1,949,731
1,186,766
29,600,000
24,720,000
16,000,000
629,823
11,371,368
12,836,600
2,418,000
3,897,915
170,103,988
Estimate is based upon the largest vessels
ballast. Ballast volumes of vessels of the
of the Navy, USCG, MSC, and Army that use clean
Air Force are not included.
Clean Ballast
12
-------
Tables. Data Sources
X"
NOD Section
2.1 Equipment Description and
Operation ' '
23. Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality " /
3.2 Rate, ,
3.3^Constituejits
3.4 Concentrations
4. tMass Loadings'
4.2 Environmental Concentrations
43 Potential for Introducing Non-
Indigenous Species
Data Source - ,
Reported
X
X
UNDS Database

X
Sampling

Estimated

N/A
N/A
N/A

Equipment Expert
X
X
X
X
X
X

X
Clean Ballast
13
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NATURE OF DISCHARGE REPORT
Compensated Fuel Ballast
1.0 INTRODUCTION

This section describes compensated fuel ballast discharge and includes information on:
the equipment that is used and its operation (Section 2.1), general description of the constituents
of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Compensated ballast tanks are used for fuel storage and to maintain stability on some
classes of Navy vessels. As fuel is consumed while underway, water is taken in by the vessel to
maintain a nearly constant total fluid weight in the vessel. Compensated fuel ballast tanks are
maintained full of either fuel, seawater, or a combination of both. When both fuel and seawater
are present in the same tank, the fuel floats on top of the seawater because the fuel is less dense.
These tanks are only completely emptied of all fluid (seawater and fuel) during in-tank
maintenance or modification work that is not part of the ships' normal operation.

In vessels that use compensated fuel ballast systems, several compensated fuel ballast
tanks are connected in series to form a tank group. The first tank of the group is called the
"receiving tank." Fuel enters and exits the tank group via the receiving tank. The last tank of the
group is called the "overflow/expansion tank." Seawater enters and exits the tank group via the
overflow/expansion tank from the ship's firemain. Compensating water is introduced into the
overboard discharge pipe of the overflow/expansion tank through a level control valve. This
valve maintains a constant pressure within the compensated fuel tanks. The compensated
ballast/fuel storage tanks are hi between the receiving and the overflow/expansion tanks. All the
tanks in the group are connected by sluice pipes. Each tank in the group has an upper and lower
sluice pipe. The lower sluice pipe in the first tank of the group is connected to the upper sluice
pipe of the next tank in the series. The upper sluice pipe in the receiving tank connects to the
ship's fill and transfer fuel piping and allows fuel to enter and leave the tank group. The lower
sluice pipe of the overflow/expansion tank allows seawater to enter and leave the tank group.
Figure 1 shows a schematic diagram of the tank group interconnection pipes.

Each Navy surface vessel using a compensated fuel ballast system has six tank groups in
adjacent tank group pah's; two tank groups forward, two tank groups midship, and two tank
groups aft. Figure 2 shows the general layout of the six tank groups. For each adjacent tank
group pair, there is one port tank group and one starboard tank group. Each tank group consists
of three to six tanks connected hi a series: a receiving tank, one to four storage tanks, and an
overflow/expansion tank. The overboard discharge from each adjacent port and starboard tank
group are cross-connected resulting in a port-starboard pair of overboard discharges forward,
midship, and aft. Figure 3 illustrates a typical fuel oil tank layout for pair of port and starboard
tank groups with cross-connected overflow piping on a surface vessel.

During a fueling operation, fuel enters the receiving tank via the inlet sluice pipe and
pushes seawater through the rest of the tanks in the group via the sluice pipes. By simple
displacement, an equal amount of seawater is discharged overboard from the overflow/expansion
tank. Each tank in the group fills hi sequence since fuel cannot get into the next tank in the series

Compensated Fuel Ballast
2
-------
until the fuel level reaches the lower sluice pipe of the tank being filled. When the fuel level
reaches the lower sluice pipe in a tank the fuel starts to flow into the next tank in the series via
the sluice pipe. Operating procedures dictate that the fueling process be stopped prior to fuel
entering the overflow/expansion tank.1 The overflow/expansion tank is intended to hold only
seawater, acting as a buffer between the fuel storage tanks and the overboard discharge. This
tank is used to prevent the accidental discharge of fuel overboard due to overfilling of the tank
group, or due to the thermal expansion of the fuel when ambient temperatures increase.

Fuel is transferred via purifiers to uncompensated fuel service tanks prior to use by ship's
propulsion and electrical generating plants. Only fuel from the service tanks is used to power the
ship's propulsion and electrical generating plants, fuel is not taken directly from the compensated
fuel ballast tanks to the engines. Therefore, compensating water is not taken on when the ship's
engines are operating in port..

Non-conventional submarines have a compensated fuel ballast system to provide fuel for
the emergency diesel generator. This compensated fuel ballast system consists of a Normal Fuel
Oil (NFO) tank and a seawater expansion tank. Compensating water is not discharged to the
surrounding water under any normal operating condition. When fueling, the displaced seawater
is removed from the NFO tank via the seawater compensating line and is transferred via a hose
connection to a port collection facility for treatment and disposal.2 While operating at sea,
compensating seawater is not discharged from the NFO tank because an air charge in the
expansion tank compresses to account for volumetric changes due to hull compression during
changes in ship depth or as a result of tank liquid temperature changes.

Mixing of the fuel into seawater discharged from the overflow/expansion tank is believed
to occur via the following mechanisms:

• Fuel and water can be mixed by turbulence in the tank during rapid introduction of
fuel or water, or the rolling motion of the ship. The turbulence is caused by fluid flow
around internal tank structure and by interfacial shear between the fuel and the water
layers.

• Internal tank structure can cause incorrect fuel level readings and inadvertent
discharge of fuel with the compensated ballast water by trapping pockets of fuel and
seawater.
• Soluble fuel constituents can be dissolved in seawater.

Some of the design and operational practices used by the Navy to mitigate fuel discharges
from compensating ballast systems include:

• Engineering Operating Sequencing Systems (BOSS) fuel filling procedure "Standard
Refueling, Fuel Oil" (SRFO) and the Class Advisories (temporary operating
instructions and notices) for destroyers and conventional cruisers recommend that fuel
storage tanks be refueled to no greater than 85 percent of capacity in port.1"4 This

Compensated Fuel Ballast
3
-------
prevents the fuel/seawater interface from entering the overflow/expansion tank and
overboard discharge pipe.

BOSS fuel rilling procedure SRFO and the Class Advisories for the same vessels
direct that the in-port flow limiting valves hi the supply to each tank group be closed
during in-port refueling only (open while refueling at sea). The flow limiting valves
restrict the fill rate to each tank group to approximately 400 gallons per minute (gpm)
versus 1000 gpm while at sea. This reduces fuel/seawater mixing in the tank.
1-4
• BOSS fuel filling procedure SRFO requires individuals to stand watch to halt
refueling in the event of overboard spills, while others are required to monitor fuel
levels in each tank during the refueling operation.1

2.2 Releases to the Environment

As discussed in Section 2.1 compensated ballast discharge occurs through the
overflow/expansion tank during refueling operations. Compensated ballast discharge consists
primarily of seawater containing some fuel constituents. Leaching and corrosion of fuel
containment systems are expected to result in the presence of metals.

2.3 Vessels Producing the Discharge

The Navy is the only branch of the Armed Forces whose vessels utilize compensated fuel
ballast systems. Compensated fuel ballast systems are used only on CG 47 Class cruisers; DD
963 Class, DDG 993 Class, and DDG 51 Class destroyers; and all non-conventional submarine
classes.2 A total of 75 U.S. based surface vessels generate this discharge. Submarine
compensated fuel ballast systems do not discharge to the surrounding water whether in port or at
sea. USCG, MSC, Army, Air Force, and Marine Corps vessels do not utilize compensated fuel
ballast systems and do not generate this discharge.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

In-port refueling of surface ships is the only circumstance during which compensated
ballast discharge occurs within 12 nautical miles (n.m.). At-sea refueling operations take place
outside of 12 n.m. based on standard operating practice.

3.2 Rate
Compensated Fuel Ballast
4
-------
During in-port refuelings of surface vessels, compensated ballast is discharged at a rate of
up to 400 gpm per tank group (2,400 gpm maximum per ship). Based on actual refueling data
obtained from Navy personnel, each ship takes on about 200,000 gallons per refueling in port and
the refuelings occur on average two times per year per ship.5

3.3 Constituents

The Navy has conducted several studies of compensated ballast in the past. These
included:

• in-port refueling test of the USS Nicholson (DD 982);6
• at-sea refueling testing of the USS Spruance (DD 963);7
• in-port and at-sea testing of the USS John Hancock (DD 981 );8 and
• in-port testing of the USS Arleigh Burke (DDG 51).9'10

These previous studies have typically measured the oil concentration of the discharge.
On the DDG 51, in-line oil content monitors were used in conjunction with standard laboratory
analyses to determine the oil concentration in the discharged ballast water. Table 1 summarizes
the data for oil concentration in compensated ballast water from the previous Navy studies. The
concentration of oil in water varied from below detection levels to 370 milligrams per liter
(mg/L).

To further support this NOD report, a sampling effort was conducted. Five samples of
compensated ballast discharge, and an additional quality assurance/quality control sample, were
taken through the course of an in-port refueling operation from the discharge of a single midship
tank group of the USS Arleigh Burke, (DDG 51) on January 27,1997.11 Based on previous Navy
operational and design experience, midship tank groups on DDG 51 Class vessels are expected to
contain the greatest concentration of fuel oil constituents in the ballast water. The samples were
analyzed for volatile and semivolatile organics, selected classical pollutants, metals, and mercury
using EPA series 1600 protocols. Table 2 presents a summary of the validated analytical data
for all detected analytes from the sampling effort that occurred on January 27,1997. The
following priority pollutants were present in measurable amounts: copper, nickel, silver,
thallium, zinc, benzene, phenol, and toluene;12 the only bioaccumulator found was mercury.13
Also, during the UNDS sampling effort, 8 additional samples were taken and analyzed for TPH
by the modified 418-2 method, with results ranging from 11.9 to 108.2 mg/L.14

3.4 Concentrations

As mentioned in Section 3.3, Table 2 presents the validated analytical data from the
UNDS sampling effort. The table includes metals, volatile organics, semivolatile organics,
classicals, and mercury. The table shows the constituents, the log-normal mean, the frequency of
detection for each constituent, the minimum and maximum concentrations, and the mass
loadings of each constituent. For the purposes of calculating the log-normal mean, a value of
one-half the detection limit was used for non-detected results.
Compensated Fuel Ballast
5
-------
In addition to the oil concentration data collected in previous sampling as described in
Table 1, two separate sets of analyses were developed from the UNDS sampling effort to support
this NOD report. The samples were analyzed for Hexane Extractable Materials (HEM) and
Silica Gel Treated (SGT) -HEM. The HEM values correspond to oil and grease and the SGT-
HEM values correspond to total petroleum hydrocarbon (TPH) which is a subset of oil and
grease. The results varied from 8 to 36.5 mg/L for HEM and from 6 to 12.5 mg/L for SGT-
HEM.11
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Based on ship transit data, Navy surface ships with compensated ballast systems are at
their homeport (within 12 n.m.) between 101 and 178 days per year, and at sea for the balance of
the year.15 A per-ship total annual discharge of 400,000 gallons per year was calculated based
upon the following averages obtained from Navy refueling data:

• 200,000 gallons median discharge per in port refueling; and
• 2 refuelings in port per year.

As mentioned in Section 2.3, 75 surface vessels are homeported in the U.S. and generate
compensated ballast within 12 n.m. of the U.S.16 The majority of these ships' in-port refuelings
occur at their homeport. Flow per ship class can be roughly approximated as the product of the
number of vessels in a class and 400,000 gallons discharged per ship per year as presented in
Table 3. The 75 U.S. based surface vessels discharge 30.0 million gallons within the 12 n.m.
zone.

Total mass loading, for in-port discharges, was estimated by multiplying the log-normal
mean concentration by the total compensated ballast discharge volume of 30.0 million gallons
per year. The generalized equation is shown below:
Mass Loading (Ibs/yr) = ?
(Concentration fcg/L))(Vofcme (gal/yr))(3.785 L/gal)(2.2 lbs/kg)(lQ-9kg/Mg)
Based on the SGT-HEM log-normal mean concentration of 4.65 mg/L the TPH loading
could be 1,160 pounds per year (Ibs/yr). Based on the HEM log-normal mean concentration of
12.73 mg/L, the total estimated oil & grease loading from in-port discharges could be expected to

Compensated Fuel Ballast
6
-------
be 3,180 Ibs/yr.

Using the metal log-normal mean concentrations as listed in Table 2; the mass loadings
are estimated to be 13.3 Ibs/yr for copper; 47.4 Ibs/yr for nickel; 2 Ibs/yr for thallium; 1,063
Ibs/yr for zinc; 0.77 Ibs/yr for silver; and 0.00015 Ibs/yr for mercury. Using the organic log-
normal concentration in Table 2, the mass loading was estimated to be 10.3 Ibs/yr for 2-Propenal;
and 22 Ibs/yr for benzene. Using the log-normal concentration in Table 2, the mass loading was
estimated to be 65 Ibs/yr for ammonia, 97 Ibs/yr for nitrogen, and 15 Ibs/yr for phosphorous.
These mass loadings are summarized in Table 4. The ratio of the number of vessels in each U.S.
homeport to the total of 75 compensated ballast vessels allows the loadings to be proportioned as
shown in Table 5.

4.2 Environmental Concentrations

Screening for acute toxicity was accomplished by comparing the log-normal mean
resulting from the UNDS sampling to Federal or the most stringent state water quality criteria for
these constituents. These data are provided in Table 6. Individual sample concentrations exceed
Florida criteria for oil, as indicated by SGT-HEM, but the log-normal mean does not; however,
this discharge has demonstrated that potential for causing a sheen when procedural controls are
not used.6'8 Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge
sufficient to cause a sheen on receiving waters. The Federal discharge standard is 15 mg/L based
on International Convention for the Prevention of Pollution from Ships (MARPOL 73/78).
MARPOL 73/78 as implemented by the Act to Prevent Pollution from Ships (APPS).

The log-normal mean concentrations for copper, nickel, silver, and zinc samples exceed
both Federal and most stringent state water quality criteria (WQC). The most stringent state
criteria are exceeded by the log-normal mean concentration for 2-Propenal, ammonia, benzene,
HEM, total nitrogen, phosphorous, and thallium. Mercury, a persistent bioaccumulator, was
present in three of the four samples, although it did not exceed WQC.

4.3 Potential for Introducing Non-Indigenous Species

Water taken into the fuel tanks during refueling could contain non-indigenous species,
but it is unlikely that the organisms will be transferred between ports for the following reasons:

1) Water is not taken into the compensated fuel ballast tanks during refueling operations -
water is only discharged during this operation. Water is only taken into the compensated
fuel ballast tanks during fuel transfer operations (either between compensated fuel ballast
tank groups or from a compensated fuel ballast tank to a fuel service tank). Water could
be taken into the compensated fuel ballast tanks prior to a refueling operation because
ship's personnel are trying to maximize the fuel storage on board by transferring fuel
from the compensated ballast tanks to top off the fuel service tanks. This process is
normally done at-sea prior to entering to a port facility. This process also prevents silt
and debris from shallow harbors from being introduced into the tanks.
Compensated Fuel Ballast
7
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2) If the ship has been generating its own electrical power for an extended period while
in-port then the fuel transfer may take place in the harbor prior to the refueling in order to
maximize the fuel stored on-board the vessel. However, the refueling that takes place
immediately after the fuel transfer will discharge the compensating water back into the
same harbor.

3) Compensating water from the fuel storage tanks is frequently flushed while the ship is
at sea due to frequent refuelings. Navy surface ships with compensated ballast systems
normally refuel every three to four days while out at sea to prevent fuel levels from
dropping below 70% capacity. Based on ship transit data, these ships are at sea between
187 and 264 days per year.11 Using the minimum number of days at sea (187), and
assuming that the ship is refueled at-sea every 4 days, results in an estimate of
approximately 46 at-sea refuelings per year compared to two in-port refuelings per year.
Therefore, there is little chance for compensating water that may have been taken on in
one port to be discharged in another port
5.0 CONCLUSIONS

Uncontrolled, compensated ballast discharge has the potential to cause an adverse
environmental effect because significant amounts of oil are discharged during a short duration at
concentrations that exceed discharge standards and water quality criteria. This discharge has
been reported to cause an oil sheen when procedural controls are not applied.6'8
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge. Based on this estimate
and on the reported concentrations of the constituents, the concentrations of the constituents in
the environment resulting from this discharge were compared with relevant water quality criteria.
Table 7 shows the sources of data used to develop this NOD report.

Specific References

1. Naval Sea Systems Command, Engineering Operating Sequencing System (BOSS),
Operational Procedure Fuel Oil Refueling, Code SRFO/0319/032596.

2. UNDS Equipment Expert Meeting Minutes - Compensated Fuel Ballast. July 24,1996.

3. Naval Sea Systems Command, DD 963 - DDG 993 Class Advisory NR 04-94, Inport
Refueling / Operational Procedures, 2 May 1994.

4. Naval Sea Systems Command, DDG 51 Class Advisory NR 22-95, Fuel Tank Level
Indicator Alignment Procedures, 21 December 1995.

Compensated Fuel Ballast
8
-------
5. Report of Travel, Compensated Fuel Ballast System NCCOSC-NRaD, San Diego, 12
March 1997.

6. Oil Concentrations in Ballast Water During In-Port Refueling of USS Nicholson (DD
982). DTNSRDC Report TM-28-81-145 (December 1981).

7. Oil Concentrations in Ballast Water During At-Sea Refueling of USS Nicholson (DD
982). DTNSRDC Report TM-28-82-158 (December 1982).

8. Evaluation of DD-963 Class Fuel/Ballast Expansion Tank Modifications Aboard USS
JOHN HANCOCK (DD 981). DTNSRDC Report TM-28-83-171 (May 1984).

9. SEA 05Y32 Preliminary Trip Report/Test Brief. DDG 51 In-Port Refueling Test, August
12-14,1992.

10. SEA 05Y32 DDG 51 Post-PSA In-Port Fueling Test. August 4,1992.

11. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

12. Committee Print Number 95-30 of the Committee on Public Works and Transportation of
the House of Representatives, Table 1.

13. The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23, 1995.

14. Compensated Ballast Sample Analysis Results from DDG 51 In-port Refueling, 27
January 97, Commanding Officer, Naval Surface Warfare Center, Carderock Division,
Philadelphia Site, Philadelphia, PA, letter 9593, Ser 631/63 of 14 February 1997.

15. UNDS Ship Database, August 1,1997.

16. The United States Navy, List of Homeports, Homeports and the Ships Assigned,
Effective May 22,1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for rntrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAG).
Compensated Fuel Ballast
10
-------
KQ
Figure 1. Fuel Tank Group 3 and 4 (Typical) Compensated Seawater Ballast
Compensated Fuel Ballast
11
-------
Figure 2. Compensated Fuel Ballast Tank Layout
Compensated Fuel Ballast
12
-------
JWBH1K1HIR //
iM.amH.VAi.VE / I

/ I— OVOTOARD DISCHARGE
naming
DPWISION vm.
Figure 3. Typical Port and Starboard Tank Groups with Cross-connected Overflow
Compensated Fuel Ballast
13
-------
Table 1. Oil Concentrations in Compensated Ballast Waters (mg/L)
Previous Navy Studies
USS Nicholson
DD 9826
(in-port)
2 to 149
USS Spruance
DD 9637
(at-sea)
<60
USS John Hancock
DD 98I8
(in-port)
<1 to 370
USSArleighBuike
DDG5110'11
(in-port)
0.0 to 10.35 (lab)
mg/L - milligrams of oil per liter of fluid
(lab) - laboratory analysis results for physical samples taken during testing
Compensated Fuel Ballast
14
-------
Table 2. Summary of Detected Analytes for Compensated Ballast Discharge
Constituent ;
'' ' „
Log Normal
Mean
Frequency of
, Detection s
" Minimum
Concentration
Maximum
Concentration
Mass Loading'
- (Ibs/yr)
Classicals (mg/L)
ALKALINITY
AMMONIA AS NITROGEN
BIOCHEMICAL OXYGEN
DEMAND
CHEMICAL OXYGEN DEMAND
(COD)
CHLORIDE
HEXANE EXTRACTABLE
MATERIAL
SGT-HEM
SULFATE
TOTAL DISSOLVED SOLIDS
TOTAL KJELDAHL NITROGEN
TOTAL ORGANIC CARBON
(TOC)
TOTAL PHOSPHOROUS
TOTAL SULFIDE (IODOMETRIC)
TOTAL SUSPENDED SOLIDS
VOLATILE RESIDUE
46.72
0.26
6.82
429.25
16042.18
12.73
4.65
2005.74
27760.50
0.39
28.98
0.06
3.94
9.62
2506.27
4 of 4
4 of 4
Iof4
4 of 4
4 of 4
4 of 4
2 of 4
4 of 4
4 of 4
4 of 4
4 of 4
3 of 4
4 of 4
4 of 4
4 of 4
45
0.19
BDL
380
15400
8
BDL
1900
27000
0.28
21
BDL
3
4
1910
49
0.3
12
490
16800
36.5
12.5
2120
29300
0.58
40
0.34
5
18
3160
11,671
65
1,704
107,231
4,007,497
3,180
1,162
501,054
6,934,851
97
7,239
15
984
2,403
626,091
Hydrazine (mg/L)
HYDRAZINE 0.08 4 of 4 0.0705 0.089 20
Mercury (ng/L)
MERCURY
0.60 | 3 of 4
BDL
0.835
0.0001
Metals (|ig/L)
ALUMINUM Dissolved
Total
BARIUM Dissolved
Total
BORON Dissolved
Total
CALCIUM Dissolved
Total
COPPER Total
IRON Dissolved
Total
MAGNESIUM Dissolved
Total
MANGANESE Dissolved
Total
NICKEL Dissolved
Total
SILVER Dissolved
SODIUM Dissolved
Total
52.03
37.00
11.44
11.24
3098.77
3060.48
256841.05
291451.71
53.37
99.76
130.50
907229.15
938389.79
12.13
12.13
184.65
189.72
3.07
8225693.86
8039337.04
2 of 4
Iof4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
Iof4
4 of 4
4 of 4
BDL
BDL
10.35
10.25
2990
2990
203000
286000
43.7
37.45
74.95
881000
907000
11.15
10.7
137
144
BDL
8040000
7740000
120
135.5
12
11.8
3220
3175
292000
299000
86
159
202
923500
1024500
13.7
13.7
263.5
267.5
5.68
8450000
8550000
13
9
3
3
774
765
64,161
72,808
13
25
33
226,635
234,419
3
3
46
47
1
2,054,861
2,008,307
Compensated Fuel Ballast
15
-------
THALLIUM Dissolved
Total
ZINC Dissolved
Total
5.61
7.40
1220.18
4256.14
Iof4
Iof4
4 of 4
4 of 4
BDL
BDL
173
3840
10.8
24
4330
4845
1
2
305
1,063
Organics (ug/L)
2,3-DICHLOROANILINE
2,4-DIMETHYLPHENOL
2-METHYLBENZOTfflOAZOLE
2-METHYLNAPHTHALENE
2-PROPANONE
2-PROPENAL
4-CHLORO-2-NITROAMLINE
ACETOPHENONE
ANILINE
BENZENE
BENZOICACID
BENZYL ALCOHOL
BIPHENYL
ETHYLBENZENE
HEXANOICACID
ISOSAFROLE
LONGIFOLENE
M-XYLENE
N-DECANE
N-DOCOSANE
N-DODECANE
N-EICOSANE
N-HEXADECANE
N-OCTADECANE
N-TETRADECANE
NAPHTHALENE
CH-PXYLENE
0-CRESOL
O-TOLUTDINE
P-CRESOL
P-CYMENE
PHENOL
TfflOACETAMBDE
TOLUENE
TOLUENE.2A-DIAMINO-
6.09
312.10
8.07
61.34
41.18
42.20
12.04
21.99
6.58
89.99
75.62
12.16
9.76
38.59
16.93
6.69
54.02
58.13
7.28
7.11
10.01
20.35
39.36
24.98
21.19
19.54
100.66
181.10
40.24
110.73
5.53
69.70
19.75
164.46
72.44
Iof4
4 of 4
Iof4
4 of 4
2 of 4
Iof4
Iof4
4 of 4
Iof4
4 of 4
3 of 4
3 of 4
4 of 4
4 of 4
4 of 4
Iof4
Iof4
4 of 4
Iof4
Iof4
2 of 4
4 of 4
4 of 4
4 of 4
4 of 4
3 of 4
4 of 4
4 of 4
4 of 4
4 of 4
Iof4
4 of 4
Iof4
4 of 4
Iof4
BDL
180
BDL
58
BDL
BDL
BDL
21
BDL
31
BDL
BDL
7.5
20.5
7.5
BDL
BDL
41.5
BDL
BDL
BDL
14
26
16
14
BDL
71
84.5
8
46.5
BDL
59
BDL
63.5
BDL
11
430
34
63
73
203
21
23
15
153
146
24
11
59
28
16
545
73
22.5
20.5
36.5
51
99.5
64
60
47
127
296
95
192
10
83
152
269
227
2
78
2
15
10
11
3
5
2
22
19
3
2
10
4
2
13
15
2
2
3
5
10
6
5
5
25
45
10
28
1
17
5
41
18
Log normal means were calculated using measured analyte concentrations. When a sample set contained one or
more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations
equivalent to one-half of the detection levels were used to calculate the mean. For example, if a "non-detect" sample
was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used hi the log normal mean
calculation.
Compensated Fuel Ballast
16
-------
Table 3. Estimated Total U.S. In-port Discharge of Compensated Ballast
(millions of gallons/year Fleetwide)
Ship Class
CG47
DD963
DD993
DDG51
, Number of Ships
25
28
4
18
Total In-port Discharge
10.0
11.2
1.6
7.2
Table 4. Estimated Annual Mass Loadings of Constituents
Constituent ,
* ; • •"'
Log Normal
Mean ~'"
Frequency of
:" Detection
Minimum
Concentration
Maximum
Concentration
Mass Loading
(Ibs/yr) „
Classicals (mg/L)
Anmionia As
Nitrogen
Hexane
Extractable
Material
Nitrate/
Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen3
Total
Phosphorous
0.26
12.73
-
0.39
0.39
0.06
4 of 4
4 of 4
-
4 of 4
4 of 4
3 of 4
0:19
8
-
0.28
0.28
BDL
0.3
36.5
-
0.58
0.58
0.34
65
3,180
-
97
97
15
Mercury (ng/L)
Mercury*
0.6
3 of 4
BDL
0.835
0.00015
Metals (ug/L)
Copper Total
Nickel Dissolved
Total
Silver Dissolved
Thallium Total
Zinc Dissolved
Total
53.37
184.65
189.72
3.07
7.40
1220.18
4256.14
4 of 4
4 of 4
4 of 4
Iof4
Iof4
4 of 4
4 of 4
43.7
137
144
BDL
BDL
173
3840
86
263.5
267.5
5.68
24
4330
4845
13
46
47
0.77
2
305
1,063 ...
Organics (ug/L)
2-Propenal
Benzene
42.2
89.99
Iof4
4 of 4
BDL
31
203
153
10
22
* - Mercury was not found in excess of WQC; mass loading is shown only because it is a bioaccumulator.
A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Compensated Fuel Ballast
17
-------
Table 5. Estimated Mass Loadings by Homeport (Ibs/yr)

Ships

HEM
SGT-HEM
Copper
Nickel
Zinc
Thallium
Silver
2-Propenal
Ammonia
Benzene
Nitrogen
Phosphorous
Total
75
Everett
4
Mayport
13
Norfolk
27
Pascagoula
2
Pearl Harbor
10
San Diego
19
LoadittR-'RaiiSfcs-''- v"*' •''';. .•-V"";.o^v ...•• ; ' - ."••
3180
1160
13.3
47.4
1063
2
0.77
10.3
65
22
97
15
170
62
0.7
2.5
56.7
0.11
0.04
0.55
3.5
1.2
1.7
0.8
551
201
2.3
8.25
184.25
0.35
0.135
1.8
11.3
3.8
17
2.6
1145
417
4.75
17.1
382.7
0.72
0.285
3.7
23.4
7.9
35
5.4
85
31
0.35
1.25
28.35
0.05
0.02
0.28
1.75
0.6
0.84
0.4
424
155
1.8
6.3
141.7
0.27
0.1
1.4
8.7
2.9
13
2.0
805
294
3.4
12
269.3
0.51
0.19
2.6
16.5
5.6
25
3.8
Compensated Fuel Ballast
18
-------
Table 6. Mean Concentrations of Constituents Exceeding Water Quality Criteria
Constituent „- \,
Log Normal
Mean

Ammonia As
Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen8
Hexane Extractable
Material
Total Phosphorous
0.26
-
0.39
0.39
12.73
0.06
Minimum
Concentration
Maximum
Concentration
FederaLAcute
, WQC
Most Stringent
State Acute WQC
Classicals (mg/L)
0.19
-
0.28
0.28
8
BDL
0.3
-
0.58
0.58
36.5
0.34
None

None
None
visible sheen3/
15b
None
0.006 (HI)A

-
0.2 (HI)A
5(FL)
0.025 (HI)A
Mercury (ng/L)
Mercury*
0.6
BDL
0.835
1800 25 (FL, GA)
Metals (ng/L)
Copper Total
Nickel Dissolved
Total
Silver Dissolved
Thallium Total
Zinc Dissolved
Total
53.37
184.65
189.72
3.07
7.40
1220
4256
43.7'
137
144
BDL
BDL
173
3840
Organics (u
2-Propenal
Benzene
42.2
89.99
BDL
31
86
263.5
267.5
5.68
24
4330
4845
2.9
74
74.6
1.9
None
90
95.1
2.5 (WA)
74 (CA, CT)
8.3 (FL, GA)
1.9 (CA, MS)
6.3 (FL)
90 (CA, CT, MS)
84.6 (WA)
g/L)
203
153
None
None
18 (HI)
71.28 (FL)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
* - Mercury was not found in excess of WQC; concentration is shown only because it is a bioaccumulator.

CA = California
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington

a Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen
on receiving waters.
b International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as
implemented by the Act to Prevent Pollution from Ships (APPS)
Compensated Fuel Ballast
19
-------
Table 7. Data Sources

NOD Section
2.1 Equipment Description and
Operation
22. Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
Data Source • ;- v>;v • •:•••/-:.•: -.--••-•
Reported
Data call responses
Data call responses
UNDS Database
Data call responses
Data call responses
Data call responses
Data call responses

Sampling

X
X

Estimated

Equipment Expert
X
X
X
X

X
X

X
Compensated Fuel Ballast
20
-------
NATURE OF DISCHARGE REPORT
Controllable Pitch Propeller Hydraulic Oil
1.0 INTRODUCTION

A nature of discharge (NOD) report has been prepared for each of the discharges that has
been identified as candidates for regulation under UNDS. The NOD reports were developed
based on information obtained from the technical community within the Navy and other branches
of the Armed Forces with vessels potentially subject to UNDS, from information available in
existing technical reports and documentation, and, when required, from data obtained from
discharge samples that were collected under the UNDS program.

This section describes the controllable pitch propeller (CPP) hydraulic oil discharge and
includes information on: the equipment that is used and its operation (Section 2.1), general
description of the constituents of the discharge (Section 2.2), and the vessels that produce this
discharge (Section 2.3).

2.1 Equipment Description and Operation

CPPs are used to control vessel speed and direction without changing the speed or
direction of the vessel's main propulsion plant shafting. With CPPs, the angle of the propeller
blades (pitch) is variable, which affects the "bite" that the blade has on the water. This allows
the amount of water displaced in the forward or reverse directions to be varied, which changes
the forward and reverse speed of the vessel.

The pitch of the CPP blades is controlled hydraulically through a system consisting of a
pump, piston, crosshead, and blade crank rings. The piston, crosshead, and crank rings are
located in the propeller hub. High pressure hydraulic oil, acting on either side of the piston,
moves the piston axially within the propeller hub. The piston is attached to a piston rod that
connects to the crosshead that moves axially with the piston. Sliding blocks fit in machined slots
on the crosshead and these sliding blocks fit over eccentrically-located pins mounted on the crank
pin rings. As the crosshead moves forward and backwards within the hub, the sliding blocks
move in an arc that also moves the eccentric pin and rotates the crank pin rings to which the CPP
blades are bolted.1

High-pressure hydraulic control oil is provided to each propeller by a hydraulic oil
pressure module (HOPM). While operating, the HOPM supplies oil pressure at 400 pounds per
square inch (psi) to control the CPP. While a vessel is pierside, the HOPM is idle and the
pressure to the CPP consists of approximately 6 to 8 psi provided by 16 to 21 feet of hydraulic
head, depending on the vessel class, from a 40- to 65-gallon reservoir that supplies head to a
larger sump tank (600 to 800 gallons) for the CPP system. Several rubber O-ring seals, along
with the finely machined surfaces of the blade port cover, the bearing ring, and the crank pin
ring, keep the hydraulic oil inside the CPP hub and away from the water.

Figures 1 through 3 show cross sections and a top view of a CPP. Figure 4 is a block
diagram of a CPP system.

2.2 Releases to the Environment

The hydraulic oil can be released under three conditions from a CPP and CPP
maintenance tools: leaks past CPP seals; releases during underwater CPP repair and
maintenance activities; and release of power head tool hydraulic oil during CPP blade
replacement. Small quantities of oil can leak past the CPP seals if they are old, worn, or
defective.
Controllable Pitch Propeller Hydraulic Oil
2
-------
Oil can also be released to the environment during the underwater maintenance of CPP
propeller blades or seals.2 Underwater maintenance is performed to: 1) replace seals or center
blade post sleeves; or 2) replace one or more propeller blades. The procedures for performing
underwater replacements are detailed in reference (2). The detailed information in the following
subsections applies to Navy vessels. Data on Military Sealift Command (MSC) underwater
replacements are unavailable, and the U.S. Coast Guard (USCG) performs replacements only in
dry dock.3'4

Blade Port Cover Removal. Approximately five to seven of the estimated thirty
underwater replacements per year fleetwide are to remove blade port covers for maintenance and
can cause some hydraulic oil to be released from the CPP hub.5 The CPP hub seals or center post
sleeve are replaced when observations or inspections indicate failure or cracking.6 To change
hub seals or the center post sleeve, the CPP blade is removed to access the blade port cover,
which, in turn, must be removed to access the seals and center post sleeve. The underwater
husbandry manual for the underwater change outs also references "NAVSEA Best Management
Practices (BMPs) to Prevent/Mitigate Oil Spills Related to Waterborne Removal(s) of Blades on
Variable Pitch Propellers for Naval Vessels." This BMP is described in Section 3.2.2.

CPP Blade Replacement. CPP blade replacement normally occurs after a casualty that
causes blade damage (e.g., running aground, hitting a submerged object). During blade
replacements, a CPP blade is unbolted from the blade port cover and replaced (see Figure 1).
Removing a CPP blade does not, in itself, cause hydraulic oil to be released from the CPP hub
assembly (other than that released by the bleeding procedure described above). Seals, bearings,
and sleeves are still in place to prevent any oil from being released.

During CPP blade replacement, the blade is rotated to the 12 o'clock position to remove
the Morgrip bolts that secure the blade to the CPP hub.6 The Morgrip bolts are removed with a
hydraulic power head tool. Before the power head tool is used, it is bled of air underwater while
attached to the Morgrip bolt by allowing oil to flow from a port until a "steady stream of
hydraulic fluid (no air) bleeds from the loosened port opposite the HP tube in the power head."6

2.3 Vessels Producing the Discharge

The Navy, MSC and USCG operate vessels equipped with CPPs. The Army and Air
Force do not operate any vessels equipped with CPPs. Table 1 lists the vessels that have CPPs
and the number of shafts (i.e., number of CPPs, per vessel).
3.0 DISCHARGE CHARACTERISTICS

Leaks of hydraulic oil past seals can occur at sea or within 12 n.m. of shore. Discharge
underway is more likely than while pierside or at anchor because the CPP system is operating
under a higher pressure.

Hydraulic oil can be discharged within 12 n.m. of shore during CPP repairs. The
replacements are performed in port and are conducted on an as-needed basis when dry-docking is
not scheduled for a vessel or is impractical.

3.2 Rate

The rate of oil release from CPPs will vary with the activity performed on the CPP. The
leakage rate from CPP seals is expected to be negligible while the release of oil from CPP blade
replacement will be larger. The release of oil from the underwater replacement of CPP seals will
generate more oil than the underwater replacement of CPP blades only. The following
paragraphs provide further information related to the anticipated release rates from CPPs.

3.2.1 Leaks From CPP Seals

The systems that monitor hydraulic oil loss can detect catastrophic failures on the order of
5 to 250 gallons over 12 hours, but not small leaks. The internal pressure in the CPP hub is
approximately 6 to 8 psi, depending on the vessel class, when the HOPM is not operating (e.g.,
while a vessel is pierside). The external pressure from the seawater is approximately 5.8 to 8 psi
provided by 13 to 18 feet of seawater, depending on the vessel class. Therefore, the pressure
differential between the hydraulic oil in the CPP and the seawater is low (e.g., 1 psi or less) and
provides little driving force to force oil from the CPP hub. Leakage rates under these conditions
constitute seal failures requiring repairs/replacement considering that CPP hubs are designed to
operate at 400 psi without leakage. CPPs are pressure tested at 400 psi prior to ship delivery and
during dry dock maintenance. The CPPs are inspected quarterly for damage and signs of failure
or excessive wear.7 CPP seals are designed to last five to seven years and are reported to last
their projected life.7'8 Most Navy vessels equipped with CPPs have dry-dock cycles of
approximately five years and MSC vessels have dry-dock cycles of two to three years.3'9'10
During the dry dock cycle, the CPP is removed and shipped back to the manufacturer for
inspection and maintenance, which includes replacement of the CPP seals. Based on the above
information, the release rate of hydraulic oil from CPPs under normal operating conditions is
expected to be negligible.

3.2.2 Underwater Replacements

Approximately thirty underwater CPP blade replacements occur per year, and five to
seven of these include blade port cover removal to access the seal or center post sleeve for
replacement.5

CPP Blade Port Cover Removal. According to Reference No. 2, as much as five
Controllable Pitch Propeller Hydraulic Oil
4
-------
gallons of oil could be present in CPP hub cavities.2 It is unlikely that all of this oil is released
during a seal replacement because the hub cavity opening is required to be oriented to the 6
o'clock position; the hydraulic oil is buoyant and floats within the hub cavity, effectively
trapping the oil.6

Oil (0 to 5 gallons) could be released when oil is supplied to the assembly to displace
water before replacing the blade port cover.6 After the seals or the center post sleeve are
replaced, head pressure is applied from the head tank to force out any water that entered the hub.
The husbandry manual does not specify if oil is discharged when displacing water in the hub, but
it appears to be a reasonable probability. The blade port cover is then replaced, and the hub is
pressure tested at 20 psi. Leaks can appear if the seals are not properly seated, the mylar shims
(i.e., spacers) are not the proper thickness, or the bearing ring is worn.6 If the bearing ring
requires replacement the vessel must be put in a dry dock.

Small amounts of oil can be discharged when removing and replacing the seal, bearing
ring, blade seal base ring, and center post sleeve. Assuming the worst-case condition, five
gallons of oil are discharged from the CPP hub during each replacement. At most a total of 35
gallons of hydraulic oil could be discharged annually fleetwide based on an average of seven
replacements per year.

The BMP also requires the following precautionary measures:

a. Establish/install a floating oil boom in the vicinity of the work. Position this boom to
enclose the aft one-third of the vessel, with approximately 20 feet beyond the stern to
ensure that escaping oil is contained.11

b. Ensure that the oil recovery kit and personnel, who are trained in oil spill recovery,
are at the work site at all times during the propeller blade removal/ installation to
respond to any oil spill. The spill kit shall include a boom, absorbent pads, and other
materials that remove oil from water.11

c. Any released oil will be captured within the oil boom and subsequently removed by
the oil recovery team on the surface. A vacuum truck, equipped with a noncollapsible
hose, will be at the site to remove any visible oil on the surface.11

CPP Blade Replacement. For the replacement of a CPP blade, the only source of oil
release is from bleeding the Morgrip bolt power head tool. Each blade replacement results in
approximately twenty ounces of hydraulic oil bled from the power tool (e.g., 10 ounces for the
blade removal and 10 ounces for the blade replacement).12 For the estimated 30 replacements
that occur each year, this translates to approximately 600 ounces (4.7 gallons) of hydraulic oil
bled from power head tools.

3.3 Constituents

The expected constituents of the discharge are 2190 TEP hydraulic oil from the CPP and
Controllable Pitch Propeller Hydraulic Oil
5
-------
the hydraulic oil (e.g., Tellus #10) that is bled from the power head tool. Constituents of the oil
vary by manufacturer and are noted in Table 2. Hydraulic oils contain Cn (heptadecane,
heptadecene) and large paraffins and olefins.13 The 2190 TEP oil can also contain up to 1%
tricresylphosphate (TCP) as an antiwear additive.14 Shell Oil Tellus Oil #10 (Code 65203)
hydraulic oil contains solvent-refined, hydrotreated middle distillates and light hydrotreated
naphthenic distillates.15 CPP hydraulic oil can contain copper, tin, aluminum, nickel, and lead
that are leached from the piping, hub, and propeller.

Copper, nickel, and lead are priority pollutants that could be present in the hydraulic oil.
There are no known bioaccumulators in this discharge.

3.4 Concentrations

The released material is expected to be hydraulic oil with metals such as copper, tin,
aluminum, nickel, and lead from the piping, hub, and propeller. These metal constituents are
expected to be in low concentrations because metals have low corrosion rates when in contact
with oil. In addition, the hydraulic oil is continually processed through a filtration system to
prevent particulate matter and water from entering the CPP system and potentially causing
system failures.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

4.1.1 Leaks From CPP Seals

As discussed in Section 3.2.1, the release rate of oil from CPP seals due to normal
operations is expected to be negligible. CPPs are designed not to leak and are tested prior to
delivery at 400 psi. In addition, the CPPs are inspected quarterly.7 The majority of those vessels
equipped with CPPs have dry-dock cycles of five years or less and CPPs are returned to the
manufacturer for inspection and overhaul during the dry dock period.3'7'9'10 Therefore, the mass
loading for oil leakage from CPPs is expected to be negligible.

4.1.2 Underwater Replacements

As estimated in Section 3.2.2, Armed Forces vessels could release up to 4.7 gallons of
hydraulic oil from the Morgrip tool and 35 gallons of hydraulic oil from blade port cover
removals each year. This quantity of oil has a mass of approximately 290 pounds based on a

Controllable Pitch Propeller Hydraulic Oil
6
-------
specific gravity of 0.88 for the hydraulic oil.

4.2 Environmental Concentrations

The quantities of hydraulic oil released can cause a sheen on receiving waters that violate
federal and state "no sheen" standards. The metal constituents (e.g., copper, tin, nickel, and lead)
in the oil can also be toxic, but it is anticipated that the concentrations, when dissolved in water,
will be below toxicity thresholds. Florida has a water quality criterion for oil and grease of 5
milligrams per liter (mg/L) that the estimated environmental concentration for underwater
replacement exceeds.

4.2.1 Leaks From CPP Seals

Because the release of oil from a CPP under routine operations is negligible, the resulting
environmental concentration is negligible.

4.2.2 Underwater Replacements

The underwater replacements are expected to result in periodic, batch releases of
hydraulic oil. Based upon the estimated release rates given in Section 3.2.2, the estimated
discharge volume during each replacement is five gallons. During a typical underwater
replacement requiring the removal of the port blade cover, the aft third of a vessel plus an
additional 20 feet are enclosed with an oil boom. The Navy vessels having CPPs are between
445 and 567 feet in length and between 45 and 67 feet in beam (i.e., width). The average
boomed length is approximately 190 feet and width of approximately 65 feet (e.g., average beam
of 55 feet plus an estimated 10 feet for proper deployment). The quantity of oil released from
CPPs during underwater replacements will result in free-phase oil that will result in localized
visible oil sheens on the surface of the water. The resulting visible oil sheens are prohibited
releases of oil under the Discharge of Oil (40CFR110) regulations of the Federal Water Pollution
Control Act.

4.3 Potential for Introducing Non-Indigenous Species
CPPs do not transport seawater; there is no potential for transporting non-indigenous
species.
5.0 CONCLUSIONS

5.1 Leaks From CPP Seals

The release of oil from CPPs during normal operation due to seal leakage is expected to
be negligible. This is due to the following:

1) CPPs are designed not to leak at 400 pounds per square inch (psi) when new or
Controllable Pitch Propeller Hydraulic Oil
7
-------
overhauled and are tested at 400 psi for leaks prior to delivery. There is a zero-leakage tolerance
under the 400 psi test.

2) CPP seals are designed with service lives of 5 to 7 years and leakage that can occur
due to wear or age occurs late within this operational life. The majority of vessels equipped with
CPPs have dry-docking cycles for overhauls of approximately 5 years such that the releases
occurring toward the end of the operational life of a CPP seal are avoided.

3) CPPs are inspected quarterly for damage and evidence of system failure (e.g., leaking
seals).

The amount of oil leakage of CPPs under routine operating conditions has a low potential
to cause an adverse environmental effect.

5.2 Underwater Replacements

CPP hydraulic oil discharge has the potential for causing adverse environmental effects
during underwater replacements because:

1) oil is released to receiving waters by the equipment used to perform the underwater
replacements, and

2) oil is released from the CPP hub assembly during underwater removals of the CPP
blade port covers.

Releases due to underwater replacements are periodic and occur approximately thirty
times per year. Those replacements that require the removal of the blade port cover release
sufficient oil to cause a visible oil sheen on receiving waters and also exceed state WQC. These
releases from waterborne CPP repairs are controlled using NAVSEA BMPs that reduce the
adverse effects of the oil releases to receiving waters.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge. The resulting

environmental oil and grease concentrations were then estimated. Table 3 shows the sources of
data used to develop this NOD report.

Specific References

1. Blank, David A.; Arthur E. Block; and David J. Richardson. Introduction to Naval
Engineering, 2nd Edition. Naval Institute Press, 1985.
Controllable Pitch Propeller Hydraulic Oil
8
-------
2.

9.
John Rosner, NAVSEA OOC. Frequency of Underwater CPP Blade Replacements.
December 1996, Gordon Smith (NAVSEA 03L1).

Penny Weersing, Military Sealift Command. Controllable Pitch Propeller (CPP)
Hydraulic Seals forMSC Ships. April 1997.

LT Joyce Aivalotis, USCG. Response to Action Item RT11, May 28,1997, David
Ciscon, M. Rosenblatt & Son, Inc.

John Rosner, NAVSEA OOC. Meeting on Underwater CPP Blade Replacements. April
14,1997, Clarkson Meredith, Versar, Inc., and David Eaton, M. Rosenblatt & Son, Inc.

Naval Sea Systems Command. Underwater Hull Husbandry Manual, Chapter 12,
Controllable Pitch Propellers. S0600-PRO-1200. February 1997.

Harvey Kuhn, NAVSSES. Personal Communication, March 13, 1997, Jim O'Keefe, M.
Rosenblatt & Son, Inc.

UNDS Equipment Expert Meeting Minutes. CPP Hydraulic Oil. September 26,1996.

William Berberich, NAVSEA 03Z51. Prepared Responses to UNDS Questionnaire,
UNDS Equipment Expert Meeting. September 26,1996.
10. William Berberich, NAVSEA 03Z51. Response to CPP Hydraulic Oil Questions, March
28,1997, Clarkson Meredith, Versar, Inc.

11. Naval Sea Systems Command. NAVSEA Best Management Practices (BMP) to
Prevent/Mitigate Oil Spills Related to Waterborne Removal(s) of Blades on Variable
Pitch Propellers for Naval Vessels. Undated.

12. John Rosner, NAVSEA OOC. Morgrip Power Head Purge During CPP Replacements,
June 6,1997, David Eaton, M. Rosenblatt & Son, Inc.

13. Patty's Industrial Hygiene and Toxicology, 3rd Edition. George D. and Florence E.
Clayton, Ed. John Wiley & Sons: New York, 1981.

14. Military Specification MIL-L-17331H, Lubricating Oil, Steam Turbine and Gear,
Moderate Service. November 19, 1985.

15. Shell Oil Company. MSDS for Tellus Oil #10, Code 65203. August 1988.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
Controllable Pitch Propeller Hydraulic Oil
9
-------
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register,?. 15366. March23,1995.
Controllable Pitch Propeller Hydraulic Oil
10
-------
CRANK PIN RING
CRANK PIN RING DOWEL PIN

BLADE PORT COVER
PRAIRIE AIR NIPPLE

PROPELLER BLADE

BLADE BOLT ASSEMBLY

BEARING RING
HUB REGULATING VALVE PIN
HUB REGULATING
VALVE PIN LINER

LINER PLUG
CHECK VALVE
ASSEMBLY
HUB CONE
END COVER

HUB CONE

PISTON NUT-

,. PISTON

CONE COVER-
BLADE SEAL
BASE RING
PURGE VALVE—I
ASSEMBLY
LHUB BODY
END PLATE
ASSEMBLY
SLIDING
BLOCK
LOCATION
FLANGE BOLT COVER
TAILSHAFT FLANGE
BOLT ASSEMBLY

TAILSHAFT
GUIDE PIN
AIR SECTION NO. 13
ASSEMBLY

VALVE ROD MAKE-UP
SECTION AFT

TAILSHAFT SPIGOT

PISTON ROD ASSEMBLY

PROPELLER SHAFT FLANGE

• SAFETY VALVE ASSEMBLY

CROSSHEAD
Figure 1. Cross Section of a CPP
Controllable Pitch Propeller Hydraulic Oil
11
-------
Suction Face
8 Morgrip Bolt
Holes
2 Dowel Pin Holes
(Diametrically Opposite)
Pressure Face
Blade Palm
(Blade Flange)
Prairie Air
Nipple Orifice
Figure 2. Top View of a CPP Blade
Controllable Pitch Propeller Hydraulic Oil
12
-------
Item Name

1 Center Post Sleeve
2 Center Post
3 O-ring (dynamic)
4 O-ring (static)
5 Blade Port Cover
6 Capscrew
7 O-ring (static)
8 O-ring (dynamic)
9 Blade Seal Base Ring
10 O-ring (static)
11 Spring
12 Bearing Ring
13 Crank Pin Ring
14 Mylar Shim
Figure 3. Cross Section of a CPP Blade Port Assembly
Controllable Pitch Propeller Hydraulic Oil
13
-------
Figure 4. Block Diagram of a CPP System
Controllable Pitch Propeller Hydraulic Oil
14
-------
Table 1. Armed Forces Vessels with CPP Systems
Vessel
Class Description Vessel Shafts
Navy:
CG47
DD963
DDG51
DDG 993
FFG7
LSD 41
LSD 49
MCM1
Ticonderoga Class Guided Missile Cruiser
Spruance Class Destroyers
Arleigh Burke Class Guided Missile Destroyers
Kidd Class Guided Missile Destroyers
Oliver Hazard Perry Guided Missile Destroyers
Whidbey Island Class Dock Landing Ships
Harpers Ferry Class Dock Landing Ships
Avenger Class Mine Counter Measures Ship
27
31
19
4
43
8
3
14
2
2
2
2
1
2
2
2
Total: 149

MSC:
T-AO 187
T-ATF 166
Henry J. Kaiser Class Oilers
Powhatan Class Fleet Ocean Tugs
13
7
2
2
Total: 20
USCG:
WHEC715
WMEC901
WMEC615
WAGE 10
Hamilton and Hero Class High Endurance Cutters
Famous Class Medium Endurance Cutters
Reliance Class Medium Endurance Cutters
Polar Class Icebreakers
12
13
16
2
2
2
2
3
Total: 43
Total Armed Forces Vessels with CPP: 212
Controllable Pitch Propeller Hydraulic Oil
15
-------
Table 2. Percentages of Constituents, TEP 2190 Oil and Tellus Hydraulic Oil
Constituent
i
n i. , i ,
Virgin Petroleum
Lubricating Oil (a)
frnraesvJ Pltosphate
|: ".,,"1 ! I]', Til ' ,„»„ i, *., , . „
:'{T€Pj ' '
'lAdcfitives
i i i y i •

iiyaK>treatea Heavy
Paraffinic Distillates
So3fcj«E3frE)ewaxed
Bsa^ Petroleum
Distffiatesi'
HydEOtoeated Mddle
Distillate
KydrotrsatedOght
Naptaenic Distillate
MIL-L-17331H
Turbine Oil 2190
Balance
<1%
< 0.5%

Chevron OUb
MSDSTtirMner
Oil 2190

> 99%
<1%

, Mobil ©iL"
MSDSTusbine,
Oil 2190

Unknown
Formaldehyde
> 95%

Shell Oil MSDS
Tellus Oil tip

<1%

0 - 100%
0 - 100%
(a) Virgin Petroleum Lubricating Oil is all classes of lubricating oil including heavy and middle Paraffinic
distillates, solvent-dewaxed heavy distillates, light naphthenic distillates, etc.
TableS. Data Sources

NOD Section
2. 1 Equipment Description and
Operation
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Data Sources :
Reported

UNDS Database, Jane's,
Navy Home Page,
USCG Cutters List

MSDSs, Mil Specs

Federal and State Regs

Sampling

Estimated

X
X

Equipment Expert
X
X
X
X

X
Controllable Pitch Propeller Hydraulic Oil
16
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NATURE OF DISCHARGE REPORT
Deck Runoff
1.0 INTRODUCTION

This section describes the deck runoff discharge and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

Decks are addressed in this NOD report under three categories: weather decks, aircraft
flight decks, and oiler weather decks. The runoff from each deck type reflects the materials and
treatment to which it is exposed during normal operations. All decks are exposed to a similar
and harsh environment; however, there is a core group of activities, weapons, and machinery
common to all ships. These common elements are addressed under the general category of
weather deck runoff. Runoff from flight decks from which aircraft are launched and recovered
and from oiler weather decks are addressed separately since the unique nature of the operations
conducted on these decks distinguishes them from other weather deck surfaces.

2.1 Equipment Description and Operation

2.1.1 Weather Deck Runoff

Weather deck runoff consists of rain and other precipitation, seawater which washes over
the decks (green water), and freshwater washdowns. Precipitation is usually the primary source
within 12 nautical miles (n.m.) of shore. Except for small craft, green water or salt spray over the
deck occurs primarily at sea and does not contribute to deck runoff while a ship is in port or in
protected coastal waters. Freshwater washdowns also occur, but contribute less to weather deck
runoff than precipitation.

The following paragraphs summarize each source that can contribute components to
weather deck runoff.1

Deck Machinery - Ships have many pieces of deck machinery, such as windlasses,
mooring winches, boat winches, underway replenishment gear, cranes, towing winches,
and stem gates. This equipment is maintained with a variety of materials, including
lubricating oils and greases that may be present hi the deck runoff.

Topside Debris - Debris is trash (e.g., cigarette butts, dirt, paper) that can be washed
overboard. The amount of debris is almost entirely a function of housekeeping practices,
and crew discipline determines how much is collected for disposal instead of being
washed overboard.
!
Wire Rope - Wire rope is used extensively in topside rigging, deck machinery,
replenishment gear, and other equipment. It must be lubricated to prevent premature
failure caused by friction between strands as the rope is worked. The lubricating oil or
grease must be thin enough to flow or be worked between individual strands, but
sufficiently wash-resistant to withstand rain and washdowns.
Deck Runoff
2
-------
Fueling Operations - Fueling operations, either at sea or in port, may contaminate the
deck with petroleum hydrocarbons (e.g., diesel, JP-5, fuel oil).

Weapons Systems - Gun mounts, missile launchers, weapons directors, and other
weapons-related equipment can contribute constituents similar to those of deck
machinery; however, they are less likely to contribute to deck runoff because most are
contained in a turret or other water-tight or water-resistant enclosure.

Ship's Boats - Surface ships have small boats (e.g., punts, landing craft, rigid inflatable
boats [Rffis]) that are stored topside. They have bilge plugs that are removed while
stored, to drain rainwater, washdown water, or green water through then- bilge and onto
the deck if the boats are not properly covered. Constituents in the bilge (primarily diesel
fuel) are discharged with the water.

Soot Particles - Burned fuels can leave fine soot particles on the deck. Except for MSC
ships that are powered in equal numbers by steam and diesel propulsion equipment, the
majority of the Armed Forces' surface ships and craft have diesel or gas turbine
propulsion and use clean-burning distillates to minimize soot. However, significant
amounts of soot can be produced during boiler light-off or after prolonged shutdowns of
turbines and diesels.

Firefighting Agents - Aqueous Film Forming Foam (AFFF) firefighting systems are
tested periodically hi accordance with the planned maintenance system (PMS). These
tests are conducted beyond 12 n.m. or while making 12 knots or more when transiting
between 3 and 12 n.m.. The AFFF must be collected if the exercise occurs within 3 n.m.
As discussed in the AFFF NOD report, AFFF is not discharged overboard within 3 n.m.
of shore except in the rare instance of an actual shipboard fire.

Cleaning Solvents and Detergents - Miscellaneous solvents are used to clean and
maintain topside equipment. These solvents may contain chlorinated compounds.
However, they are also volatile and evaporate quickly. As such, then- presence in deck
runoff is expected to be minimal to nonexistent. During freshwater washdowns, crew
members may use detergents that become part of the runoff.

Some or all of the above-listed sources that contribute to the contamination in deck runoff
are common to all vessels.

Various Navy ports treat weather deck runoff differently. To date, no port is known to
require the containment of rainwater runoff; however, a containment requirement may exist for
some freshwater washdowns in certain Navy ports. For instance, at the Naval Submarine Base,
Bangor, WA, freshwater washdowns containing cleaning agents, detergents, or other additives
are considered to be industrial discharges; and, as such are not permitted to be discharged into the
Hood Canal, rated a class AA "extraordinary" water body.2 On the other hand, low-pressure
freshwater washdowns completely free of cleaning agents or other chemicals need not be
contained, and may be discharged into the Hood Canal.2

Deck Runoff
3
-------
The U.S. Coast Guard (USCG) performs washdowns of its ships after returning to port
and weekly while in port.3 Initially, the decks are cleared of debris by hand and/or vacuum and
then scrubbed with fresh water and detergent using brushes and screening pads. Fresh water is
used to rinse the washdown overboard.

Deck runoff occurs on boats and craft although some, such as RIBs, are stored on land.
Because these vessels are small, green water becomes a significant contributor to deck runoff,
and freshwater washdowns occur more frequently to remove the effects of green water on these
vessels compared to larger ships. Craft, such as mechanized landing craft (LCMs), and smaller
boats, such as RIBs and river patrol boats (PBRs), are washed down frequently to remove
saltwater spray and residues left by heavy equipment and troops. However, many of these craft
have large wells and very little deck area, which reduces the amount of deck runoff. Instead,
precipitation, washwater, and green water collect in the bilge, rather than contributing to deck
runoff. The USCG washes down its smaller vessels (i.e., those less than 65 feet long) nearly
every day.3

2.1.2 Flight Deck Runoff

The same three sources of water contribute to this discharge as to that of weather deck
runoff: precipitation, greenwater over the deck from heavy seas, and deck washdowns, in this
case flight deck washdowns. As with weather deck runoff, flight deck runoff can be
contaminated with a variety of chemicals.

Aircraft carrier launch and recovery equipment, e.g., catapult troughs and jet blast
deflectors, are unique to aircraft carriers and are a major contributor of contaminants to flight
deck runoff. Lubricating oil is applied to the catapult before each launch, and a fraction of this
oil, along with the fuel mist emitted from aircraft during launch and hydraulic fluid and grease
from the catapult, are deposited in the four catapult troughs of each carrier. Most of these
deposits drain overboard during flight operations, i.e., beyond 12 n.m., but a considerable amount
of residual deposits can remain where precipitation can wash it overboard, either during transit or
in port.4"6 Oil sheens have been observed in port around aircraft carriers. This usually occurs
following rainstorms due to runoff from the catapult troughs. In addition, the jet blast deflectors
accumulate soot from jet exhaust, and have hydraulic system leakage that could contribute to
flight deck runoff.

Most commissioned Navy vessels have flight decks for helicopter landing and takeoff.
Many of these ships also have hangar facilities for helicopter storage and maintenance. The
LHA, LHD, and LPH Classes of amphibious assault vessels have between 30 and 36 helicopters
embarked, and some have about a dozen Vertical/Short Take-Off and Landing (VSTOL) aircraft
as well. Flight exercises are conducted routinely with these aircraft.

Several other classes of vessels also have helicopter landing areas and hangars which
accommodate one to three helicopters. These ships carry helicopters as part of their normal
complement, but conduct flight operations less frequently than carriers or amphibious assault

Deck Runoff
4
-------
ships. Exceptions are the large service force ships, such as fast support ships (AOEs),
ammunition ships (T-AEs), and combat stores ships (T-AFSs), which carry two or three UH-46
Sea Knight helicopters for underway replenishment (UNREP). These ships use the helicopters to
transfer large volumes of provisions and ammunition rapidly during UNREP operations.

Vessels with ancillary helicopter flight decks and do not have their own helicopters, are
not included in this analysis because they contribute very little helicopter-specific flight deck
runoff compared to an amphibious assault vessel, which can carry up to 36 helicopters.

Flight deck washdowns to eliminate fire and slip hazards and to wash salt spray off flight
decks are performed while ships are underway:7'8 Both Commander Naval Air Force, U.S.
Atlantic Fleet (COMNAVAIRLANT) and Commander Naval Air Force, U.S. Pacific Fleet
(COMNAVAIRPAC) have promulgated policies that carrier flight decks are not to be washed
down within 12 n.m. of shore except in cases of emergency.7'8 Further, both Commander Naval
Surface Force, U.S. Atlantic Fleet (COMNAVSURFLANT) and Commander Naval Surface
Force, U.S. Pacific Fleet (COMNAVSURFPAC) have policies in force that state that decks shall
not be washed within 12 n.m. of shore.9'10

Aircraft and helicopter freshwater washdowns are performed to remove dirt,
hydrocarbons, salt deposits, and other materials resulting from flight operations or from salt
spray. Unless the ship's engineering officer is short of fresh water, the aircraft are washed before
they disembark upon the ship's return to port. Since current policies require that flight deck
washing be completed prior to the ship arriving within 12 n.m. of shore, and since aircraft are
disembarked prior to washing the flight deck, aircraft are not usually aboard either aircraft
carriers or amphibious assault ships within 12 n.m. of shore. Therefore, aircraft freshwater
washdowns do not contribute to deck runoff with 12 n.m. of shore.11

MSC has not promulgated protocols for the washing of helicopter flight decks on its
vessels. The cleaning agent/solvent used and the washdown frequency are at the discretion of the
officer in charge of the deck. Except in unusual circumstances, flight decks are not washed in
port.12

2.1.3 Oiler Weather Deck Runoff

Oilers carry various petroleum products as cargo. This report examines the discharge
from Navy and MSC oilers and UNREP ships which perform fueling-at-sea (FAS) operations. It
also examines the discharge from the fuel barge service craft, which are used to fuel and defuel
surface vessels while in port.

During the receiving and off-loading of bulk fuel, oilers have the potential to discharge
oil. To prevent this, the weather deck is sealed by plugging or blocking the weather deck
openings as required by Federal Regulations.13 If the liquid contains oil from inadvertent spills
or releases, the liquid is processed through the ship's oily waste treatment system. These ships
are also provided with oil spill containment and cleanup kits.
Deck Runoff
5
-------
The newer oilers, such as the T-AO 187 Class, incorporate engineering design features
and follow fueling practices that minimize oil releases. Excess oil and other uncontained liquids
drain to a sludge collection tank, which is routed to an oily waste collection system. Any other
liquid that collects in these sumps, such as rainwater or seawater, is also routed through the oily
waste collection system.14 The 7-inch fueling hoses contain check valves to prevent spills when
disconnected. Additional protection against spills is provided by "blowing down" the hose with
compressed air and/or taking a "back suction" with the cargo or stripping pumps and pumping
the contents of the hose back to the oiler's cargo reclamation system before disconnecting the
hose. FAS stations are also provided with spill response equipment to contain one to six barrels
of oil (42 to 252 gallons), and with sorbents to contain any drips or small spills.

The newer designs also include the required catchment basin around fuel tank vent
stations to contain oil and other liquids released because of overfilling during fueling
operations.13 If the liquids contain oily residues, these basins are pumped to the oily waste
collection system. If the catchment basin contains only rainwater, the rainwater is discharged
overboard. The catchments are routinely cleaned to remove oily residue. The disposition of
these wash waters is to the oily waste collection system.14 The treatment and disposition of oily
waste is covered in the Surface Vessel Bilgewater/OWS Discharge NOD report.

All fuel barges have fire and flooding alarms, and are equipped with high tank level
alarms. Ship alterations have been prepared to install oil retaining coamings and plugs for all
fuel barges. Most barges currently in use were built or retrofitted with the coamings.15 Fuel oil
barges refuel ships within 12 n.m. of shore, whereas the oilers/UNREP vessels refuel ships
beyond 12 n.m.

2.2 Releases to the Environment

Deck runoff is produced when water falls on or is applied to the exposed surfaces, such as
weather and flight decks, superstructure, bulkheads, and the hull above the waterline, of a ship.
Frequently runoff is contaminated by residues from the activities described in Section 2.1. The
probable contaminants include: oil and grease; petroleum hydrocarbons; surfactants; cleaners;
glycols; solvents; and particulates, such as soot, dirt, or metallic particles.

2.3 Vessels Producing the Discharge

Deck runoff is produced on all ships, submarines, boats, and craft of the Armed Forces
(Table 1). Table 1 lists ship class, number of ships homeported in the U.S., dimensions (length
and beam), flight deck dimensions (where applicable), and the number of days annually that
each class of ship averages within 12 n.m.16"25 The several thousand small boats and craft of the
Armed Forces are not individually categorized.

. Water, other than green water, that falls on the decks of submarines while they are in port
or transiting inside of 12 n.m. is deck runoff. For submarines, green water is not considered deck
runoff because of their design. All operating equipment on a submarine, with some minor
exceptions, is contained within the double hull of the ship. Some outboard equipment, such as

Deck Runoff
6
-------
the hydroplanes, rudder, shaft seals, periscope, and antennae, are greased on a submarine;
however, discharges from these sources are described in a separate NOD report. When
operating, submarines spend virtually all of their time submerged beyond 12 n.m., and no
activities are performed topside on a routine basis that could contribute to the contamination of
deck runoff. Similarly, while submarines are in port, the majority of work occurs on the inside of
the ship, not topside. Based on this information, the deck runoff from submarines is not a
significant discharge.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

This discharge consists of runoff from rainfall and other precipitation, from freshwater
washdowns, and from green water; therefore, it can occur while in port or at sea. Table 1
contains a tabulation of the number of days the various vessel types spend within 12 n.m. of
shore.16

3.2 Rate

The gallons of precipitation runoff per year estimated for each home port of a ship class is
the product of the deck area of a ship in the class, the number of ships in the class in a given
homeport, the average fraction of the year spent within 12 n.m. of shore, the average annual
rainfall in the homeport, and the appropriate conversion factors. The total gallons of runoff from
a ship class is the sum of the estimates thus developed for all the homeports of the class.

3.2.1 Weather Deck Runoff

Precipitation is expected to be the largest contributor to deck runoff in all types of
vessels. Annual average precipitation data were obtained for the largest ports used by the Armed
Forces as homeports: Norfolk and Little Creek, VA; San Diego, CA; Pearl Harbor, HI; Groton,
CT; Mayport, FL; rngleside, TX; and Bremerton, WA.26 The average number of transits and
days in port were developed for the years 1991 through 1995 for Navy and USCG ships.16

The various deck areas were estimated by multiplying the product of a vessel's length and
beam by a factor intended to account for the departure of the deck's shape from a rectangle, hi
Table 1, those ship classes which are asterisked have a helicopter platform, but do not have a
helicopter routinely embarked. The deck areas listed for these vessel classes include the area of
the flight deck. For vessel classes whose helicopter platform dimensions are without an asterisk,
such as the Spruance Class destroyers (DD 963), the deck area listed in Table 1 does not include
Deck Runoff
7
-------
the area of the helicopter platform.
I
The gallons per year precipitation runoff values listed in Tables 2 through 7 and in Tables
9a and 9b were all estimated using the same formula:
(N) (D/365)(A)(P)(PF)(FG) = Annual Runoff (gallons per year)
where N = the number of ships with the same deck area contributing to the annual runoff
D = the number of days per year each ship is within 12 n.m. of shore
A = the area in square feet of the deck or flight deck under consideration
P = the annual rainfall in inches
PF = 1/12, the conversion factor - one foot per 12 niches
FG = 7.48 gallons per cubic foot

Based upon this information and average deck area, an estimate of weather deck runoff
from precipitation was developed for Navy ships by home port, and is presented in Table 2.
Approximately 37.6 million gallons of weather deck runoff occurs annually from Navy surface
ships in U.S. homeports due to rainfall.

To derive estimates of the precipitation-induced weather deck runoff from MSC, USCG,
and Army vessels, a 40-inches-per-year rainfall was assumed, the annual average for the Navy
homeports. The estimates are provided in Table 3. Approximately 54.6 million gallons of
weather deck runoff occur annually within 12 n.m. of the U.S. coast from MSC, USCG, and
Army vessels due to precipitation.

The Armed Forces operate literally thousands of boats and craft of a multitude of sizes
throughout the offshore waters, harbors, and rivers of the U.S. Because neither the precise
location of all of the boats and craft nor the mode of operation and storage at each location has
been determined, it is impractical to estimate rates for these vessels.

3.2.2 Flight Deck Runoff

An estimate for aircraft carrier flight deck precipitation runoff is based upon reported
average annual precipitation, the number of ships in each homeport, the flight deck area, and the
number of days hi port. Approximately 23.3 million gallons of weather deck runoff from aircraft
carrier flight decks occur annually within 12 n.m. of the U.S. coast due to precipitation.

These results show that the quantity of aircraft carrier flight deck runoff varies
significantly with geographical location. San Diego, CA, has the lowest average annual rainfall
resulting in the least runoff. Although Norfolk, VA does not have the highest precipitation rate,
it produces the highest amount of flight deck runoff because it is homeport to the most carriers.
The data and results are presented in Table 4. Because it is not unusual for three carriers to be in
Norfolk at the same time, and for summer storms to produce an inch of rain in a few hours, the

Deck Runoff
8
-------
three carriers, with a combined flight deck area of 690,000 ft2, will generate approximately
430,000 gallons of flight deck runoff for each inch of rain.

Of the 11 amphibious assault vessels in service, 10 are stationed in U.S. ports, and are
homeported either in Norfolk, VA, or San Diego, CA. The ships, by class, are divided evenly
between these two ports. The mine countermeasures support ship USS Inchon (MCS 12) is a
converted Iwo Jima Class LPH, and is homeported in rngleside, TX. The estimated total annual
helicopter flight deck runoff for these vessels due to precipitation is approximately 8.3 million
gallons. Table 5 is a compilation of the data used to estimate the average annual deck runoff
from these ships due to precipitation.

Table 6 lists flight deck runoff from Navy surface vessels, other than aircraft carriers and
amphibious assault vessels, by U.S. homeport, number and location of vessels by class, and the
average annual rainfall for each port. Based on this information, these ships generate an annual
deck runoff of approximately 2.6 million gallons due to precipitation.

The estimate for precipitation runoff from helicopter flight decks of MSC and USCG
surface ships is presented in Table 7. The estimate was derived from the areas of the flight
decks, the average annual rainfall, and the number of days in port for each ship class. Based on
this information, MSC and USCG surface ships generate an estimated annual deck runoff of 860
thousand gallons due to precipitation.

A volume of helicopter flight deck wash water generated by USCG vessels is estimated in
Table 8. The volume used to wash and rinse a given flight deck area is considered to be the same
as would be used on a Navy ship, that is, 30-gallons of a cleaning solution mix of MIL-C-85570,
type n detergent, sodium metasilicate (anhydrous or pentahydrate), and freshwater will treat
approximately 3,000 ft2 of deck. The amount of water used to rinse the cleaning solution off of
the deck is on the order of three to five times the volume of the cleaning solution used. Further,
because the USCG washes weekly, the number of washes annually is estimated by dividing the
number of days a vessel is within 12 n.m. of shore by seven.3 Based upon these assumptions,
USCG surface ships generate approximately 70 thousand gallons of helicopter flight deck wash
water as compiled in Table 8.

3.2.3 Oiler Weather Deck Runoff

Estimates have been prepared, using the same methodology, for the deck runoff from
Navy and MSC oilers due to precipitation. They are presented in Table 9a. Similar estimates
were prepared for the various service craft, such as fuel barges, and are presented in Table 9b.
As indicated in the tables, the estimated annual runoff from the oilers is approximately 8 million
gallons, and from the various service craft approximately 8.9 million gallons.

3.2.4 Runoff Summary

Table 10 is a compilation of the runoff volumes associated with the various runoff
sources and vessel types. As indicated in the table, the estimated annual runoff from vessels of

Deck Runoff
9
-------
the Armed Forces due to precipitation and the limited number of in-port washdowns is
approximately 143.9 million gallons.

3.3 Constituents

The runoff from flight and other weather decks can contain a number of different
constituents, including: JP-5, found in the runoff from aircraft carrier flight decks, helicopter
flight decks, and the weather decks of support ships carrying JP-5 as cargo; diesel fuel marine,
distillate fuel, or gasoline, from vessel fueling and refueling operations; various solids, such as
soot, paint chips, dirt, and trash; glycol from the windshield washing system; hydraulic fluid
leakage; metals from scrapes, gouges and corrosion; rubber from aircraft tires; and the residue
from cleaners and solvents, particularly sodium metasilicate.

These materials contain short- and medium-length aliphatics, light and heavy aromatics,
paraffins, olefins, surfactants, glycols, and metals. Some cleaning solvents can contain
chlorinated compounds, such as tetrachloroethylene. These solvents quickly evaporate.

Analytical data are available for one element of aircraft carrier flight deck runoff: the
runoff that flows through a catapult trough and is discharged overboard. This runoff was
sampled in a study on the feasibility of using an oil/water separator to treat trough runoff.27 The
resulting data are not representative of the runoff from the entire flight deck of a carrier, only of
runoff that is discharged from one of the catapult troughs. The aqueous phase of the catapult
trough runoff was analyzed for:
I
• oil and grease,
• phenols, and
• metals (silver, cadmium, chromium, copper, nickel, and lead).
I
The four catapult troughs are located in close proximity to the aircraft fueling spots, and
collect spilled JP-5. Lubricating oil is applied to a catapult before each shot. A fraction of this
oil, along with fuel mist emitted from aircraft during launch, and hydraulic fluid and grease from
the catapult is deposited in each of the four catapult troughs.4"6 The concentrations originating in
the catapult troughs can, therefore, be expected to exceed those for the flight deck runoff in
general.

None of the constituents analyzed for are bioaccumulators, and no bioaccumulators are
anticipated in this discharge. The materials used on the decks of vessels do not contain the
pesticides, herbicides, PCBs, or other chlorinated aromatic compounds that constitute
bioaccumulators.

Of the constituents listed above, silver, cadmium, chromium, copper, nickel, lead, and
phenols are priority pollutants.

3.4 Concentrations
Deck Runoff
10
-------
The laboratory data from an aircraft carrier catapult trough drain system are presented in
Table 11. The data are the concentrations before processing the runoff through an oil/water
separator, and are not representative of the runoff from the entire flight deck of an aircraft
earner.27
Constituent concentrations resulting from precipitation are expected to vary significantly
with a number of factors. These include: time since the last rain or deck washing; the intensity
and duration of the last rainfall; the season (which will effect glycol loading from deicing fluids);
the ship's adherence to good housekeeping practices; and the type, intensity, and duration of
weather (high sea state and green water) and ship's operations. For example, higher seas which
result in more frequent green water runoffs and more frequent freshwater washdowns, both of
which generally occur outside 12 n.m., will minimize the concentrations of accumulated residues
that contribute to runoff contamination in port. Further, it should be noted that deck runoff from
precipitation may mimic the constituent concentration patterns observed in storm water runoff
from highways and parking lots: contaminant concentrations will be higher in first portions of
the runoff, and then will taper off to low or nondetectable levels as the precipitation continues.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. A discussion of mass
loadings is presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
are compared with the water quality standards. In Section 4.3, the potential for transfer of non-
indigenous species is discussed.

4.1 Mass Loadings

Currently, no basis exists for estimating the mass loadings of deck runoff accurately. The
factors discussed in Section 3.4, that combine to produce the great variance in deck runoff,
prohibit the development of engineering assumptions from which to estimate deck contaminant
concentrations. The use of the data from any analysis of the untreated runoff that had flowed
through an aircraft carrier catapult trough could result in mass loadings that are overestimated by
orders of magnitude.

4.2 Environmental Concentrations

As with mass loadings, because the constituent concentrations vary with a number of
factors, most of which vary over time since the last rainfall or washdown; the environmental
concentrations will vary accordingly. For any given set of factors discussed in Section 3.4, the
discharge concentrations for the catapult trough portion of deck runoff can be used as a worst
case for a specific contributor.

The catapult trough discharges as a component of the flight deck runoff are diluted as
they enter the receiving waters, but to what extent is unknown. Therefore, the raw concentration

Deck Runoff
11
-------
values are used for comparison to the Federal and most stringent state water quality criteria listed
in Table 12. The comparisons show that a number of the constituent concentrations in catapult
trough runoff exceed Federal and state acute water quality criteria, in addition to discharging oil
exceeding the Federal discharge limits.28 Chromium concentrations exceed the most stringent
state's water quality criteria. The detected metals that exceed the Federal and most stringent state
water quality criteria are: cadmium, nickel, and lead, hi addition, two metals, silver and copper,
which were not detected, have reported limits that are more than an order of magnitude higher
than their corresponding Federal and state water quality criteria. The reported phenols
concentration exceeded the most stringent state criteria. The oil and grease concentration
exceeds the Federal criterion and the concentrations reported are also likely to cause a visible
sheen on receiving waters. Discharges of oil that cause a visible sheen on receiving waters must
be reported.28

4.3 Potential For Introducing Non-Indigenous Species

The potential for non-indigenous species transport is insignificant. The runoff due to
rainfall and washdown has a low potential to contain non-indigenous species, and the runoff
from green water is discharged in the same location from which it came aboard.
5.0 CONCLUSION

Oil in the deck runoff discharge has the potential to cause an adverse environmental
effect. This conclusion is based upon observations of oil sheens on the water surface
surrounding certain vessels during and after rainfalls.
6.0 DATA SOURCES AND REFERENCES

Table 13 shows the sources of data used to develop this NOD report.

Specific References

1. "Deck Runoff from U.S. Naval Vessels", M. Rosenblatt & Son, Inc. Prepared for Naval
Sea Systems Command. September 1996.

2. Dye, J., Public Works Office, Naval Submarine Base, Bangor, WA. Response to UNDS
Questionnaire: Contained Washdowns and Deck Runoff.

3. Aivalotis, Joyce, USCG. Report Regarding USCG Outstanding hiformation, May 29,
1997, David Ciscon, M. Rosenblatt & Son, hie.

4. UNDS Equipment Expert Meeting Minutes - Catapult Troughs, Water Brake, Jet Blast
Deflector, Arresting Cables. August 22,1996.
Deck Runoff
12
-------
5. UNDS Equipment Expert Meeting Minutes - Catapult Discharges. July 26,1996.
6.
7.
8.
9.
10.
11.

12.

13.

14.

15.

16.

17.

18.
Commander, Naval Sea Systems Command. Memorandum to Commander, Naval Air
Systems Command. Pollution of Coastal Waters Attributable to Catapult Lube Oil.
December 16,1992.

LCDR Mills, Staff (N43), COMNAVAIRLANT. AIRLANT Policy Relative To Aircraft
Carrier Washdowns, August 21,1997, Randy Salyer, M. Rosenblatt & Son, Inc.

ABECS Gibson, Staff (N43), COMNAVAIRPAC. AffiPAC Policy Relative To Aircraft
Carrier Washdowns, August 21,1997, Randy Salyer, M. Rosenblatt & Son, Inc.

LT Carlos Castillo, Staff, Commander Amphibious Group Two. Norfolk - Little Creek,
VA. SURFLANT Policy Relative to Amphibious Assault Ship Flight Deck Washdowns,
November 5,1997, Jim O'Keefe, M. Rosenblatt & Son., Inc.

LCDR Southall, Staff (N42), Commander Surface Force, U.S. Pacific Fleet, San Diego,
CA. SURFPAC Policy Relative To Amphibious Assault Ship Flight Deck and Surface'
Ship Weather Deck Washdowns, November 6,1997, Jim O'Keefe, M. Rosenblatt &
Son., Die.

UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Steam
Blowdown Discharge. August 20,1996.

Stucka, Bob, MSC Field Engineer, Norfolk, VA. MSC Policy Relative To Flight Deck
Washdowns, September 9, 1997, Jim O'Keefe, M. Rosenblatt & Son, Inc.

Code of Federal Regulations, 33CFR155, Sub Part B, Vessel Equipment.

Hofinann, Hans, MR&S. Responses To Inquiries Regarding The Design Features hi The
T-AO 187 Class Oilers To Prevent Pollution, December 17, 1996, Clarkson Meredith,
Versar, Inc.

North, Dick, Puget Sound Naval Shipyard, Boston Detachment, Boston, MA. Status of
Pollution Preventative ShipAlts For Yard and Service Craft Oilers, September 3,1997,
Jim O'Keefe, M. Rosenblatt & Son, Inc. (MR&S).

Pentagon Ship Movement Data for Years 1991 -1995, Dated March 4,1997.

Ship Management Information System Report JQ02, U.S. Naval Battle Forces As Of 30
June 1997, June 13,1997. 20.

Weersing, Penny, MSC Engineer, Estimates of Time In U.S. Ports For MSC Vessels,
March 19,1997, Jim O'Keefe, M. Rosenblatt & Son, hie. U.S. Navy Public Affairs'
Home Page. List of U.S. Navy Ships and Their Homeports, March 1,1997.

Deck Runoff
13
-------
19. U.S. Coast Guard, Listing of Vessels and Permanent Stations, 1992.

20. Naval Sea Systems Command (NAVSEA), Data Book for Boats and Craft of the United
States Navy, NAVSEA 0900-LP-084-3010, Revision A. May 1988.

21. U.S. Army Combined Arms Support Command, Army Watercraft Master Plan,
November 1996.

22. Headquarters, Dept. of the Army. Watercraft Equipment Characteristics and Data,
Technical Manual TM 55-500, May 1992.

23. Sharpe, Richard. Jane's Fighting Ships. Jane's Information Group, Ltd.,1996.
I
24. Aivalotis, Joyce, USCG. USCG Ship Movement Data, May 27,1997,
Lee Sesler, Versar, Inc.

25. UNDS Ship Database, August 1,1997.

26. The World Almanac and Book of Facts. Mahwah: Funk & Wagnalls, 1995.

27. "Waste Buster" Test of Oily Waste Treatment Facility. NNS Laboratory Services. April
1994.

28. Code of Federal Regulations, 40 CFR110, EPA Regulations on Discharge of Oil.

General References
j
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
•
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.
Deck Runoff
14
-------
Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

M. Rosenblatt & Son, Inc. Comments on Draft Nature of Discharge Report: Flight Deck
Runoff, Aircraft Carriers. February 13,1997.

UNDS Equipment Expert Meeting Minutes - Deck Runoff. September 19 and October 17,1996.

Wallace, Christine, Public Works Office, Naval Base, Norfolk, VA. Response to UNDS
Questionnaires: Deck Runoff, Solvent Cleaning, Degreasing Solutions, Aircraft
Washdowns;

Military Specifications for Petroleum Compounds:
Diesel Engine Lubricating Oil Data, MIL-L-9000 Military Symbol (MS) 9250
JP-5 Aviation Fuel Data, MIL-T-5624 NATO Code F44
Fuel, Naval Distillate Data, MIL-F-16884 NATO Code F76

3M Corporation. MSDS - FC-203CF Light Water Brand Aqueous Film Forming Foam, April
1995.

MSDSs from Vermont SIR! - http://hazard.com/MSDS:
Texaco - Marine Diesel Blend 00813 (NATO Code F76) - Diesel Fuel DFM
Amoco - Marine Diesel Fuel (F76) - Diesel Fuel DFM
U.S. Oil Refining - JP-5 Jet Fuel, Turbine Engine, Aviation JP-5 F (44)
Deck Runoff
15
-------
P-D-680 Type I Dry Cleaning Solvent (bought to spec)
Captree Chemical - Sodium Metasilicate, Pentahydrate
Lidochem - Sodium metasilicate anhydrous

Naval Surface Warfare Center, Norfolk Division. UNDS Small Boats and Craft Meeting,
September 12 and 13,1996.

Patty's Industrial Toxicology, 2nd Ed. New York: John Wiley & Sons, 1981.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Deck Runoff
16
-------
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Table 3, Estimate of Annual Weather Deck Runoff From Precipitation
MSC, Army and USCG Surface Ships

^^v^W^&3^^:y^at&^^i^9^ifSWMfS^A~/'.
Weather Deck
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Military Sealift Command
Kilauea Class Ammunition Ships (T-AE)
Mars Class Combat Stores Ship (J-AFS)
Sinus Class Combat Stores Ship (T-AFS)
Henry J. Kaiser Oilers (T-AO)
Hayes Class Acoustic Research Ship (T-AG)
Mission Class Navigation Research Ship (T-AG)
Observation Is. Class (T-AGM)
Stalwart Class Ocean Surveillance Ship (T-AGOS)
Victorious Class Ocean Surveillance Ships (T-AGOS)
Silas Bent Class Surveying Ships (T-AGS)
Waters Class Surveying Ship (T-AGS)
McDonnell Class Surveying Ships (T-AGS)
Pathfinder Surveying Ships (T-AGS)
Mercy Class Hospital Ships (T-AH)
Maersk Class Strategic Sealift Ships (T-AKR)
Gordon Class Strategic Sealift Ships (T-AKR)
Algol Class Fast Sealift Ships (T-AKR)
Zeus Class Cable Repairing Ship (TXARC)
Powhatan Class Meet Ocean lugs ( l-A l>)
31,494
31,461
25,140
51,222
15,005
34,808
33,375
7,513
21,949
10,682
24,453
7,301
14,861
73,637
78,215
79,042
78,232
28,612
7,869
45
45
45
50
45
45
45
60
120
45
45
45
45
365
320
320
320
45
120
8
5
3
12
1
1
1
5
4
2
1
2
4
2
3
2
8
1
7
774,534
483,587
231,853
2,099,533
46,129
107,004
102,600
153,975
719,741
65,674
75,172
44,888
182,746
3,672,277
5,129,551
3,455,850
13,681,694
87,959
451,557
USCG
Hamilton Class High Endurance Cutters (WHEC)
Famous Class Medium Endurance Cutters (WMEC)
Famous Class Medium Endurance Cutters (WMEC)
Reliance Class Medium Endurance Cutters (WMEC)
Reliance Class Medium Endurance Cutters (WMEC)
Polar Class Icebreaker (WAGB)
Bay Class Tugs (WTGB)
Point Class Patrol Craft (WPB)
Island Class Patrol Boats (WPB)
Juniper Class Seagoing Buoy Tender (WLB)
Balsam Class Buoy Tenders (WLB)
Keeper Class Buoy Tenders (WLM)
Red Class Buoy Tenders (WLM)
White Sumac Class Buoy Tenders (WLM)
Inland Buoy Tenders (WLI)
Inland Buoy Tenders (WLI)
River Buoy Tenders, 65 ft (WLR)
River Buoy Tenders, 75 ft (WLR)
River Buoy Tenders, 115 ft (WLR)
Pamlico Class Construction Tenders (WLIC)
Cosmos Class Construction Tenders (WLIC)
Anvil/Clamp Class Construction Tenders (WLIC)
Harbor Tugs (WYTL)
Motor Lifeboats
10,633
6,803
6,803
5,582
5,582
21,435
4,106
1,114
1,802
8,073
5,195
4,914
4,041
3,216
1,872
862
1,115
1,287
2,691
3,765
1,872
1,287
963
523
154
139
166
238
151
365
365
320
320
287
295
227
227
227
365
365
365
365
365
365
365
365
365
365
12
4
9
5
11
2
9
36
49
2
23
2
9
4
2
4
6
13
1
4
3
9
11
26
1,342,412
258,392
694,312
453,826
633,449
1,068,959
921,430
876,335
1,930,053
316,565
2,407,882
152,408
564,018
199,485
93,357
85,966
166,875
417,187
67,100
375,527
140,035
288,822
264,219
339,110
Armv
Frank Besson Class Logistic Support Ship (LSV)
Mechanized Landing Craft (LCM 8)
Utility Landing Craft (LCU 2000)
Utility Landing Craft (LCU 1600)
Lighter Amphibious Resupply, Cargo (LARC)
Large Tug (LT 128)
Large Tug (LT 100)
Barge Derrick, 1 1ST (BC)
Barge Derrick, 89T (BD)
Barge Cargo (BC)
6,547
511
2,412
1,292
92
3,594
2,212
13,125
9,800
3,520
183
320
320
320
365
320
320
365
365
365
6
104
34
14
23
10
15
5
7
3
491,105
1,161,183
1,792,495
395,403
52,992
785,730
725,240
1,636,359
1,710,541
263,314
Estimated Total Annual Runoff (gals): 54,638,410
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Table 11. Laboratory Results, Catapult Trough Drains Aqueous Phase Discharge*
Constituent
Date:
Phenols
Oil and grease
Silver
Cadmium
Chromium
Copper
Nickel
Lead
Zinc
Sample Results (mg/L)
4/13/94 <- „
4.6
9,683
<0.050
0.155
0.103
0.050
1.90
26.1
<0.050
. 4/14/94 :
5.3
13,919
O.050
0.141
0.088
<0.050
1.81
76.3
<0.050
Source: NNS Laboratory Services, 199428
* Data represent concentrations prior to processing through an oil water separator.
-------
Table 12. Comparison of Catapult Trough Drains Discharge to
Water Quality Criteria27
Constituent
Date:
Phenols
Oil and grease
Silver
Cadmium
Chromium
Copper
Lead
Nickel
Sample Results (mg/L)
4/13/94
4.6
9,683
O.050
0.155
0.103
O.050
26.1
1.90
4/14/94
5.3
13,919
<0.050
0.141
0.088
<0.050
76.3
1.81
Federal Acute WQC (rag/L)
none
Visible sheen Vl52
0.0019
0.042
1.1
0.0024
0.210
0.074
Most Stringent State Acute WQC
•-::^ -;:-:Mmg/L>^,,- > .,
0.17 (BO)
5(FL)
0.0012 (WA)
0.0093 (FL, GA)
0.05 (FL, GA)
0.0025 (WA)
0.0056 (FL, GA)
0.0083 (FL, GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.

FL =* Florida
GA m Georgia
HI - Hawaii
WA = Washington

I. The Federal Pollution Control Act, 40CFR110, defines a prohibited discharge of oil as any discharge sufficient to
cause a sheen on the receiving waters.
2. International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 is
implemented by the Act to Prevent Pollution From Ships (APPS).
Table 13. Data Sources

NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
23 Vessels Producing the Discharge
3,1 Locality
3.2 Rate
33 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
43 Potential for Introducing Non-
Indigenous Species
Data Source
Reported

UNDS Database

Sampling

Estimated

X
X

Equipment Expert
X
X
X
X

X
-------
NATURE OF DISCHARGE REPORT
Dirty Ballast
1.0 INTRODUCTION

This section describes the dirty ballast discharge and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Duty ballast is created when seawater is pumped into fuel tanks for the purpose of
improving ship stability. Ballast is weight added to a vessel to move the center of gravity to a
position that increases the vessel's stability. Ballast is normally placed low within a vessel's hull
to lower the center of gravity. Permanent ballast is usually heavy solid material, such as lead.
Temporary ballast is normally seawater, which is pumped in and out of tanks in the vessel.

Dirty ballast systems are different from compensated ballast and clean ballast systems.
Compensated ballast systems continuously replace fuel with water in a system of tanks as fuel is
consumed. Clean (or segregated) ballast systems have tanks that only carry ballast water;
therefore, the ballast water does not mix with fuel. These systems are covered in other NOD
reports. In a dirty ballast system, water is added to a fuel tank after most of the fuel is used.
Some fuel remaining in the tank mixes with the ballast water, producing "dirty" ballast.

Most classes of Armed Forces vessels use segregated tanks as the primary ballast system
and use dirty ballast systems only in extraordinary or emergency situations. Some vessel classes,
however, are not provided with clean ballast systems. These vessels regularly use dirty ballast
systems and discharge overboard, using oil content monitors (OCM) and oil water separators
(OWS) to avoid discharging oil at concentrations greater than regulatory limits.1 Using fuel
tanks for ballast water degrades fuel quality and is therefore avoided whenever possible.

As a vessel consumes fuel, air displaces the fuel in its fuel tanks, thus reducing the
vessel's stability. There is an added detrimental effect to stability when a tank is partially full
and the liquid inside can slosh around. The degree to which these factors affect ship stability are
dependent on ship design and the sea state. Some classes of ships are more susceptible to
stability problems than others and certain locations have historically high wave action. When
ship stability is threatened, ballast water can be pumped into a fuel tank to replace the consumed
fuel and to regain stability. Ballast water is discharged when it is no longer needed for
operational reasons or when preparing for fuel reintroduction.

To maintain safe stability, vessels without clean ballast systems may begin ballasting fuel
tanks when remaining ship's fuel drops to approximately 70-80% of total capacity. These
vessels may continue to ballast fuel tanks until approximately 20% of ship's fuel capacity
remains (the minimum percentage allowed by U.S. Coast Guard (USCG) ships).1 Therefore, by
the end of a voyage, as much as 80% of the fuel tanks' contents could be seawater.

Procedures have been established for both ballasting and deballasting to minimize the
concentration of fuel in the dirty ballast. To prepare a fuel tank for ballast, most of the remaining

Dirty Ballast
2
-------
fuel is pumped to another fuel tank. The small quantities of fuel not removed in this first step is
transferred to a waste oil tank. When deballasting, most of the dirty ballast is pumped overboard,
while being monitored by an OCM, which measures the concentration of oil (fuel) in the water.
If the OCM detects oil concentrations in excess of the 15 parts per million (ppm), an alarm
sounds and the overboard discharge is stopped. The remaining dirty ballast is then processed
through an OWS to reduce the oil concentration to 15 ppm or below, as measured by another
OCM. The processed seawater is discharged overboard and the separated oil (fuel) is retained in
a waste oil tank for pierside disposal.

2.2 Releases to the Environment

Dirty ballast is water which may contain residual fuel and other constituents as a result of
sea water being stored hi fuel tanks. Dirty ballast is discharged to the environment after being
processed through OCMs and/or OWS systems that ensure the ballast water fuel/oil
concentrations are below Federal standards. The discharge is infrequent and occurs just above
the waterline of the ship. The possible sources of the constituents of dirty ballast are seawater,
fuel remaining in the tank, fuel additives, materials used hi the ballast system, and the zinc
anodes in the fuel tanks.

2.3 Vessels Producing the Discharge

Three USCG vessel classes use dirty ballast systems. Ships of the WHEC 378 Class (12
ships), WMEC 210 (16 ships), and the WAGE 399 Class icebreakers (2 ships) use their fuel
tanks for ballasting in accordance with published Coast Guard directives and as conditions
dictate.

In an emergency, all vessels of the Armed Forces with fuel tanks have the capability to
generate emergency duty ballast. Generation of emergency duty ballast on Navy, MSC, Army,
Air Force, Marine Corps, and the remainder of the USCG vessels occurs only when the vessels'
clean or compensated ballast systems are insufficient to maintain proper stability during
extraordinary or emergency circumstances. Emergency dirty ballast is not considered a discharge
under UNDS, and is not addressed in this report.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Two of the three USCG ship classes (WHEC 378 and WAGE 399) that use dirty ballast
systems operate beyond 12 nautical miles (n.m.) of land and only transit through 12 n.m. of land

Duty Ballast
3
-------
entering and leaving port. These ships may deballast within 12 n.m. of land using their OCM and
OWS systems however this is rarely done. The third class of ship that uses a dirty ballast system
is the USCG's WMEC 210. These ships are located in several ports on the East, Gulf and West
Coasts. They may conduct normal operations within 12 n.m. of land on these Coasts, and
therefore may ballast and deballast within 12 n.m. of land. These vessels also deballast using
their OCM and OWS systems.

The policy for MSC and Navy vessels, and the practice of USCG vessels, is to discharge
dirty ballast beyond 12 n.m. of shore, or to hold the dirty ballast until it can be transferred to a
shore facility or containment barge.2>3

3.2 Rate
i
A survey found that few cutters routinely use dirty ballast within 12 n.m. even though
USCG policy permits discharge within this area if using an OWS and OCM.4 The limited
number of ballasting operations were insufficient to estimate the annual volume of dirty ballast
discharged. Therefore, for cutter class vessels, fuel capacities, and the maximum percentage of
these fuel tank capacities that are allowed by USCG policy for dirty ballasting; were used to
estimate the annual volume of duty ballast discharged. This resulted in an overestimate of dirty
ballast discharge volumes for USCG vessels. Table 1 lists USCG vessel fuel capacities.

Using 80% of fuel capacities listed in Table 1 to estimate the deballasting discharge for
each deballasting event, WMEC 210 Class vessels could discharge approximately 41,800 gallons
of dirty ballast [(0.8)(52,236 gallons)]. The WAGE 399 Class ships could generate up to
1,080,000 gallons of dirty ballast and WHEC 378 Class ships could generate up to 166,400
gallons per deballasting event. The estimated maximum total annual discharge of dirty ballast
for the three classes of USCG ships is 21.6 million gallons, using the number of deballast events
per year from Table 2 and the following calculations. All of this discharge is assumed to occur
within 12 n.m. of shore and the results are believed by the USCG to be a gross overestimate of
the actual discharge. Of this 21.6 million gallons, two-thirds is from one class (WHEC 378)
which operates principally beyond 12 n.m.
where,
Total (gal/yr) = sum of [(0.8)(capacity)(# vessels)(# deballasting events)]
Total = estimated maximum dirty ballast total annual discharge
0.8 = maximum percentage of fuel tank capacity allowed by USCG policy for
dirty ballast
capacity = fuel capacity in gallons
# vessels = number of vessels per class
# deballasting events = number of debaUasting events per year
The estimated maximum dirty ballast total annual discharge for WHEC 378 Class ships
is:
Dirty Ballast
4
-------
(0.80) (208,000 gallons of foe!) (12 vessels in the class) (7 deballasting events per year)
= approximately 14 million gallons per year.r
The duration of USCG vessels' dirty ballast discharge is estimated by considering
deballasting procedures and equipment characteristics. Based on operational experience,
approximately 75% of the dirty ballast can be discharged directly overboard while being
monitored through an OCM at an estimated flow rate of 250 gallons per minute (gpm).2 The
remaining 25% of ballast is required to be processed through an OWS, at a flow rate of 25 gpm.
Using a dirty ballast volume of 80% of vessel fuel capacity, an estimated flow rate of 250 gpm
for direct ballast overboard discharge, and 25 gpm through the OWS, the discharge duration is
summarized in Table 3. For example, the maximum tune to deballast for WHEC 378 Class ships
is approximately 36 hours.

These values result in the maximum expected time to deballast since the calculations
assume the largest dirty ballast volume (the maximum allowed is 80% of the ship's fuel capacity)
and ignore any processing of ballast through the OWS performed concurrently with the ballast
being discharged directly overboard. Also, it is unlikely that the entire duration of deballasting is
within 12 n.m. of shore, so the calculations overestimate the amount of dirty ballast discharged
within 12 n.m.

3.3 Constituents

Because process information and data on compensated fuel ballast, a similar discharge,
were sufficient to characterize this discharge, no sampling was performed on dirty ballast. The
constituent sources of dirty ballast are almost identical to the constituent sources hi compensated
fuel ballast systems. Therefore, sampling performed for compensated fuel ballast discharge can
be used to predict the constituents in dirty ballast.

Soluble components of the fuel remaining in the tank mix with the seawater ballast
during extended contact while in the compensated fuel or dirty ballast tanks. The fuels will
normally be either Naval Distillate Fuel (NATO F-76) or Aviation Turbine Fuel (JP-5). In
addition, the USCG uses biocide fuel additives in their fuel tanks to control bacterial growth hi
the fuel-water interface.5'6 All these sources can contribute to the concentrations reported as total
petroleum hydrocarbons and oil and grease. Specific fuel-based constituents can include
benzene, toluene, ethylbenzene, xylene, cresols, phenols, and polycyclic aromatic hydrocarbons.7

Materials used in fuel and ballast systems on the ships, which include copper, nickel, iron
and zinc, and the fuel or additives in the fuel such as biocides, can contribute to metal
concentrations in the discharge. Based on compensated ballast sampling, the metals in the
discharge can include copper, nickel, silver and zinc. The biocides used can contain naphtha and
dioxaborinane compounds.

The potential priority pollutants in dirty ballast discharge are 2-propenal, benzene,
toluene, ethylbenzene, phenol, copper, nickel, silver, thallium, and zinc. The only
bioaccumulator found in compensated ballast screening was mercury.

Dirty Ballast
5
-------
3.4 Concentrations

Knowledge of dirty ballasting systems and practices and use of compensated fuel ballast
screening enables the characterization of dirty ballast discharge concentrations.
I
In support of the Compensated Ballast NOD report, a sampling effort was conducted
during a refueling evolution. The results of the sampling effort are applicable to this NOD report
because the same fuels are used in both compensated ballast and dirty ballast. Constituent
concentrations are based on compensated ballast with the exception of oil concentrations, which
are limited to 15 ppm by USCG practices and the use of OCMs and OWSs. The concentrations
of detected priority pollutants, oil and grease, and a bioaccumulator are shown in Table 4.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. hi Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

An estimate of the maximum oil loading from duty ballast for the three USCG vessel
classes was calculated by first estimating the greatest potential discharge volume and assuming
that the discharge contains the maximum allowable concentration of oil (15 ppm). hi reality, the
concentration is expected to be somewhat lower than this, due to the preballasting and
deballasting procedures used by the USCG vessels, as described in Section 2.1. Using these
values with existing information on vessel operating profiles, an annual oil mass loading value
for each of the three USCG vessel classes was calculated.

The estimated maximum oil mass loading generated for each deballast event was
calculated using the equation:
Estimated Maximum Oil Loading Generated by Deballasting Event in Pounds (Ibs) =
[80% fuel capacity (gal)] (3.785 L/gal)(15 mg/V^lff6 kg/mg)(2.205 Ib/kg)
Using this equation, the estimated maximum oil loading generated in each deballasting
event for WHEC 378 Class ships is:
(0.80X208,000galX3.785 L/gal)(15 mg/L)(10"6 kg/mg)(2.205 Ib/kg) ^approximately 21 Ibs

Similarly, the WMEC 210 Class and the WAGE 399 Class would generate approximately
Dirty Ballast
6
-------
5 and 135 pounds of fuel for each deballasting event, respectively.

The annual maximum oil mass loading per class was calculated using the equation:
Estimated Maximum Oil Loading Generated by Deballasting (Ibs/yr) =
(discharge amt perevent (ibs))(# vessels)(# debaUasts/year)
where, « -, / "*' , " - ,;
discharge amt. = pounds of oil per deballasting event 7
# vessels = number of vessels in class > ,- ~* ~ "
* #debal!asts/year=nmnberofdebaMasting events per year /,' A
Using this equation, the estimated maximum oil loading generated by deballasting per
year for WHEC 378 Class ships is:
(21 Ibs per deballast) (12 vessels in class) (7 deballasting events per year) = 1,76416s/yr
Given the assumed maximum concentration of 15 ppm, the maximum total mass loading
for oil for all Coast Guard vessels is 2,704 pounds per year as shown in Table 2.

In a similar manner, the concentrations of each of the constituents shown hi Table 4
(which are based on compensated ballast data for constituent concentrations) were used to
calculate the mass loadings shown in Table 5.

4.2 Environmental Concentrations

Dirty ballast water discharged from armed forces vessels is expected to be similar to the
compensated ballast discharge. In compensated ballast samples, copper, nickel, silver, and zinc
exceeded Federal and the most stringent state WQC, and ammonia, benzene, phosphorous,
thallium, total nitrogen, O&G, and 2-propenal concentrations exceeded the most stringent state
WQC.7 Table 4 is a summary of compensated ballast sample concentrations and applicable
WQC.

4.3 Potential for Introducing Non-Indigenous Species

There is no significant potential for introducing, transporting, or releasing non-indigenous
species with dirty ballast discharge. Navy and MSC policy requires that all dirty ballast be
discharged beyond 50 n.m., and those USCG vessels with a combination of clean and duty
ballast systems also follow that practice.2'3 The potential is mitigated by the fact that the three
classes of USCG vessels with exclusively dirty ballast systems do not take on ballast while hi
port and normally ballast and deballast beyond 12 n.m., where they are less likely to take on non-
indigenous species, hi addition, the USCG has a policy that states if a cutter does ballast within
12 n.m. of land, a full-tank ballast exchange should be conducted twice while in open waters
beyond 12 n.m., otherwise, hold the ballast and discharge it on the next voyage beyond 12 n.m.

Duty Ballast
7
-------
Dirty ballast could also be discharged to a shore facility for processing. Most USCG vessels
deballast prior to returning to port, at greater than 12 n.m. from shore.
5.0 CONCLUSIONS
j

Uncontrolled, dirty ballast has the potential to cause an adverse environmental effect
because:

1) oil can be discharged in significant amounts above water quality criteria, and

2) oil in the discharge can also create a sheen that diminishes the appearance on surface
waters.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 6
lists data sources for this NOD report.

Specific References

1. LT. Aivalotis, Joyce, USCG, April 15,1997, to File.

2. UNDS Equipment Expert Meeting Minutes, Dirty Ballast, August 2,1996.

3. Department of the Navy. Environmental and Natural Resources Programs Manual,
OPNAVINST 5090.1B, Chapter 19-10, November 1994.

4. Department of the Navy. Carderock Division, Naval Surface Warfare Center. Summary
of Dirty Ballast Questionnaire Responses for the Uniform National Discharge Standards
(UNDS) Program. NSWCCD-TM-63-98/48. March 1998.

5. Military Specification MIL-S-53021 A, Stabilizer Additive, Diesel Fuel, August 15,1988.

6. LT Aivalotis, Joyce, USCG, Dirty Ballast Reply, 20 May, 1997.

7. UNDS Phase 1 Sampling Data Report, Volumes 1-13, October 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c){2)(B). 40 CFRPart 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Dirty Ballast
8
-------
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Ihtrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Dirty Ballast
9
-------
Table 1. USCG Vessel Fuel Capacity and Consumption Data'
Vessel Class
Fuel Capacity (100%) (gal):
F-76 (diesel)
WMEC210

52,236
;WHEC378^ •:•:••-/

208,000
WAGB 399

1,349,920
Table 2. Maximum Annual Oil Mass Loading Estimate for USCG Vessels
Vessel Class
WMEC210
WHEC378
WAGB 399
No. of Vessels
16
12 ,
2
Oil per Deballast
Event Ob)
5
21
135
Deballast Events
per Year
5
7
2
Notes:
Maximum Oil
Discharged Obs/yr>A
400
1764
540
Total: 2,704 Ibs/yr
A - based on maximum allowable OWS system discharge concentration limit (15 ppm),
Table 3. USCG Vessel Dirty Ballast Discharge Duration
Vessel Class
Amount to Deballast (gal)A
Direct Discharge (gal)
Direct Discharge (gpm)
Direct Discharge (hours)
OWS Processing (gal)
OWS Processing (gpm)
OWS Processing (hours)
Total Ballast Discharge Time (hours)8
WMEC210
41,800
31,400
250
2.1
10,500
25
7.0
9.1
WWEC378 -:•:
166,400
124,800
250
8.3
41,600
25
27.7
36
WAGB 399
1,080,000
810,000
250
54
270,000
25
180
234
Notes:
A - Amount to deballast is 80% of F-76 fuel capacity.
B - Time estimates are maximum values per deballast event, based on maximum ballast volumes and moderate direct
discharge flow rates.
Dirty Ballast
10
-------
Table 4. Estimated Dirty Ballast Constituent Concentrations that Exceed Federal and/or
Most Stringent State Water Quality Criteria Based on Compensated Ballast Sampling
Measurements
Constituent "f
Ammoniaas
Nitrogen
Benzene
2-Propenal
Total Nitrogen
Total Phosphorous
Copper
Mercurjr
Nickel

Silver
Thallium
Zinc
Oil & Grease
Maximum Dirty Ballast
7 Concentration (pg/L)
300
153
203
580
340
86
0.00083
267

5.7
10.8
4845
15000
Federal Acute WQC
-•^/ftwfcV «•>>'
none
none
none
none
none
2.4
1.8
74

1.9
none
90
visible sheenc
715,000°
Most Stringent State
Acute WQC (wj/L)
6(HI)A
71.28(FL)
18 (HI)
200(HI)A
25(ffl)A
2.4 (CT, MS)
0.025 (FL, GA)
8.3 (FL, GA)

1.9 (CA, MS)
6.3 (FL)
84.6 (WA)
5000 (FL)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)

A - Nutrient criteria are not specified as acute or chronic values.
B - Mercury was not found in excess of WQC; concentration is shown only because it is a bioaccumulator.
C - Discharge of Oil. 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen
on receiving waters.
D - International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as
implemented by the Act to Prevent Pollution from Ships (APPS).

CA= California
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
Dirty Ballast
11
-------
Table 5. Estimated Maximum Annual Mass Loadings for Dirty Ballast Constituents that
Exceed Water Quality Criteria
Constituent
AmmoniaA
BenzeneA
PhosphorousA
Total Nitrogen
2-Propenal
Copped
NickelA

Silver'"
Thallium
ZincA
Mercury^8
Oil & Greasec
Annual Mass Loading (Ife/yr)
54.2
27.6
61.4
105
36.6
15.5
48.1

1.0
1.95
872.1
0.00015
2704
Notes:
A - Based on constituent concentrations found in compensated ballast water
B - Mercury was not found in excess of WQC; mass loading is shown only because it is a bioaccumulator.
C - Oil and Grease mass loading based on maximum allowable OWS system discharge concentration limit (15
ppm), not on compensated ballast sampling results.
80% of the ship's fuel capacity is always used for ballast anytime a ship takes on ballast water.
Dirty Ballast
12
-------
Tabled. Data Sources
-
NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
23 Vessels Producing the Discharge
3.1 Locality
.3.2 Rate ,
3.3 Constituents
3,4 Concentrations :
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Jtaroducing^Non-
Indigenous Species
^ Data Source
Reported
Data Call Responses
Data Call Responses
UNDS Database
Data Call Responses
Data Call Responses
Data Call Responses
Data Call Responses

Sampling

Estimated

X
X
X
X
X

Equipment Expert
X
X
X
X

X
X

X
Dirty Ballast
13
-------
-------
NATURE OF DISCHARGE REPORT
Distillation and Reverse Osmosis Brine
1.0 INTRODUCTION

This section describes the distillation and reverse osmosis (RO) brine discharge and it
includes information on: the equipment that is used and its operation (Section 2.1), general
description of the constituents of the discharge (Section 2.2), and the vessels that produce this
discharge (Section 2.3).
i

2.1 Equipment Description and Operation
i
Distilling and RO plants, known as "water purification plants," generate freshwater from
seawater for a variety of shipboard applications. These include potable water for drinking and
hotel services (e.g., sanitary, laundry, and food preparation) and high-purity feedwater for boilers.
Vessels with steam turbine propulsion plants are equipped with large boiler systems that require
significant amounts of high-purity feedwater for generating high-pressure steam to operate the
ship's engines. Vessels also need low-pressure steam for producing hot water and for heating.

2.1.1 Distilling Plants

Distilling plants, also known as evaporators, are used to distill freshwater from seawater.
Non-volatile seawater components, such as inorganic and organic solids (dissolved and
suspended), remain in the plant and become concentrated. The mixture of concentrated seawater
components that remain and the constituents leached from material hi the plant is known as brine
and is discharged overboard.
i
There are two types of distilling plants used on Armed Forces vessels. One type uses
low-pressure steam as the heat source and generally operates under vacuum. Figure 1 is a
diagram of a two-stage flash-type distilling plant. The other type, vapor compression, uses a
compressor to "drive" the evaporation process. Both types produce similar brine discharges.

The heat that is essential to the distilling process is transmitted to the influent seawater
through one or more heat exchangers. The heat exchangers consist of a series of metal tubes or
plates enclosed in a metal casing. They are designed to segregate the heat source fluid (steam in
the case of distilling plants) from the fluid to which the heat is transmitted (influent seawater)
while providing as much thermal contact through the metal surfaces as possible. This is
accomplished by having a high density of tubes or plates.

Condensate, which is segregated from distillate and brine, is produced from the
generating steam when it is cooled by distilling plant heat transfer surfaces. The condensate can
be directed to a collection tank along with condensate from other heating devices (e.g.,
ventilation heaters) for reuse in the ship's boilers. The condensate that is not reused in the boilers
is a source of non-oily machinery wastewater, as discussed in the NOD report for that discharge.

During the distilling process, inorganic seawater constituents form a scale on the
distilling plant heat transfer surfaces. Anti-scaling compounds are continuously injected into the
influent seawater to control the scaling. Nevertheless, the surfaces will gradually foul from
Distillation and Reverse Osmosis Brine
2
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scaling over extended periods and periodic cleaning is required to restore flow and heat transfer
efficiency.

Citric acid cleaning can be done at sea or in port. At-sea acid cleaning is done during
distillation by injecting the citric acid solution into the influent seawater. The citric acid reacts
with the distilling plant scale to form soluble byproducts that are discharged with the distilling
plant brine. Carbon dioxide is also given off by this reaction and is removed by the distilling
plant air ejector.

In-port citric acid cleaning is done every 5 to 7 years on Navy distilling plants. The
cleaning solution is recirculated between the distilling plant and a tank truck on the pier. The
spent cleaning solution is disposed at an off-site shore facility.1

2.1.2 RO Plants

RO plants separate freshwater from seawater by using semi-permeable membranes as a
physical barrier. The RO membrane retains a large percentage of suspended and dissolved
constituents, allowing freshwater to pass through. The retained substances become concentrated
into brine. Shipboard RO plants produce lower-purity freshwater than distilling plants, with total
dissolved solids (IDS) concentrations two orders of magnitude greater than distilling plant
distillate.2

Because RO plants operate at ambient temperatures, scaling is not a concern. Therefore,
chemicals are not used in RO plants for either scaling suppression or cleaning.

2.2 Releases to the Environment

The overboard discharge from water purification plants on vessels is RO and distilling
plant brine. The brine primarily consists of seawater, but can also contain materials from the
purification plants and anti-scaling treatment chemicals. RO and distilling processes separate a
relatively small proportion of freshwater from the influent seawater, returning the slightly more
concentrated brine effluent to the sea. The discharged brine from distilling plants is at elevated
temperatures, typically 100 to 120 °F.

The citric acid cleaning solutions that are used to periodically clean the distilling plants
are either collected on-site after shoreside cleaning or discharged overboard beyond 12 n.m. after
at sea cleaning.

2.3 Vessels Producing the Discharge

There are currently 541 vessels of the Armed Forces equipped with water purification
plants. Four hundred fifty-seven vessels have distilling plants and the remainder have RO plants.
Table 1 provides a list of Navy, MSC, USCG, and Army vessels that produce this discharge.3
Distillation and Reverse Osmosis Brine
3
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3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

The distilling plant on a steam-propelled vessel can be operated any time the vessel's
boilers are operating. MSC steam-propelled ships typically operate one distiller while in port,
except for ships on reduced operating status. As a result, discharge of brine from steam-
propelled vessels can occur in port, at sea, and while transiting to and from port. However,
diesel- and gas-turbine-propelled vessels with distilling plants, and all vessels with RO plants
seldom operate their water purification plants in port or while transiting coastal waters less than
12 nautical miles (n.m.) from shore.

For Navy vessels, brine discharge within 12 n.m. is from the production of boiler
feedwater. Navy vessels do not produce potable water within 12 n.m., except during extended
operations.

3.2 Rate

While the existing Navy fleet has water purification plants of many sizes and capacities,
current naval ship design practice is to use standardized water purification plants of two
capacities: 12,000-gallons per day (gpd) distilling and RO plants and 100,000-gpd distilling
plants. Multiple water purification plants will be used to achieve capacities of up to 450,000-
gpd. For example, a destroyer's RO system may include two 12,000-gpd plants, while the new
IPD 17 Class amphibious transport dock vessels require five 12,000-gpd plants to meet
freshwater demand. Aircraft carriers have multiple 100,000-gpd distilling plants.

The volume of brine discharged from water purification plants depends on the type of
plant. When operating, distilling plants are typically run at full capacity, even when the demand
for potable water is low. Excess distillate is discharged directly overboard. Based on operating
experience, distilling plants generate 17 gallons of brine for every gallon of fresh water. RO
plants generate 4 gallons of brine for every gallon of fresh water.3 These brine production factors
can be used to calculate the water purification plant brine flow rate in gallons per day:
Water Purification Plant Brine Flow Rate in gallons per day (gpd) =
(total freshwater flow in gpd) (brine production factor)
A single distilling plant on a typical Navy DD 963 Class destroyer produces 8,000 gpd of
freshwater.4 Therefore:
(8,000 gpd freshwater) (17) = 136,000 gpd brine discharge
Distillation and Reverse Osmosis Brine
4
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A single RO plant on a typical Navy MHC 51 coastal minehunter produces 1,600 gpd of
freshwater.3 Therefore:
(1,600 gpd freshwater) (4) = 6,400 gpd brine discharge

Current Navy vessel water purification plant operating practice is for steam-propelled
ships to operate one distilling plant in port for one to five days before departure (to fill boiler
feed water tanks) and while transiting through coastal waters less than (<) 12 n.m.). Submarines
are normally supplied boiler feed water by shore or a tender while in port. The distilling plants
on all these vessels can be operated at full capacity while at sea (greater than (>) 12 n.m.)).

Table 1 shows estimated distilling and RO plant brine discharge quantities for various
vessel classes. The estimates are based on available information regarding the number of vessels
in each class, type and capacity of water purification plant(s), vessel operating schedules (number
of transits and days in port per year), and water purification plant operating practices while in
port, in transit (<12 n.m.) and at sea (>12 n.m.). The assumptions and formulas used to calculate
the brine discharge estimates are summarized in the notes section of Table 1, and include four
hours per vessel transit in coastal waters. The assumptions also include operation of one
distilling plant to produce boiler feedwater for four hours prior to departure from port in the case
of submarines.3 Surface steam-powered vessels may operate a distilling plant for as much as
three days prior to departure from port (i.e., every second transit).3'5 The calculation of the total
annual brine discharge within 12 n.m. of shore consists of an in-port component and a transit
component, which are added together. The formula for a Navy vessel class is:
; Annual Flow within 12 n.m.'(gajls/yr) =• - ' \ '• ^
(number of vessels in class) (single (fistin^ brine flow in gaJ/day/vessefy(number of
distiiiers/vessei) (number of jKoisite/yrj ((3"days before each transit/2 transits) + •i-
(4 hours/transit X I day/24 hours)) ^
A sample calculation for the LSD 36 Class dock landing ship is as follows:
(5 ships) (510,OOQ.gaJ/day/sfaip) (26jransits/yr) ((3.days before each transit 12) +-
(4/24 day per transit))^5* III million gals/yr
Table 1 lists the results of the above calculation for all vessels of the Armed Forces. A
total of approximately 2.47 billion gallons of distilling and RO plant brine discharges occur
annually within 12 n.m. from shore. Of this, approximately 1.84 billion gallons is discharged in
port and 620 million gallons is discharged in transit within 12 n.m. These calculations
overestimate the actual discharge rate because steam-powered surface ships can operate a
distilling plant for less than three days prior to leaving port.

The volume of influent seawater to a distilling plant can be estimated using the ratio of
brine produced to gallons of freshwater produced, or 17:1. This ratio indicates that for every 18

Distillation and Reverse Osmosis Brine
5
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gallons of seawater introduced into a distilling plant, 17 gallons of brine is produced. Knowing
that a total of approximately 2.47 billion gallons of distilling and RO plant brine discharges occur
annually within 12 n.m. of shore, the following calculation can be made to approximate the total
annual volume of seawater influent:
(18 gallons of seawater/17 gallons of brine) (2.47 billion gallons of brine)
= 2.62 billion gallons seawater .
Therefore, the influent flow rate is approximately 2.62 billion gallons, and the effluent
flow rate is approximately 2.47 billion gallons

3.3 Constituents

The three sources of the constituents of water purification plant discharge are: 1) influent
seawater; 2) anti-scaling treatment chemicals; and 3) the purification plant components,
including heat exchangers, casings, pumps, piping and fittings. /The primary constituents of the
brine discharge are identical to those in seawater. These include non-volatile dissolved and
suspended solids, and metals.

Distilling plants are made primarily of metal alloys that are corroded by seawater,
particularly at the elevated temperatures at which these plants operate. The metal alloys used for
heat transfer surfaces and other components include copper-nickel alloys, nickel/chromium
alloys, stainless steel, titanium, brass, and bronze. Based on the metallurgical composition of
these alloys, the corrosion process could be expected to introduce copper, chromium, nickel, and
zinc into the brine. The corrosion effect on the brine discharge metal loadings is less of a
concern for the RO plants, with non-metallic membranes and ambient seawater operating
temperatures.

The distilling plant anti-scaling compound used in Navy surface ships is Distiller Scale
Preventive Treatment Formulation. The military specification requires anti-scaling compound
products to contain organic polyelectrolytes such as polyacrylates, and an antifoaming agent in
aqueous solution.6 The polyelectrolyte chelates (ties-up) inorganic constituents (calcium,
magnesium, metals) to prevent them from depositing on equipment surfaces. Equipment supplier
material safety data sheets (MSDSs) indicate that the products contain about 10% to 20%
polyacrylate and low levels of antifoaming chemicals (e.g., one product contains 1%
polyethylene glycol). Ethylene oxide was identified on two of the MSDSs as potentially present
in trace amounts. One of the MSDSs also indicated that acrylic acid, acetaldehyde, and 1,4-
dioxane can also be present at trace levels.7
i
Distilling plant influent and effluent were sampled for materials that had a potential for
being hi the discharge. An aircraft carrier, an amphibious assault ship, and a landing ship dock
were sampled.8 Based on the brine generation process, system designs, and analytical data
available, analytes in the metals, organics, and classicals classes were tested. In addition, Bis(2-
ethylhexyl) phthalate, a semi-volatile organic compound, was specifically tested for, since it is
not covered in the three aforementioned analyte classes, but is a standard parameter in sampling

Distillation and Reverse Osmosis Brine
6
-------
for semi-volatile constituents. The results of the sampling are provided in reference 8. Table 2
provides a list of all constituents and their concentrations that were detected in the discharge. In
terms of thermal effects, this discharge is expected to be warmer than ambient water
temperatures with a maximum overboard discharge temperature of 120 °F.

Priority pollutants that were detected included copper, iron, lead, nickel, and zinc; and the
semi-volatile organic compound bis(2-ethylhexyl) phthalate. No bioaccumulators were detected.

3.4 Concentrations

The concentrations of detected constituents are listed in Tables 2 and 3.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented hi Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria.
Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of non-
indigenous species is discussed.

4.1 Mass Loadings

The water purification plant brine annual discharge flow rate (Section 3.2) and constituent
concentration data (Tables 2 and 3) were used to develop brine constituent effluent mass loading
estimates. Similarly, constituent influent mass loadings were found by using the seawater annual
flow rate (Section 3.2) and constituent concentration data (Tables 2 and 3).

The following general formula was used to determine influent mass loading and effluent
mass loading:
Mass Loading (Ibs/yr) = : !
(concentration in figTL) (flow rate in gal/yr) (3.7854 L/gal) (2.21b/kg) (10"9 kg/ug)
For instance, the estimated effluent mass loading for copper generated by distilling plant
brine discharge is:
38 ug/I^ff^^

The estimated influent mass loading calculation for copper is:
(83.51 ng/L) (2.62 billion gal/yr) (3.7854 L/gal) (2:2 Ib/kg) (IP'9 kg/fig) = 1822^IMbs?yr
Distillation and Reverse Osmosis Brine
7
-------
The mass loading of the discharge was then determined by subtracting the influent mass
loading from the effluent mass loading for each constituent. Concentration values and mass
loadings are provided in Table 2. Log-normal average concentrations were used because the
sample data were assumed to approximate a log-normal distribution.

The mass loadings were calculated based upon flow from all distilling and RO plants and
assuming constituent concentrations in distiller and RO effluent are equal. Calculations using
this assumption are expected to overestimate mass loadings because constituent concentrations
will be lower in RO effluent because the operating temperature is lower, resulting in less
corrosion. Table 3 provides a water purification plant brine discharge mass loading summary.

4.2 Environmental Concentrations

Table 4 identifies distilling plant brine constituents that were detected at or above their
respective Federal or most stringent state water quality criteria (WQC). Copper and zinc
exceeded both Federal and most stringent state WQC. Nitrogen (as ammonia, nitrate/nitrite, and
total kjeldahl nitrogen), phosphorous, iron, lead, nickel, and zinc exceed the most stringent state
WQC.

4.3 Thermal Effects

The potential for distilling plant brine discharge to cause thermal environmental effects
was evaluated by modeling the thermal plume generated and then comparing it to plumes
representing state thermal discharge requirements. Thermal effects of distilling plant brine were
modeled using the Cornell Mixing Zone Expert System (CORMLX) to estimate the plume size
and temperature gradients in the receiving water body. The model was run under conditions that
would overestimate the size of the thermal plume (minimal wind, slack tide) for the largest
generator of distilling plant brine (aircraft carrier) and for a typical distillation brine generator
(cruiser). The plume characteristics were compared to thermal mixing zone criteria for Virginia
and Washington. Other coastal states require that thermal mixing zones be established on a case-
by-case basis.

The Washington thermal regulations state that when natural conditions exceed 16 °C, no
temperature increases will be allowed that will raise the receiving water temperature by greater
than 0.3 °C. The mixing zone requirements state that mixing zones shall not extend for a
distance greater than 200 feet plus the depth of the water over the discharge point, or shall not
occupy greater than 25% of the width of the water body. The Virginia thermal regulations state
that any rise above natural temperature shall not exceed 3 °C. Virginia requires that the plume
shall not constitute more than one-half of the receiving watercourse, and shall not extend
downstream at any time a distance more than five times the width of the receiving of water body
at the point of discharge.

The aircraft carrier distilling plant brine flow rate was determined to be 24,083 gallons
per hour at a temperature of 104 °F while the cruiser flow parameters were 120 °F and 6,375
gallons per hour for temperature and flow rate, respectively. The ambient water temperature was

Distillation and Reverse Osmosis Brine
8
-------
dependent upon location and varied between 40 and 60 °F. Both modeled discharges were
continuous and were assumed to emanate from a 6-inch diameter pipe located at the bottom of
the hulls. The results of this modeling are provided in Table 5.9

Some of the model parameter assumptions lead to a reduced amount of mixing within the
harbor. The assumptions are:

• wind velocity is at a minimum (1 m/s);
• the discharge will occur during a simulated slack tide event, using a minimum water
body velocity (0.03 m/s);
• the average depth of water at the pier is 40 feet.

Using the above parameters and assumptions, distilling plant brine discharges from
Armed Forces vessels do not exceed state thermal mixing zone criteria.

4.4 Potential for Introducing Non-Indigenous Species

The potential for introducing, transporting, or releasing non-indigenous species with this
discharge is low because the maximum retention time of water in these plants is short; therefore
the effluent is discharged in the same area from which the influent seawater is taken.
5.0 CONCLUSIONS

The discharge from vessel water purification plants has the potential to cause adverse
environmental effects because significant amounts of metals are discharged at concentrations
above WQC.
6.0 DATA SOURCES AND REFERENCES

Table 6 lists the data source of the information presented in each section of this NOD
report.

Specific References

1. Personal communication between Carl Geiling, Malcolm Pimie, Inc., and Chief Luedtke,
USS Carter Hall (LSD 50), 23 January, 1997.

2. Aerni, Walter, NAVSEA. Elements Present in Water, 19 November 1997, Greg
Kirkbride, M. Rosenblatt & Son, Inc.

3. UNDS Equipment Expert Meeting Minutes - Evaporator Brine & Reverse Osmosis (RO)
Plant. August 27, 1996.
Distillation and Reverse Osmosis Brine
9
-------
4. Aqua-Chem Marine, Inc. Marine Multi-Stage Flash Distilling Plants.

5. U.S. Navy. Commander, Naval Air Forces Pacific. Implementation of Uniform National
Discharge Standards. Letter to SEA OOT-E1,17 December 1996.

6. Specification for Distiller Scale Preventive Treatment Formulations (Metric), DOD-D-
24577(2), 19 December, 1986.

7. Ashland Chemical Company. Material Safety Data Sheets - Ameroyal Evaporator
Treatment, January 5,1996.

8. UNDS Phase 1 Sampling Data Report, Volumes 1-13, October 1997.

9. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed
Services. Versar, Inc. July 3,1997.

General References
I
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
Distillation and Reverse Osmosis Brine
10
-------
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2-307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.

UNDS Ship Database, August 1,1997.
Distillation and Reverse Osmosis Brine
11
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PRESSURE
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Distillation and Reverse Osmosis Brine
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0

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cs
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rs
s
s
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34692.28
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en

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125895.89
r-

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en
t-
t-;
Total Sulfide
-------
Table 3. Estimated Mass Loadings of Constituents
Constituent*
Ammonia as
Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total
Phosphorous
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Total
Zinc
Total
Log-normal Mean
Influent (pg/L)
0.07
20
540
0.17

29.97
83.51

594.59

.6.77

44.43

18.49
Log-normal
Meant Effluent
(m/L)
0.17
20
470
0.23

59.21
217.38

1081.50

23.84

13.17

122.26
Influent Mass
Loading (Ibs/yr)
f "" */f
1527.33
436.38
11782.28
3709.24

653.92
1822.11

12973.39

147.71

969.42

403.43
Effluent Mass
,„ Loading
(Ibs/yr) "
'/
2262.68
411.39
9667.84
4731.07

1217.94
4471.48

22246.31 •

490.39

270.91

2514.87
Estimated Annual
Mass Loading
(Effluent -Influent)
' (ibs/yr)
735.35
-24.99
-2114.44
1021.83

564.02
2649.37

9272.92

342.68

-698.51

2111.14
Notes:
1. The table lists all constituents whose effluent log-normal mean concentration exceeds the Federal or most
stringent state water quality criteria. 2. The average total concentration is the log-normal mean for a constituent,
determined from Table 2, by subtracting the influent total average (background) concentration from the effluent
total average concentration.
3. Mass loadings are based on average total concentrations and a total fleet brine discharge flow estimate of 2.47
billion gallons per year to navigable waters less than 12 n.m. from shore (1.84 billion gallons per year in port and
0.62 billion gallons per year in transit, from Table 1). Mass loading was not determined for nickel, for which the
influent concentration exceeded the effluent concentration.
Distillation and Reverse Osmosis Brine
19
-------
Table 4. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituent
Classicals (ug/L)
Ammonia as
Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen8
Total Phosphorous
Metals (ug/L)
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Total
Zinc
Total
Log-normal
Mean
Effluent

170
20
470
490
230

59.21
217.38

1081.5

23.84

13.17

122.3
Minimum
Concentration
Effluent

BDL
BDL
460

160

49.7
127

576.5

BDL

93.0
Maximum
Concentration
Effluent

330
220
490

270

71.15
325.5

1590

24.4

174
Federal
Acute WQC

None
None
None
None
None

2.4
2.9

None

217.2

74.6

95.1
Most Stringent
State Acute WQC

6 (HI)A
8iffl)A
-
200 (HI)A
25 (HI)A

2.4 (CT, MS)
2.5 (WA)

300 (FL)

5.6(FL, GA)

8.3 (FL, GA)

84.6 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA - California
CT ** Connecticut
FL - Florida
GA = Georgia
HI <** Hawaii
MS = Mississippi
WA — Washington
Distillation and Reverse Osmosis Brine
20
-------
Table 5. Summary of Thermal Effects of Distilling Plant Brine Discharge9
CASE
"V
Discharge
Temp(°F)
Discharge
Elow<,
(gallons per
hour)
Ambient
Water -
Temp (°F)
Predicted
Pin me
Length (m)
Allowable
Plume
Length (m)
Predicted
Plume Width
(«*>
Allowable
Plume Width
<«») j"
Predicted „
Plumr
Depth (m)
Virginia State (3.0°C AT) , , 1
4a (CV 63)
4b (CGN 36)
104
120
24,083
6,375
40
40
3.8
2,57
32,000
32,000
0.43
0,35
3,200
3,200
0.43
0.35
Washington State (ft3°C AT) -
4a(CV63)
4b (CGN 36)
104
120
24,083
6,375
50
50
16.42
7.72
73
73
1.83
19.28
400
400
1.83
0.96
Table 6. Data Sources
/
NOD Section
2,1 Equipment Description and
Operation ~
2.2 Releases to the Environinenf
/ *
s ^,
2.3 Vessels Producing tbe Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations 1
'4.1 Mass Loadings
4.2 Environmental Concentrations' «
4.3 Thermal Efiects
4.4 Potential for Introducing Non-
Indigenous Species
- ' Data Source
Reported
NSTMa
NSTMand
MSDSs3-"
UNDS Database

Design
Documentation

MSDS"

X
X

Sampling

X
X

Estimated

X
X

' Equipment Expert
X
X
X
X
X
X

X
NSTM - Naval Ships' Technical Manual
MSDS - Material Safety Data Sheet
Distillation and Reverse Osmosis Brine
21
-------
-------
DISTILLATION AND REVERSE OSMOSIS BRINE
MARINE POLLUTION CONTROL DEVICE (MPCD) ANALYSIS
Several alternatives were investigated to determine if any reasonable and practicable
MPCDs exist or could be developed for controlling distillation and reverse osmosis (RO) brine
discharges. An MPCD is defined as any equipment or management practice, for installation or
use onboard a vessel, designed to receive, retain, treat, control, or eliminate a discharge incidental
to the normal operation of a vessel. Phase I of UNDS requires several factors to be considered
when determining which discharges should be controlled by MPCDs. These include the
practicability, operational impact, and cost of an MPCD. During Phase I of UNDS, an MPCD
option was deemed reasonable and practicable even if the analysis showed it was reasonable and
practicable only for a limited number of vessels or vessel classes, or only on new construction
vessels. Therefore, every possible MPCD alternative was not evaluated. A more detailed
evaluation of MPCD alternatives will be conducted during Phase n of UNDS when determining
the performance requirements for MPCDs. This Phase n analysis will not be limited to the
MPCDs described below and may consider additional MPCD options.

MPCD Options

Distilling and RO plants generate freshwater from seawater for a variety of shipboard
applications, including potable water for drinking, hotel services, aircraft and vehicle washdowns,
boiler feedwater on steam-powered vessels, and auxiliary boiler feedwater on most vessels.
Discharges from distilling and RO plants contain influent seawater, contaminants from system
components, and anti-scaling treatment chemicals. Distilling plants boil seawater, and the
resulting steam is condensed into distilled water. During the distilling process, seawater
constituents form a scale on the heat transfer surfaces. Therefore, anti-scaling compounds are
continuously injected into the influent seawater to control the scaling. The remaining seawater
concentrate or "brine" that does not boil away is discharged overboard. RO systems separate
freshwater from seawater using semi-permeable membranes as a physical barrier, allowing a
portion of the influent seawater to pass through the membrane as freshwater, while capturing
suspended and dissolved constituents. These captured substances become concentrated in a
seawater brine that is subsequently discharged overboard.

Five potential MPCD options were investigated for controlling this discharge within 12
n.m. of shore. The MPCD options were selected based on screenings of alternate materials and
equipment, pollution prevention options, and management practices. They are listed below with
brief descriptions of each:

Option 1: Restrict operation of water purification plants in port - Eliminate or
minimize distilling and RO plant use in port. This would require alternate sources of
distilled/demineralized water for boiler feedwater for steam powered vessels.
Distillation and Reverse Osmosis Brine MPCD Analysis
1
-------
Option 2: Layup non-essential water purification plants with freshwater when in
port - Require the use of shore-supplied freshwater to layup all water purification plants
on non-steam powered vessels and the non-essential plants onboard steam powered
vessels, to reduce corrosion.
|
Option 3: Require RO systems on new ships - Specify RO plants instead of distilling
plants to meet freshwater requirements (except boiler feedwater production) for new
construction ships. RO plant discharges are expected to contain fewer heavy metals.

Option 4: Substitute freshwater for seawater to operate distilling plants onboard
steam-powered vessels while in port - Require freshwater from a shore connection,
instead of seawater, to provide feedwater for distilling plants on steam-powered vessels.
This option would reduce metal mass loadings in the brine discharge by reducing seawater
induced corrosion.

Option 5: Change distilling and RO plant construction materials - Specify water
purification plants that are constructed of materials that minimize or eliminate discharge of
harmful constituents.

MPCD Analysis Results

Table 1 shows the results of the MPCD analysis. It contains information on the elements
of practicability, effect on operational and warfighting capabilities, cost, environmental
effectiveness, and a final determination for each option. Based on these findings, Option 3 —
requiring RO systems on new construction ships - offers the best combination of these elements
and is considered to represent a reasonable and practicable MPCD.
Distillation and Reverse Osmosis Brine MPCD Analysis
2
-------
-.I-
55
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-------
REFERENCES

.' Memorandum from Mr. R. Bernstein (M. Rosenblatt & Son, Inc.), Subj: Estimate for
Freshwater Supply to Vessels While Inport, November 13,1997.

2 Naval Ship's Technical Manual, Chapter 531 - Desalination, Volume 1 - Low-Pressure Distilling
Plants, S9086-SC-STM-010/CH-531V1, First Revision, March 21,1996.

3 Naval Ship's Technical Manual, Chapter 533 - Potable Water Systems, S9086-SC-STM-
010/CH-533, Third Revision, March 15,1995.
!
4 Titanium Prices, e-mail from Mr. Sam Fisher, Principal Metals, Inc., November 13,1997.

5 Titanium Prices, personal communication with Mr. Bob Marsh, Titanium Industries, Inc.,
November 24,1997.

6 Metals Prices, MetalWorld, Inc., http://www.metalworld.com, August 29,1997.
Distillation and Reverse Osmosis Brine MPCD Analysis
6
-------
NATURE OF DISCHARGE REPORT
Elevator Pit Effluen/
1.0 INTRODUCTION

This section describes the discharge from elevator pits and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Most large surface vessels have at least one type of elevator; however, elevator
configurations vary between ship classes. On each ship, several different types and sizes of
elevators may be used to transport small packages, large cargo items, ordnance, food supplies,
and personnel.1 Elevators can service several decks depending on their purpose. Elevator doors
open at each deck for loading and unloading. The elevator operates using either cables, rails, or
hydraulic pistons. The elevators that raise and lower aircraft on aircraft carriers cannot produce
this discharge because they are open to the sea and do not have elevator pits. Elevators that
operate in shafts have a sump in the pit to collect liquids that may enter the elevator and shaft
area.1 If the elevator pit is located above the waterline, the sump is fitted with a drain that directs
the waste overboard. This drain is normally higher than the sump floor to prevent clogging from
solids. If the elevator pit is located below the waterline, the pit is educted dry using the firemain
water supply.

2.2 Releases to the Environment

For elevators with pits, deck runoff and elevator equipment maintenance activities are the
major sources of liquid that accumulate in the pit. Deck runoff occurs during heavy rains, rough
seas, and deck washdowns. During these events, water from the deck can enter the elevators and
elevator shafts when the elevator doors are open, or through worn seals when the doors are
closed (non-watertight). When water enters the elevator pit, it can contain materials that were on
the deck, including aviation fuel, hydraulic fluid, lubricating oil, residual water, and aqueous film
forming foam (AFFF).2 The runoff may also include lubricant applied to the elevator doors, door
tracks, and other moving elevator parts. Residue in the elevator car from the transport of
materials may also be washed into the elevator pit. The cleaning solvent used during
maintenance cleaning operations as well as liquid wastes generated by the cleaning process drain
into the elevator pit sump. This mixture of materials and liquid collects in the sump at the
bottom of the elevator pit.

Waste accumulated in the elevator pits is removed by gravity draining, by educting
overboard using firemain powered eductors, by using a vacuum or sponges to transfer the waste
to the ship's bilge system for treatment as bilgewater, or by containerizing it for shore disposal.3
Since elevator pit eductors use the firemain water supply, the elevator pit effluent can contain any
constituents present in the firemain water. The ratio of elevator pit waste to firemain supply can
vary from 1:1 to 3:1, depending on the type of eductor used to evacuate the elevator pit.

23 Vessels Producing the Discharge
Elevator Pit Effluent
2
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All of the ships listed in Tables 1, 2, and 3 have the potential to produce an elevator pit
discharge. Table 1 lists the MSC ships that have elevators. Tables 2 and 3 list the number and
types of major elevator systems on Navy surface combatants and support ships, respectively.4
U.S. Coast Guard (USCG), Air Force, and Army vessels do not produce this discharge because
they do not have elevator pits.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

This discharge has the potential to occur within and beyond 12 nautical miles (n.m.) from
shore. Inspections of elevator pits on Navy ships in port revealed that elevator pits are generally
dry and that elevator pit effluent is not expected to be discharged in significant amounts within
12 n.m. because of current practices which educt the waste overboard prior to the ship coming
within 12 n.m. of shore.3 Without these practices, this effluent could be discharged while
pierside or underway.

3.2 Rate

The rate of this discharge is subject to frequency and amount of deck runoff (e.g.,
washdown water and rainfall), as well as the frequency of use of the elevators and the size of the
elevator opening. These factors vary greatly between vessel classes. Inspections were performed
on nine vessels to investigate the presence of accumulated waste in elevator pits. The inspections
revealed that elevator pits in each vessel were often dry when the vessel came into port, because
the accumulated waste had either been drained or educted overboard prior to the vessel coming
within 50 n.m. of land, containerized for shore disposal, or the waste had been transferred to the
bilge for treatment by the oil water separator (OWS) as bilgewater.3 Based on this information, it
is estimated that the discharge flow rates of elevator pit effluent within the 12 n.m. zone are
minimal.

3.3 Constituents

The constituents of elevator pit effluent are affected by the amount and type of materials
on deck, the agents used during cleaning and maintenance of the elevators, and to some degree
the material transported in the elevators. At any given time elevator pit effluent may contain the
following constituents:

• grease;
• lubricating oil;
Elevator Pit Effluent
3
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• solvent;
• soot;
• dirt;
• paint chips;

Additional constituents that may be carried into the elevator pit by deck runoff can
include fuel, AFFF, glycol, and sodium metasilicate. Material safety data sheet (MSDS)
information on these materials indicate that the constituents can include polymers, heavy
hydrocarbons, paraffinic distillates, silicone compounds, various organic acids, hydroxyl
compounds, naphtha compounds, various oils, and some metals such as lead and zinc.

When eductors are used to remove the waste accumulated in elevator pits, the effluent is a
combination of the pit waste and the flremain water that is used for eduction. It is not possible to
determine the percentages of each of these sources, because they would vary from ship to ship
depending upon a number of factors. Furthermore, effluent sampling would not help to
determine these percentages, as it would be impossible to isolate and analyze the three sources of
the discharge. The Firemain Systems NOD report contains a more complete discussion of those
constituents found in flremain water. The only constituents present in the firemain water that
were found to exceed water quality criteria were copper, iron, and nickel.

Of the constituents listed above, the expected priority pollutants in this discharge are
bis(2-ethylhexyl) phthalate, silver, chromium, copper, iron, nickel, lead, zinc, and phenols. Deck
runoff is the source of these pollutants, with the exception of bis(2-ethylhexyl) phthalate, copper,
iron, and nickel, which are also present in firemain water. Additional information concerning
these pollutants can be found hi the Deck Runoff NOD report.

No bioaccumulators are anticipated in this discharge.

3.4 Concentrations

Constituent concentrations of deck runoff resulting from precipitation will vary with a
number of factors. The following factors affecting deck runoff constituent concentrations are
dependent on time since the last rainfall or deck washdown:

• intensity and duration of rainfall;
• type, intensity, and duration of weather (high sea state and green water);
• season (which will affect glycol loading from deicing fluids);
• ship's adherence to good housekeeping practices; and
• ship's operations.

The periodicity of cleaning and lubrication of the mechanical components in the elevator
pit will also affect constituent concentrations. For example, if the guide rollers, bearings, etc.,
located in the bottom of the elevator shaft are cleaned and greased more often, the concentrations
of solvent and grease in the effluent could increase.
Elevator Pit Effluent
4
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The Firemain Systems NOD report contains a more detailed analysis of firemain water
constituent concentrations. As shown in Table 4, the firemain water constituents that exceeded
the most stringent water quality criteria were total nitrogen, bis(2-ethylhexyl) phthalate, copper,
iron, and nickel, where the total measured effluent log-normal mean concentrations were 500
micrograms per liter (ug/L), 22 ug/L, 62.4 ug/L, 370 ug/L, and 15.2 ug/L, respectively.5
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. A discussion of mass
loadings is presented in Section 4.1. In Section 4.2, the concentrations of discharge are
discussed, and in Section 4.3, the potential for the transfer of non-indigenous species is
evaluated.

4.1 Mass Loading

. Mass loadings cannot be calculated because the quantity of constituents released from
elevator pits cannot be estimated, and because the concentration of these constituents will vary as
discussed in Section 3.4. Inspections of elevator pits on Navy ships in port revealed that elevator
pits are generally dry and that elevator pit effluent is not expected to be discharged in significant
amounts within 12 n.m. because of current practices which educt the waste overboard prior to the
ship coming within 12 n.m. of shore.3

4.2 Environmental Concentrations

Concentrations of grease, oil, cleaning solvent, and other pollutants that might be present
in elevator pit effluent have not been estimated. The concentrations of total nitrogen, bis(2-
ethylhexyl) phthalate, copper, iron, and nickel in the firemain water used for eduction have been
found to exceed water quality criteria.

4.3 Potential for Introducing Non-Indigenous Species

The major sources of elevator pit effluent, deck runoff and maintenance activities, do not
have a significant potential to introduce non-indigenous species; therefore, this discharge does
not have a significant potential for transporting non-indigenous species.
5.0 CONCLUSION

Uncontrolled, elevator pit effluent could possibly have the potential to cause an adverse
environmental effect because oil could be discharged in amounts and concentrations high enough
to cause an oil sheen, especially when the vessel is pierside. There are currently no formalized
management practices in place regulating this discharge. However, surveys and inspections of
nine Navy ships indicated that the current practice is to containerize the waste for shore disposal,

Elevator Pit Effluent
5
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to transfer the waste to the ship's bilges for processing by the OWS, or to refrain from
discharging the waste overboard.3
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained, reviewed,
and analyzed. Table 5 indicates the data source of the information presented in each section of
this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Elevator Pit Effluents. October 1,1996.
i
2. Round 2 Equipment Expert Meeting Minutes - Elevator Pit Effluent. April 3,1997.

3. Navy Fleet Technical Support Center Pacific (FTSCPAC) Inspection Report Regarding
Elevator Pit and Anchor Chain Locker Inspection Findings on Six Navy Ships, March 3,
1997.

4. Naval Surface Warfare Center, Carderock Division, Philadelphia Site (NSWCCD-SSES)
Report Regarding Number and Type of Elevators on Various Navy Vessels, Paul
Hermann, October 17,1997.

5. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22, 1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.
Elevator Pit Effluent
6
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Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for rntrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 -307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23, 1995.
Elevator Pit Effluent
7
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Table 1. Type of Elevators and Conveyors on MSC Ships
Vessel
Mars
AFS1
Niagara Falls
AFS3
Concord
AFS5
San Diego
AFS6
San Jose
AFS7
T-AFS 8 Class
3 Vessels
T-AH 19 Class
2 Vessels
T-AO 187 Class
10 Vessels
LKA-1 13 Class
2 Vessels
T-AE 28 Class
4 Vessels
T-AE 32 Class
4 Vessels
Passenger
Elevators

10 per vessel
1 per vessel

Carga Elevator
(1) 16,000 Ib CARGO
(2) 4,000 Ib (HYD)
HELO
(1) 16,000 Ib CARGO
(2) 10,000 Ib HELO
(2) 12,000 Ib CARGO
(1) 16,000 Ib CARGO
(2) 10,000 Ib HELO
(2) 12,000 Ib CARGO
(1) 16,000 Ib CARGO
(2) 10,000 HELO
(1) 16,000 Ib CARGO
(2) 10,000 Ib HELO
(2) 12,000 CARGO
(3) 4,000 Ib CARGO
8 per vessel

6 per vessel
6 per vessel
6 per vessel1
Stores Lift
(British)

1 per vessel

1. Number 6 elevator divides into two elevators.
Elevator Pit Effluent
8
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Table 2. Number and Type of Major Elevator Systems
(Navy Surface Combatants)
Ship Class
-< ?>* *
CG47
DD 9637
DDG 993
FFG7
CVN65
CVN68
CV67
CV63
Number of
Vessels -
27
35
48
1
7
1
2
Number of Elevators
-''x Per Vessel "' *:
2
2
1
14
9(CVN72-74)
10(CVN68,70,71)
11(CVN69)
9
11(CV63)
12 (CV 64)
Type of . f
r Elevator
Ammunition
Ammunition
Pallet
Weapons
Weapons
Weapons
Weapons
Elevator Pit Effluent
9
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Table 3. Number and Type of Major Elevator Systems
(Navy Auxiliary and Amphibious ships)
Ship Class

Jnderway
Replenishment
Ships

Material
Support
Ships

Amphibious
Warfare
Ships

Hull

AE27
AE28
AE29
AE32
AE33
AE34
AE35
AOE1
AOE2
AOE3
AOE4
AOE6

AOE7

AOE8
AO177
AO178
AO179
AO180
AO186
AS 36

AS 39

AS 41

LCC19
LCC20
LHA1

LHA2

LHA3

LHA4

LHA5

LHD1

LHD2

Number of
Elevators
6
6
6
7
7
7
7
9
9
9
9
6
1
6
1
7
1
1
1
1
1
8
2
2
8
2
1
8
2
1
1
1
5
1
5
1
5
1
5
1
5
1
6
1
6
1
r&r; '••'"•&**<* '•£•->* :
Elevator
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo
Cargo/Weapons
Cargo
Cargo/Weapons
Weapons
Weapons
Weapons
Weapons
Weapons
Cargo
Component
Weapons
Cargo
Component
Weapons
Cargo
Component
Weapons
Vehicle
Vehicle
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Elevator Pit Effluent
10
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Ship Class
_ ^
Amphibious
Warfare
Ships (continued)

Other Auxiliary
Ships
Hull
—
LHD3

LHD4

LHD5

LPD1
LPD2
LPD4
LPD5
LPD6
LPD7
LPD8
LPD9
LPD10
MCS12
LPD13
LPD14
LPD15
LPH3
LPH11
LPH12
LSD 41

LSD 42

LSD 43

LSD 44

LSD 45

LSD 46

LSD 47

LSD 48

LSD 49

LSD 50

LSD 51

AGF3
AGF11
•'Nandjerof
'Elevators
6
1
6
1
6
1
Decommissioned
Decommissioned
1
1
1
1
1
1
1
1
1
1
1
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
3
2
1
3
2
1
3
1
1
Type of
Elevator
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac

Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Weapons
Weapons
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Ammunition
Lift Platform
Cargo
Ammunition
Lift Platform
Cargo
Ammunition
Lift Platform
Cargo/Weapons/Stores
Cargo/Weapons
Elevator Pit Effluent
11
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Table 4. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituents
Classicals (ug/L)
Total Nitrogen
Organics (ug/L)
Bis(2-ethylhexyl)
phthalate
Metals (ug/L)
Copper
Dissolved
Total
Iron
Total
Nickel
Total
Log-normal
Mean
Effluent

500

24.9
62.4

370

15.2
Minimum
Concentration
Effluent

BDL

BDL
34.2

95.4

BDL
Maximum
Concentration
Effluent

428

150
143

911

52.1
Federal Acute
WQC

None

2.4
2.9

None

74.6
Most Stringent
State Acute WQC

200 (ffl)A

5.92 (GA)

2.4 (CT, MS)
2.5 (WA)

300 (FL)

. 8.3(FL,GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
A - Nutrient criteria are not specified as acute or chronic values.

CT e Connecticut
FL =• Florida
GA ** Georgia
MS = Mississippi
WA s Washington
Table 5. Data Sources

NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
Data Source
Reported

X
UNDS Database
X
X
MSDS

Sampling

Estimated

unknown
unknown
unknown

Equipment Expert
X
X
X
X

X
Elevator Pit Effluent
12
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NATURE OF DISCHARGE REPORT
Firemain* Systems
1.0 INTRODUCTION

This section describes the firemain discharges and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Firemain systems distribute seawater for fire fighting and secondary services. The
firefighting services are fire hose stations, seawater sprinkling systems, and foam proportioning
stations. Fire hose stations are distributed throughout the ship. Seawater sprinkling systems are
provided for spaces such as ammunition magazines, missile magazines, aviation tire storerooms,
lubricating oil storerooms, dry cargo storerooms, living spaces, solid waste processing rooms,
and incinerator rooms. Foam proportioning stations are located in rough proximity to the areas
they protect, but are separated from each other for survivability reasons. Foam proportioners
inject fire fighting foam into the seawater, and the solution is then distributed to areas where
there is a risk of flammable liquid spills or fire. Foam discharge is covered in the aqueous film
forming foam (AFFF) NOD report. The secondary services provided by wet firemain systems
are washdown countermeasures, cooling water for auxiliary machinery, eductors, ship
stabilization and ballast tank filling, and flushing for urinals, commodes and pulpers. The
washdown countermeasure system includes an extensive network of pipes and nozzles, to
produce a running water film on exterior ship surfaces. Not all these services are provided on all
vessels.

Firemain systems fall under two major categories: wet and dry firemains. Wet firemains
are continuously pressurized so that the system will provide water immediately upon demand.
Dry firemains are not charged with water and, as a result, do not supply water upon demand.
Most vessels in the Navy's surface fleet operate wet firemains.1 Most vessels in the Military
Sealift Command (MSC) use dry firemains.1 All U.S. Coast Guard (USCG), and U.S. Army
vessels use dry firemains.

For the purposes of the Firemain Systems NOD report, the firemain system includes all
components between the fire pump suction sea chest and the cutout valves to the various
services. If the discharge from the service is not covered by its own NOD report, it is included in
this Firemain Systems NOD report. The components of the firemain system are the sea chests,
fire pumps, valves, piping, fire hose, and heat exchangers.

Seawater from the firemain is discharged over the side from fire hoses, or directly to the
sea through submerged pipe outlets. Seawater discharges from secondary services supplied from
the firemain are described in the pertinent NOD reports; see Section 2.2 below.

The sea chest is a chamber inset into the hull, from which seawater flows to a fire pump.
The fire pump sea chests are constructed of the hull material - steel - and are coated with durable
epoxy paints. They also contain steel waster pieces or zinc sacrificial anodes for corrosion
protection. The fire pumps are constructed of titanium, stainless steel, copper alloyed with tin or

Firemain Systems
2
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nickel, or non-metallic composites. The pipes in wet firemain systems are primarily copper-
nickel alloys and fittings are bronze that are connected by welding or by silver-brazed joints. Dry
firemain systems can be constructed of these same materials but are normally constructed of
steel.

Fire pumps are centrifugal style pumps driven by steam turbines, electric motors, and/or
diesel engines. The pumps are located in the lower levels of vessels and are sized to deliver
required flow and pressure to equipment or systems on the upper decks. Pump sizes range from
50 to 250 gallons per minute (gpm) on small vessels to 2,000 gpm on large vessels.1 To prevent
overheating when firemain load demands are low, Navy fire pumps are designed to pass 3 to 5%
of the nominal flow rate back to the sea suction or overboard.2 This also provides flow to the
pump's seals.

The firemain piping layout (architecture) is governed by the mission or combatant status
of the ship. The simplest architecture consists of a single main run fore and aft in the ship, with
single branches to the various services supplied from the firemain. More complex architectures
incorporate multiple, widely separated mains with cross connects, and feature multiple pipe paths
to vital services. Regardless of the architecture, all firemain systems include pipe sections which
may contain stagnant water. For example, except during fire fighting, the valves at the fire plugs
are closed and sprinkling systems do not flow.

Navy firemain system capacity is designed to meet peak demand during emergency
conditions, after sustaining damage. This capacity is determined by adding the largest fire
fighting demand, the vital continuous flow demands, and a percentage of the intermittent cooling
demands. The number of fire pumps required to meet this capacity is increased by a 33% margin
to account for battle damage or equipment failure.2 As a result, Navy firemain systems have
excess capacity during routine operations.

Firemain capacity on most MSC, U.S. Coast Guard (USCG), and Army ships is designed
to commercial standards as prescribed by regulations pertinent to each ship type.3'4 Ships
acquired from naval or other sources satisfy other design criteria, but the firemain capacity
requirements meet or exceed commercial standards. A minimum of two pumps is required. The
required firemain capacity is less than would be required on Navy ships of similar type and size.

Dry firemains are not charged and do not provide instantaneous water pressure. These
systems are periodically tested as part of the planned maintenance system (PMS) and are
pressurized during training exercises.

2.2 Releases to the Environment

Seawater discharged overboard from the firemain contains entrained or dissolved
materials, principally metals, from the components of the firemain system. Some traces of oil or
other lubricants may enter the seawater from valves or pumps.
Firemain Systems
3
-------
Fire fighting, space dewatering using eductors, counterflooding, and countermeasure
washdown constitute emergency discharges from the firemain, and are not incidental to the
vessel's operation. Some auxiliary machinery is provided with backup emergency cooling from
the firemain. Use of the firemain for backup emergency cooling is not an incidental discharge.
Seawater from the firemain is released to the environment as an incidental discharge for the
following services:

• Test and maintenance;
• Training;
• Cooling water for auxiliary machinery and equipment, for which the firemain is the
normal cooling supply. Examples are central refrigeration plants, steering gear
coolers, and the Close In Weapon System;
• Bypass flow overboard from the pump outlet, to prevent overheating of fire pumps
when system demands are low; and
• Anchor chain washdown.

The following are incidental services provided from the firemain, but the release to the
environment is discussed separately as shown:

• Ballast tank filling (Clean Ballast NOD report);
• Flushing water for commodes (Black Water[sewage]; not part of the UNDS study);
• Flushing water for food garbage grinders (Graywater NOD report);
• Stem tube seals lubrication (Stern Tube Seals & Underwater Bearing Lubrication
NOD report); and
• AFFF (AFFF NOD report).

2.3 Vessels Producing the Discharge

All Navy surface ships use wet firemain systems with the exception of two classes of
oceanographic research ships. Submarines use dry systems. Boats and craft are not equipped
with firemain systems and generally use portable fire pumps or fire extinguishers for fire
fighting. Most ships operated by the MSC use dry firemain systems, so they do not continuously
discharge water overboard as part of normal operations; however, two classes of ships use wet
firemains. These classes are ammunition ships (T-AE) and combat stores ships (T-AFS). The
USCG and Army use dry firemain systems, so they do not continuously discharge water
overboard as part of normal operations. Table 1 lists the ships and submarines in the Navy,
MSC, USCG, and Army, and notes whether their firemain systems are the wet or dry type.
3.0 DISCHARGE CHARACTERISTICS

Firemain Systems
4
-------
3.1 Locality

Firemain discharge occurs both within and beyond 12 nautical miles (n.m.) of shore.

3.2 Rate

The flow rates for wet firemain discharge depend on the type, number, and operating time
of equipment and systems that use water from the firemain. Operating times of many systems are
highly variable. Some connected services, such as refrigeration plants, are operated
continuously; others, such as hydraulics cooling or aircraft carrier jet blast deflectors, are
operated only during specific ship evolutions. Ships with auxiliary seawater cooling systems
tend to have relatively few services that draw continuous flow from the firemain. For these
ships, the firemain discharge will be small compared to the discharge from the seawater cooling
system. Table 2 shows the theoretical upper bound estimate of discharge from wet firemain
systems, with an estimated total annual volume of approximately 18.6 billion gallons. The
estimate is considered an upper bound because, for most ships, all flow from the fire pumps is
assumed to be an environmental release attributable to the firemain system.

Sample calculation for Table 2:
ISVjC^ffii^*^ 12 n.m./yjr) ~ gal/yr
The discharge from dry firemains is approximately 0.1% of the discharge from wet
firemains because none of the discharge is continuous. A theoretical upper bound estimate for
discharges from dry systems within 12 n.m. is given in Table 3.

Sample calculation for Table 3:
(Qty of ships)(Flow rate (gpm))(tO minute$/wk)(Days within 12 n.m./yr)(l wk/7 days) = gal/yr
The 10 minutes/week is based on a minimum of 2 pumps required by USCG regulations,
in addition to a run time of 5 minutes/week per pump based upon equipment expert
knowledge.5'6'7

3.3 Constituents

The water for firemain services is drawn from the sea and returned to the sea. Metals and
other materials from the firemain and its components can be dissolved by the seawater. Table 4
lists such metals and other materials. Where seawater flow is turbulent, particles of metal will be
eroded from pump impellers, valve bodies, and pipe sections, and carried in the firemain as
entrained particles.8 Electrochemical corrosion attacks at the junctions of dissimilar metals to
produce both dissolved and particulate metals. Any wetted material in the system can contribute
dissolved or particulate constituents to the firemain discharge. These constituents can include
copper, nickel, aluminum, tin, silver, iron, titanium, chromium, and zinc. Based on knowledge

Firemain Systems
5
-------
of the system, the principal expected constituents that are priority pollutants would be copper,
nickel, and zinc. Copper and nickel are found in the piping of wet firemain systems, and
sacrificial zinc anodes are placed in some sea chests and heat exchangers. None of these
expected constituents are bioaccumulators.

Most dry type firemain systems are constructed of steel pipe, without zinc anodes.
Therefore, copper, nickel and zinc are not expected constituents of dry type firemain systems.

3.4 Concentrations

The firemain systems of three ships were sampled for 26 metals (total and dissolved),
semi-volatile organic compounds, polychlorinated biphenyls (PCBs), and classical constituents.
Only wet firemains were sampled because the volumes discharged by wet firemains comprise the
vast majority of the total volume of the discharge. The firemains were sampled both at the inlet
and at the discharge to determine what constituents were contributed by the firemain system.
The three ships sampled were a dock landing ship, an aircraft carrier, and an amphibious assault
ship. Details of the sampling effort and the sampled data are described in the Sampling Episodes
Report for seawater cooling. Table 4 summarizes the results.

Variability is expected within this discharge as a result of several factors including
material erosion and corrosion, residence times, passive films, and influent water variability.
Pipe erosion is caused by high fluid velocity, or by abrasive particles entrained in the seawater
flowing at any velocity. In most cases of pipe erosion, the problematic high fluid velocity is a
local phenomenon, such as would be caused by eddy turbulence at joints, bends, reducers,
attached mollusks, or tortuous flow paths in valves. Passive films inhibit metal loss due to
erosion. Corrosion is influenced by the residence time of seawater hi the system, temperature,
biofouling, constituents hi the influent, and the presence or absence of certain films on the pipe
surface. All of these influences on metallic concentrations are variable within a given ship over
time, and between ships.

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented hi Section 4.1. hi Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria.
Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of non-
indigenous species is discussed.

4.1 Mass Loadings

Mass loadings are shown hi Table 5. The concentrations of constituents contributed by
the firemain system were combined with the estimated annual firemain discharge from Table 2
for wet firemains to determine mass loadings by the equation:
Firemain Systems
6
-------
Mass Loading (Ibs/yr) = (Table 4 net log normal mean concentration ;. „
(Table 2 discharge volume (IS.o" biiBonga!/yr))(3.785 L/gal)(2.205 lbs/kg)(10'9kg/^g).
Dry firemains were not sampled. Most dry firemain systems are constructed of steel, so
the principal expected metallic constituent will be iron. The discharge rate from dry firemain
systems is about 0.1% of the rate from wet firemain systems, so the mass loadings should also be
much less. Accordingly, the mass loadings from dry firemain systems were not included in the
mass loading estimates.

4.2 Environmental Concentrations

Table 6 compares measured constituent concentrations with Federal and the most
stringent state chronic water quality criteria (WQC). The comparison in Table 6 shows that the
effluent concentrations of bis(2-ethylhexyl) phthalate, nitrogen (as nitrate/nitrite and total
nitrogen), copper, iron, and nickel exceed WQC. The copper and nickel contributions each
exceed both the Federal and most stringent state criteria. The ambient copper concentration in
most ports exceeds the chronic WQC. As mentioned previously, copper and nickel constitute the
major construction materials for wet firemains in the Navy. Bis(2-ethylhexyl) phthalate, nitrogen,
and iron concentration exceeds the most stringent state chronic criterion.

4.3 Thermal Effects

As mentioned previously, portions of the firemain are used for seawater cooling purposes
and will discharge excess thermal energy to receiving waters. The thermal plume from firemains
was not modeled directly; however, firemain discharge can be compared to a discharge that was
modeled, such as seawater cooling water from an Arleigh Burke Class (DDG 51) guided missile
destroyer. The use of DDG51 flow parameters for seawater cooling will overestimate the size of
the thermal plume because all vessels have firemain discharge rates less than the estimated
pierside seawater cooling rate of 1,680 gpm for a DDG 51 class ship. Additionally, the
temperature difference (delta T) between the effluent and influent for firemain is lower
(measured at 5°F) than the delta T for seawater cooling from a DDG 51 class ship (measured at
The seawater cooling water discharge was modeled using the Cornell Mixing Zone
Expert System (CORMK) to estimate the plume size and temperature gradients in a receiving
water body using conditions tending to produce the largest thermal plume. Thermal modeling
was performed for the DDG 51 in two harbors (Norfolk, Virginia; and Bremerton, Washington).
Of the five states that have the largest presence of Armed Forces vessels, only Virginia, and
Washington have established thermal mixing zone criteria.9 The discharge was also assumed to
occur in winter when the discharge would produce the largest thermal plume. Based on
modeling for a DDG 51 class ship, the resulting plume did not exceed the thermal mixing zone
requirements for Virginia or Washington.9

All vessels.have firemain discharge rates less than the seawater cooling discharge rate,
and delta T's less than the measured temperature difference associated with a DDG 51.

Firemain Systems
7
-------
Therefore, the heat rejection rate from any firemain system will be lower than that of a DDG 51
class ship for seawater cooling water. Accordingly, the resulting thermal plume for the firemain
discharge is not expected to exceed the thermal criteria for, Virginia or Washington and adverse
thermal effects are not anticipated.

4.4 Potential for Introducing Non-Indigenous Species
.•
Wet and dry firemain systems have a minimal potential for transporting non-indigenous
species, because the residence times for most portions of the system are short. Some portions of
the system lie stagnant where marine organisms may reside. However, these areas tend to
develop anaerobic conditions quickly, except at the junctions with the active portions of the
system, where oxygenated water continuously flows by and through the ship. Anaerobic
conditions are not hospitable to most marine organisms. Additionally, firemain systems do not
transport large volumes of water over large distances.
5.0 CONCLUSIONS

Firemain discharge has the potential to cause an adverse environmental effect because the
concentrations of Bis(2-ethylhexyl) phthalate, nitrogen, copper, nickel, and iron exceed federal or
most stringent state water quality criteria and the estimated annual mass loadings for these metals
are significant. The thermal effects of this discharge were reviewed and are not significant. The
potential for introducing non-indigenous species is minimal.
6.0 REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge and sampling was
performed to gather results related to the constituents and concentrations of the discharge. Table
7 shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes. Firemain System Discharge. 8 October,
1996.

2. Naval Sea Systems Command, Design Practice and Criteria Manual for Surface Ship
Firemain Systems, 1988.

3. Naval Sea Systems Command, Commercial General Specifications for T-ships of the
United States Navy, 1991 Ed. 15 March 1991.

4. Code of Federal Regulations, 46 CFR Parts 34, 76, and 95.
Firemain Systems
8
-------
5.

9.
Code of Federal Regulations, 46 CFR Part 34. 10-5.

Weersing, Penny, Military Sealift Command Central Technical Activity. Dry firemain
discharge within 12 n.m., 17 March 1997, David Eaton, M. Rosenblatt & Son.

Fischer, Russ, Army. Dry Firemain Discharge within 12 n.m., 13 March 1998, Ayman
Ibrahim, M. Rosenblatt & Son.

The International Nickel Company, Guidelines for Selection of Marine Materials 2nd
Ed., May 1971.

NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed
Services. Versar, Inc. July 3,1997.
General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Texas. Texas Surface Water Quality Standards, Sections 307.2-307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Van der Leeden, et al. The Water Encyclopedia, 2nd Ed. Lewis Publishers: Chelsea, Michigan,
1990.

Malcolm Pirnie, Inc. UNDS Phase 1 Sampling Data Report, Volumes 1 through 13, October
1997.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register,?. 15366. March23,1995.
ii
UNDS Ship Database, August 1,1997.
Firemain Systems
10
-------
Table 1. Wet and Dry Firemains of the Navy, MSC, USCG, and Army
, Class
{

SSBN
SSN
SSN
SSN
SSN
cv
CVN
CV
CVN
CGN
CG
CGN
DDG
DDG
DD
FFG
LCC
LHD
LHA
LPH
LPD
LPD
LPD
LSD
LSD
LSD
MCM
MHC
PC

AGF
AGF
AO
AOE
AOE
ARS
AS
AS
AGOR
AGOR

T-AE
T-AFS
T-ATF
T-AO
Description - " ; x
/* , * \
Navy Ships
Ohio Class Ballistic Missile Submarines
Sturgeon Class Attack Submarines
Los Angeles Class Attack Submarines
Narwhal Class Submarine
Benjamin Franklin Class Submarines
Forrestal Class Aircraft Carrier
Enterprise Class Aircraft Carrier
Kitty Hawk Class Aircraft Carriers
Nimitz Class Aircraft Carriers
Virginia Class Guided Missile Cruiser
Ticonderoga Class Guided Missile Cruisers
California Class Guided Missile Cruisers
Kidd Class Guided Missile Destroyers
Arleigh Burke Class Guided Missile Destroyers
Spruance Class Destroyers
Oliver Hazard Perry Guided Missile Frigates
Blue Ridge Class Amphibious Command Ships
Wasp Class Amphibious Assault Ships
Tarawa Class Amphibious Assault Ships
Iwo Jima Class Assault Ships
Austin Class Amphibious Transport Docks
Amphibious Transport Docks
Amphibious Transport Docks
Whidbey Island Class Dock Landing Ships
Harpers Ferry Dock Landing Ships
Anchorage Class Dock Landing Ships
Avenger Class Mine Countermeasure Vessels
Osprey Class Minehunter Coastal Vessels
Cyclone Class Coastal Defense Ships
Navy Auxiliary Ships
Raleigh Class Miscellaneous Command Ship
Austin Class Miscellaneous Command Ship
Jumboised Cimarron Class Oilers
Supply Class Fast Combat Support Ships
Sacramento Class Fast Combat Support Ships
Safeguard Class Salvage Ships
Emory S Land Class Submarine Tenders
Simon Lake Class Submarine Tender
Gyre Class Oceanographic Research Ship
Thompson Class Oceanographic Research Ships
Military Sealift Command
Kilauea Class Ammunition Ships
Mars Class Combat Stores Ships
Powhatan Class Fleet Ocean Tugs
Henry J Kaiser Class Oilers
Quantity of
Vessels

17
13
56
1
2
1
1
3
7
1
27
2
4
18
31
43
2
4
5
2
3
2
3
8
3
5
14
12
13

1
1
. 5
3
4
4
3
1
1
2

8
8
7
13
Wet/Dry

Dry
Dry
Dry
Dry
Dry
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet

Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Dry
Dry

Wet
Wet
Dry
Dry
Firemain Systems
11
-------
Class
T-AGM
T-ARC
T-AKR
T-AKR
T-AGOS
T-AGOS
T-AG
T-AGS
T-AGS
T-AGS
T-AGS

WHEC
WMEC
WMEC
WMEC
WMEC
WMEC
WMEC
WAGE
WAGE
WTGB
WPB
WPB
WLB
WLB
WLB
WLB
WLM
WLM
WLI
WLR
WLR
WLR
WLX
WLIC
WLIC
WLIC
WLIC
WYTL

FMS
LSV
LCU
LT
Description >
Compass Island Class Missile Instrumentation Ships
Zeus Class Cable Repairing Ship
Maersk Class Fast Sealift Ships
Algol Class Vehicle Cargo Ships
Stalwart Class Ocean Surveillance Ships
Victorious Class Ocean Surveillance Ships
Mission Class Navigation Research Ships
Silas Bent Class Surveying Ships
Waters Class Surveying Ship
McDonnell Class Surveying Ships
Pathfinder Class Surveying Ships
Coast Guard
Hamilton and Hero Class High Endurance Cutters
Storis Class Medium Endurance Cutter
Diver Class Medium Endurance Cutter
Famous Class Medium Endurance Cutters, Flight A
Famous Class Medium Endurance Cutters, Flight B
Reliance Class Medium Endurance Cutters, Flight A
Reliance Class Medium Endurance Cutters, Flight B
Mackinaw Class Icebreaker
Polar Class Icebreakers
Bay Class Icebreaking Tugs
Point Class Patrol Craft
Island Class Patrol Craft
Juniper Class Seagoing Buoy Tenders
Balsam Class Seagoing Buoy Tenders, Flight A
Balsam Class Seagoing Buoy Tenders, Flight B
Balsam Class Seagoing Buoy Tenders, Flight C
Keeper Class Coastal Buoy Tenders
White Sumac Class Coastal Buoy Tenders
Inland Buoy Tenders
River Buoy Tenders, 1 15-foot
River Buoy Tenders, 75-foot
River Buoy Tenders, 65-foot
Eagle Class Sail Training Cutter
Inland Construction Tender, 115-foot
Pamlico Class Inland Construction Tenders
Cosmos Class Inland Construction Tenders
Anvil and Clamp Classes Inland Construction Tenders
65 ft. Class Harbor Tugs
Army
Floating Machine Shops
Frank S. Besson Class Logistic Support Vessels
2000 Class Utility Landing Craft
Inland and Coastal Tugs
Quantity of
Vessels
1
1
3
8
5
4
2
2
1
2
4

12
1
1
4
9
5
11
1
2
9
36
49
2
8
2
13
2
9
6
1
13
6
1
1
4
3
7
11

3
6
48
25
Wet/Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry

Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry

Dry
Dry
Dry
Dry
Firemain Systems
12
-------
Table 2. Theoretical Upper Bound-Estimate of Annual Wet Firemain Discharge
Class

cv
CVN
CV
CVN
CGN
CG
CGN
DDG
DDG
DD
FFG
LCC
LHD
LHA
LPH
LPD
LPD
LPD
LSD
LSD
LSD
MCM
MHC
PC

AGF
AGF
AO
AOE
AOE
ARS
AS
AS

T-AE
T-AFS

Description, /-, .:
'"'" - ~ ; -------
Table 3. Theoretical Upper-Bound Estimate of Annual Dry Firemain Discharge
Class

SSBN
SSN
SSN
SSN
SSN

AGOR
AGOR

T-ATF
T-AO
T-AGM
T-AH
T-ARC
T-AKR
T-AKR
T-AGOS
T-AGOS
T-AG
T-AGS
T-AGS
T-AGS
T-AGS

WHEC
WMEC
WMEC
WMEC
WMEC
WMEC
WMEC
WAGB
WAGE
WTGB
WPB
WPB
WLB
Description
Navy
Ohio Class Ballistic Missile Submarines
Sturgeon Class Attack Submarines
Los Angeles Class Attack Submarines
Narwhal Class Submarine
Benjamin Franklin Class Submarines
Navy Auxiliary
Gyre Class Oceanographic Research Ship
Thompson Class Oceanographic Research Ships
Military Sealift Command
Powhatan Class Fleet Ocean Tugs
Henry J Kaiser Class Oilers
Compass Island Class Missile Instrumentation Ships
Mercy Class Hospital Ships
Zeus Class Cable Repairing Ship
Maesrk Class Fast Sealift Ships
Algol Class Vehicle Cargo Ships
Stalwart Class Ocean Surveillance Ships
Victorious Class Ocean Surveillance Ship
Mission Class Navigation Research Ships
Silas Bent Class Surveying Ships
Waters Class Surveying Ship
McDonnel Class Surveying Ships
Pathfinder Class Surveying Ships
Coast Guard
Hamilton and Hero Class High Endurance Cutters
Storis Class Medium Endurance Cutter
Diver Class Medium Endurance Cutters
Famous Class Medium Endurance Cutters, Flight A
Famous Class Medium Endurance Cutters, Flight B
Reliance Class Medium Endurance Cutters, Flight A
Reliance Class Medium Endurance Cutters, Flight B
Mackinaw Class Icebreaker
Polar Class Icebreaker
Bay Class Icebreaking Tugs
Point Class Patrol Craft
Island Class Patrol Craft
Juniper Class Seagoing Buoy Tenders
Flow
(GPM)

250
250
250
250
250

50
100

100
200
100
400
100
400
400
200
200
200
200
200
200
200

250
250
250
250
250
250
250
250
250
250
50
50
200
Quantity
ofVessels

17
13
56
1
2

1
2

7
13
2
2
1
3
8
5
4
2
2
1
2
4

12
1
1
4
9
5
11
1
2
9
36
49
16
Days
within
•:'I;2Eum. •

183
183
183
183
183

113
113

127
78
133
184
8
59
350
70
107
151
44
7
96
96

151
167
98
137
164
235
149
365
365
365
157
157
290
Estimated
Annual Volume
- ::.
-------
Class
WLB
WLB
WLB
WLM
WLM
WLI
WLR
WLR
WLR
WIX
WLIC
WLIC
WLIC
WLIC
WYTL

FMS
LSV
LCU
LT

Description
'' ' " * f ~ ~ s
"*. " ' •j. ^
Balsam Class Seagoing Buoy Tenders, Flight A
Balsam Class Seagoing Buoy Tenders, Flight B
Balsam Class Seagoing Buoy Tenders, Flight C
Keeper Class Coastal Buoy Tenders
White Sumac Class Coastal Buoy Tenders
Inland Buoy Tenders
River Buoy Tenders, 115-foot
River Buoy Tenders, 75-foot
River Buoy Tenders, 65-foot
Eagle Class Sail Training Cutter
Inland Construction Tenders, 115 foot
Pamlico Class Inland Construction Tenders
Cosmos Class Inland Construction Tenders
Anvil and Clamp Classes Inland Construction
Tenders
65 ft. Class Harbor Tugs
Army
Floating Machine Shops
Frank S. Besson Class Logistic Support Vessel
2000 Class Utility Landing Craft
Inland and Coastal Tugs

HOW
(GPM)
200
200
200
100
100
100
100
100
100
50
50
50
50
50
50

400
564
500
640

"Quantity
,ofVesse!s
8
2
13
2
9
6
1
13
6
1
1
4
3
27
14

3
6
48
25

Days
within
12 n.m.
290
220
223
323
223
365
365
365
365
188
365
365
365
365
350

350
180
335
295
Total
Estimated
Annual
Volume,
(gal):

Estimated
Annual Volume
(&A)
662,857
125,714
828,286
92,286
286,714
312,857
52,143
677,857
312,857
13,429
26,071
104,286
78,214
703,929
350,000

600,000
870,171
11,485,714
3,371,429
35,992^85

Note:
1. Estimates assume that all discharge is due to maintenance or testing. All fire fighting exercises are assumed to occur
at sea beyond 12 n.m. Maintenance is assumed to occur weekly while vessels are in port, with seawater flowing at the
design rate of the pumps for 5 minutes each week.
Firemain Systems
15
-------
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p
CN

X
tu
X
BIS(2-ETHYL
PHTHALATE
Ss
bo
c
a «
•«t
o c
a> cs
"S g
*° ^H
IS
^§

'&
g
Se
-------
Table 5. Estimated Annual Mass Loadings of Constituents
Constituent*
Bis(2-ethylhexyl)
phthalate
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen*
Copper
Dissolved
Total
Iron
Total
Nickel
Dissolved
Total
Log-normal Mean
InfluentJug/L)
-
60
310

8.43
16.82

348.48

-
-
Log-normal Mean
Effluent (Mg/I;)
22
20
480

24.9
62.4

370

13.8
15.2
Log-normal Mean
Concentration (Mg/L)
22.04
-40
170

16.46
45.59

21.28

13.8 (b)
15.2 (b)
Estimated Annual
Mass Loading (Ibs/yr)
3,414
(a)
26,330
26,330

3,111
8,618

4,022

2,142 (b)
2,360 (b)
1 Mass loadings are presented for constituents that exceed WQC only. See Table 4 for a complete listing of mass
loadings.

Notes:
* Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
(a) - Mass loading was not determined for parameters for which the influent concentration exceeded the effluent
(b) - No background concentration is given for the parameter
Firemain Systems
18
-------
Table 6. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituents
#
T N
Classicals (ng/L)
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen8
Organics (|ig/L)
Bis(2-ethylhexyl)
phthalate
Metals (fig/L)
Copper
Dissolved
Total
Iron
Total
Nickel
Dissolved
Total
Log-normal
• Mean
Effluent

20
480
500

24.9
62.4

370

13.8
15.2
Minimum
'Concentration
Effluent

BDL
230

BDL

BDL
34.2

95.4

BDL
BDL
Maximum
Concentration
-Effluent

400
840

428

150
143

911

38.9
52.1
, ,- Federal
Chronic WQC

None
None
None

None

2.4
2.9

None

8.2
8.3
Most Stringent State
», Chronic WQC

8(HI)A
-
200 (ffl)A

5.92 (GA)

2.4 (CT, MS)
2.9 (GA, FL)

300 (FL)

8.2 (CA, CT)
7.9 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
BDL-Below Detection Level

CA = California
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
Firemain Systems
19
-------
Table?. Data Sources

NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
23 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
4.1 Mass Loadings
4.2 Environmental Concentrations
43 Thermal Effects
4.4 Potential for Introducing Non-
Indigenous Species
Data Sources . •. , :•-• -. -• ;•?" • ••:-•
Reported

UNDS Database

Sampling

X
X

Estimated

Equipment Expert:
X
X
X
X

X
Firemain Systems
20
-------
NATURE OF DISCHARGE REPORT
Freshwater Layup
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed hi three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

This section describes the freshwater layup discharge and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
I
i
2.1 Equipment Description and Operation
j
I
Seawater cooling systems on vessels provide cooling water for propulsion plant and
auxiliary system heat exchangers. Heat exchangers remove heat directly from the main
propulsion machinery and the electrical generating plants, and directly or indirectly from all other
equipment requiring cooling. The primary purpose of the main seawater system is to provide the
coolant to condense low pressure steam from the main turbines and the generator turbines.1
!!
When nuclear-powered submarines and aircraft carriers remain for an extended period
and the seawater cooling systems are not circulated, the main condensers are placed in a
freshwater layup.1 The purpose of placing the condensers in a freshwater layup is to prevent the
accumulation of biological growth and the resultant loss of condenser efficiency while the
seawater cooling system is not in use. The propulsion plants of nuclear-powered vessels
generally require a 2- to 3-day cooling down period prior to being laid up.1

The layup is accomplished by blowing the seawater from the main condensers with low
pressure air and isolating the condensers.1 The condensers are then filled with potable water
from port facilities, a process that takes 1 to 2 hours, or more, to complete.2 The potable water
remains in the condensers, uncirculated, for approximately 2 hours. After this period of time, the
potable water fill is blown overboard with low pressure air, which takes approximately an hour to
accomplish.112 The condensers are then considered flushed of any residual seawater (seawater or
potable water). The condensers are then refilled with potable water for the actual layup. This
process can be referred to as a double fill and flush cycle.
j
' i
After 21 days, the initial fill water is discharged overboard and replaced. The layup is
discharged and refilled on a 30-day cycle thereafter.1 This process can be referred to as a refill
cycle. The freshwater layup may be terminated at any point during these cycles to support
equipment maintenance or ship's movement.

During a ship check and sampling episode aboard USS Scranton (SSN 756), it was
observed that the main seawater condensers were filled indirectly with freshwater from port
facilities.3 The crew filled the forward potable water tank from the pier connection and then
transferred the freshwater to the aft potable water tank.3 The main condensers were then put in
freshwater layup from the aft potable water tank.3 The initial freshwater layup process lasted
greater than 5 hours (e.g., from the beginning of initial fill to initiating the low pressure air blow
to remove the initial freshwater flush).3
!|
The main steam condensers on submarines are constructed either of titanium or 70/30
copper/nickel alloy.4 Aircraft carrier main seawater condensers are constructed of 90/10
Freshwater Layup
2
-------
copper/nickel alloy. The condenser boxes for the 70/30 copper/nickel alloy condensers are
constructed of a nickel/copper alloy and can be lined with a tin/lead solder and have zinc anodes
installed for corrosion control.4 The seawater piping that carries cooling water from the
condensers to overboard discharge is constructed of 70/30 copper/nickel piping.4

2.2 Releases to the Environment

These discharges occur in port at pierside when the submarine's nuclear power plant has
cooled and the main seawater cooling system is unable to be circulated for more than 3 days.
Also, this discharge can occur if the ship will be hi port for greater than 7 days (i.e., It takes 72
hours to cool down a reactor and 72 hours to ramp up a reactor which translates to six days, or
roughly one week.) and the seawater cooling system can not be circulated. The freshwater is
discharged from the seawater cooling piping openings located below the waterline of the ship.
The discharge occurs when the fresh water is pushed out by low pressure air applied to the
seawater cooling piping system. It is expected that this discharge will contain many of the
constituents found in the fresh water (typically supplied by port facilities) used for the layup, as
well as metals leached from the ship's piping system while the water is held during the layup,
and any residual seawater remaining in the system after the double fill and flush.

2.3 Vessels Producing the Discharge

All attack submarines (SSNs), ballistic missile submarines (SSBNs), and nuclear-
powered carriers (CVNs) generate this discharge. A total of 89 SSNs and SSBNs, and eight
CVNs are currently in service in the Navy. While the three existing nuclear guided missile
cruisers (CGNs) also produce this discharge, these are scheduled to be removed from service by
2003/2004, and therefore, will not be considered further. The Navy is the only member of the
Armed Forces that operates nuclear-powered vessels.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

This discharge only occurs when vessels are in port.

3.2 Rate

The volume of the initial fill and flush of a nuclear-powered submarine is approximately
6,000 gallons of freshwater. This 6,000 gallons of freshwater is discharged overboard after a 1-
to 2-hour layup in the main seawater condensers and refilled with an additional 6,000 gallons of

Freshwater Layup
3
-------
freshwater as described in Section 2.1.5 The total volume of freshwater required for the fill,
flush, and refill of the condenser for freshwater layup on nuclear submarines is approximately
12,000 gallons, of which 6,000 gallons is discharged overboard.5 The volume of this discharge
will vary with the volumes of the main steam condensers for each submarine class.5

The amount of time that a submarine is in port, and hence, the number of layup cycles
required, is dependent upon many factors, the most critical being the submarine's current
mission. Each mission requires varying times in port for preparation, repairs, or modifications to
support the mission specifics. In addition, many submarines undergo overhauls or other
maintenance and/or repair activities that extend their time in port (e.g., must put their seawater
systems into a dry layup condition).
i
i!
Attack submarines (SSNs) average about 10 layup cycles per year, including five double
fill and flush cycles and five refill cycles.5 Each double fill and flush cycles and each refill cycle
discharges approximately 6,000 gallons of freshwater per evolution. This results in 60,000
gallons of freshwater for each of the Navy's 72 SSNs per year. Therefore, fleet-wide discharge
for the SSNs is 4,320,000 gallons of freshwater layup discharge per year, of which half is from
the initial fill and half is from the refill cycles, or 2,160,000 gallons for each.

Ballistic missile submarines (SSBNs) have extended layovers of 1 to 1 1/2 months
approximately three or four tunes per year. The volume of seawater systems in ballistic missile
submarines are comparable to those of attack submarines. These submarines have an estimated
three initial flush and fill cycles per year and approximately six refill cycles per year. For an
SSBN, this totals 54,000 gallons per submarine per year. The Navy operates 17 SSBNs.
Therefore, the total freshwater layup discharged for all SSBNs is estimated to be 918,000 gallons
per year, of which 306,000 gallons is from the initial fill and flush and 612,000 gallons is from
refill cycles.

A total estimated volume of 5,238,000 gallons of freshwater layup is discharged in U.S.
ports from the 89 SSN and SSBN hulls. The initial fill cycle accounts for 2,466,000 gallons and
the refill cycles account for 2,772,000 gallons.

Nuclear powered aircraft carriers do establish freshwater layups in their various
condensers, but the effluent is dumped into the bilges of the ship rather than being discharged
directly overboard. Hence, the residual water from the aircraft carriers' layup is covered under
the Surface Vessel Bilgewater/OWS Nature of Discharge report.

3.3 Constituents

The freshwater used hi the freshwater layup can contain disinfectants from potable water
treatment. The most common disinfectant is chlorine. Some municipalities, however, are
switching over to chloramine disinfection to reduce the amount of disinfectant by-products
formed. This switch could be permanent or seasonal, with the chloramines added during the
warmer months when formation of disinfectant by-products are more prevalent. It is noted that
Freshwater Layup
4
-------
the constituent make-up of the freshwater used to conduct the layup will have a significant effect
on the discharge.

The constituents that can be present in freshwater layup from nuclear-powered
submarines include: copper, lead, nickel, chlorine, ammonia, nitrogen (as nitrate/nitrite, and total
kjeldahl nitrogen), phosphorous and related disinfectants, chromium, tin, titanium and zinc.
Chromium, copper, lead, nickel, and zinc are priority pollutants. None of these constituents are
bioaccumulators. The freshwater layup of a single submarine was sampled to determine the
constituents that are present in the discharge.

3.4 Concentrations

The water used to fill the main condensers, the initial layup discharge, and an extended,
21-day discharge were sampled from USS Scranton (SSN 756).3 A total of 17 metals were
measurable in the initial and extended layup discharges from the sampling event. The vast
majority of the metals detected have sources from either the materials within the main steam
condenser or from the domestic water treatment/distribution system. The metals and classical
parameters detected in the discharge are compiled in Table 1. In addition, the mass loadings are
estimated for those constituents that were detected in either the 2-hour or 21-day layup
discharges. Three priority pollutant metals, copper, nickel and zinc, were detected in the
discharge at elevated concentrations. Total chlorine was also detected in the initial layup
discharge (28 |ig/L), but not in the discharge after 21 days. The domestic water from the pier
connection was also sampled for total and free residual chlorine levels and contained 1,200 jj.g/L
and 1,000 p.g/L, respectively.3 Nitrogen (as nitrate/nitrite, and total kjeldahl nitrogen), ammonia,
and phosphorous were detected in both the 2-hour layup and the 21-day layup discharges.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Based upon the concentrations of the metals reported for the layup effluents in Table 1
and the estimated discharge volumes in Section 3.2, the mass loadings were calculated using the
estimated volumes of freshwater layup discharge in Table 2 for those constituents that exceeded
either Federal or most stringent state water quality criteria (WQC). Table 3 highlights the
constituents that exceed WQC. The estimated mass loadings, provided in Table 2, are derived by
adding together contributions from both the initial fill volumes and the refill cycle volumes,
because the two portions of the effluent have different concentrations.
Freshwater Layup
5
-------
(cone. ug/L)(g/l,000,000 jig) (lbs/453.593 g) (annual volume gal/yr) (3,785 Vgal) ••
mass loading (Ibs/yr)
Based on the sampling data, the total fleet-wide loadings of ammonia, nitrogen, chlorine,
copper, nickel, phosphorous, and zinc from this discharge are approximately 41, 55,1, 7, 36, 8,
and 29 pounds per year, respectively.
i
. . !
4.2 Environmental Concentrations

The discharge concentrations presented hi Table 3 are compared to Federal and most
stringent state WQC.

Copper was present in the fill water from the aft potable water tank, but it is unknown if
copper was present in domestic water from the pier connection. The fill water copper
concentrations exceeded Federal and the most stringent state. Copper is normally present in the
domestic water supply in concentrations that exceed WQC because of the presence of copper-
constructed components in drinking water distribution systems. The levels of copper can be
partially attributable to the construction of the potable water systems on board the submarine
through which the domestic water was routed prior to filling the main seawater condensers.
These systems have copper piping and brass valves that can contribute copper to the water.

Table 3 shows the concentrations of the three priority pollutant metals (copper, nickel,
and zinc) that exceed Federal and most stringent state WQC. The chlorine concentration from
the initial 2-hour layup exceeds the most stringent state criterion. Ammonia, total nitrogen (as
nitrate/nitrite, and total kjeldahl nitrogen), and total phosphorous concentrations in the two layup
discharges exceed the most stringent state criterion. The presence of phosphorous in the effluent
appears to be from the domestic water as the effluent concentrations for total phosphorous shows
no increase over the fill water concentrations.
i
4.3 Potential for Introducing Non-Indigenous Species

There is no movement of the vessel during the layup process and the water used for the
layup is chlorinated domestic water from shore facilities. As such, there is no potential for
transporting non-indigenous species.
5.0 CONCLUSION

Freshwater layup of seawater cooling systems has a low potential of adverse
environmental effects for the following reasons.
i
1. The mass loadings of chlorine, copper, nickel, and zinc are small although the
concentrations exceed Federal and most stringent state WQC. The mass loadings
of ammonia, nitrogen, and phosphorous are also small, but concentrations exceed
the most stringent state WQC. The total annual mass loadings for ammonia,
i
Freshwater Layup
6
-------
2.
nitrogen, chlorine, copper, nickel, phosphorous, and zinc contribute
approximately 41, 55,1, 7, 36, 8, and 29 pounds, respectively. The 89 submarines
producing this discharge are geographically dispersed over seven ports.

There is no potential for the transfer of non-indigenous species.
6.0 DATA SOURCES AND REFERENCES

Process knowledge and sampling of this discharge were used in preparing this NOD
report. Table 4 shows the sources of data used to develop this NOD report. The specific
references cited in the report are shown below.

Specific References

1. Kurz, Rich, NAVSEA 92T251. UNDS Equipment Expert Meeting Structured Questions.
Main Sea Water System Freshwater Layup. September 5,1996.

2. Versar Notes, UNDS Freshwater Layup Sampling Meeting. NAVSEA. May 23,1997.

3. UNDS Phase I Sampling Data Report, Volumes 1 - 13. October 1997.

4. Bredehorst, Kurt, NAVSEA 03L. Materials Within the Seawater Side of Main
Condenser. September 1996. Miller, Robert B, M. Rosenblatt & Son, Inc.

5. Miller, Robert B., M. Rosenblatt & Son, Inc. Personal Communications on Nature of
Discharge Report: Freshwater Layup, Submarine Main Steam Condensers. January
1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
;|
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.
i
New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
;i
Virginia, Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
i
UNDS Equipment Expert Meeting Minutes. Seawater Cooling Water Overboard. August 27,
1996.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
ii
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, pg. 15366. March 23,1995.

Kurz, Rich, NAVSEA 92T251. Submarine Main Steam Condenser Freshwater Layup E-mail.
November 1996. H. Clarkson Meredith, HI, Versar, Inc.

Jane's Fighting Ships, Capt. Richard Sharpe, Ed., Jane's Information Group, Sentinel House:
Surrey, United Kingdom, 1996.
!l
UNDS Ship Database, August 1,1997.
Freshwater Layup
8
-------
Table 1. Summary of Detected Analytes
Constituent .
Classicals *
Alkalinity
Ammonia as Nitrogen
Chemical Oxygen Demand (COD)
Chloride
Nitrate/Nitrite
Sulfate
Total Chlorine
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (TOC)
Total Phosphorous
Total Recoverable Oil and Grease
Total Sulfide (lodometric)
Volatile Residue
Metals '-"
Aluminum
Dissolved
Total
Arsenic
Dissolved
Barium
Dissolved
Total
Beryllium
Dissolved
Boron
Dissolved
Total
Calcium
Dissolved
Total
Copper
Dissolved
Total
Lead
Dissolved
Total
Magnesium
Dissolved
Total
Manganese
Dissolved
Total
Nickel
Dissolved
Freshwater
Influent
• (mg/L)
26
0.17
12
20
0.62
21
1.2
140
0.70
2.70
0.22
1.0
6
76
(Hg/L> -

BDL
109

BDL

35.5
36.2

BDL

BDL
BDL

15700
16000

135
136

BDL
2.3

2720
2860

BDL
6.3

BDL
2-Btour
Freshwater
Effluent
(mg/L)
27
1.3
BDL
63
0.68
22.8
0.028
232
0.63
2.7
0.19
BDL
3.0
165
"(vsM

57.7
43.9

0.8

27.5
28.10

BDL

36.8
37.5

17050
16750

137
150

BDL
2.0

6880
6890

19.7
21.8

409
21-Day
Freshwater
Effluent
(mg/L)
46
0.6
48
34
0.4
17
BDL
82
0.81
25
0.19
1.0
BDL
BDL
Oig/L)

BDL
BDL

BDL

25.6
26.3

0.75

BDL
BDL

19800
20400

107
148

3.45
4.75

5185
5495

276
310

1175
Frequency of
Detection

lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
•\

lofl
lofl

lofl

lofl
lofl

lofl

lofl
lofl

lofl
•Mass Loading
• (Ibs/yr) '
1,616
41
1,108
2,078
23
861
0.58
6,657
32
633
8.3
23
62
3,388
(Ibs/yr)

1.19
0.90

0.016

1.16
1.19

0.017

0.76
0.77

807
815

5.3
6.5

0.08
0.15

261
268

6.8
7.6

35.6
Freshwater Layup
9
-------
Total
Selenium
Dissolved
Total
Sodium
Dissolved
Total
Thallium
Dissolved
Total
Tin
Dissolved
Total
Zinc
Dissolved
Total
Organics
BSs(2-ethylhexyl) phthalate
BDL

BDL
BDL

10500
10500

BDL
1.3

5.1
4.2

137
127
Otg/L)
137
433

BDL
BDL

39200
37550
&
0.75
BDL

BDL
BDL

463
451
-------
Table 2: Estimated Annual Mass Loadings for Freshwater Layup Discharge
s /
~ , ^Analyte
Annual Volume (gal/yr):
Copper
Dissolved
Total
Nickel
Dissolved
Total
Zinc
Dissolved
Total
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*"
Total Chlorine
Total Phosphorous
2-hr Layup
•Cone. .,
-------
Table 3: Mean Concentrations of Constituents Exceeding Water Quality Criteria
Constituent
Metals (ug/L)
Copper
Dissolved
Total
Nickel
Dissolved
Total
Zinc
Dissolved
Total
Classical (rag/L)
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
Total Chlorine
Total Phosphorous
2-Hour Layup
Concentration

137
150

409
433

463
451

1.3
0.68
0.63
1.31
0.028
0.19
21-Day Layup
Concentration

107
' 148

1175
1175

784
851

0.6
0.4
0.81
1.21
-
0.19
Federal Acute
woe

2.4
2.9

74
74.6

90
95.1

None
None
None
None
None
None
Most Stringent State
Acute WQC

2.4 (CT, MS)
2.5 (WA)

74 (CA, CT)
8.3 (FL, GA)

90 (CA, CT, MS)
84.6 (WA)
--•"'--. '-.-••- •'• •'•-••-•>-'••:• •'•:•,':
0.006 (ffl)A
0.008 (ffl)A
-
0.2 (HI)A
0.010 (FL)
0.025 (HI)A
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA = California
CT =• Connecticut
FL = Florida
GA = Georgia
HI «* Hawaii
MS = Mississippi
WA •" Washington
Freshwater Layup
12
-------
Table 4. Data Sources
V
NOD Section
2.1 Equipment Description and
3Operation / - -
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge *
3.1 Locality
3.2 Rate
3,3 Constituents _ - ,
3.4 Concentrations
4.1 Mass Loadings - - -
4.2 Environmental Concentrations
4.3 Potential for Introducing Noa- ''
Indigenous Species
- Data Source * .
Reported

UNDS Database

Sampling

X
X
X

Estimated

Equipment Expert
X
X
X
X
X
X

X
Freshwater Layup
13
-------
-------
NATURE OF DISCHARGE REPORT
Gas Turbine Water Wash
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)j. UNDS is being developed in three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

This section describes the gas turbine water wash and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Shipboard gas turbine systems are used on certain vessels to provide propulsion power,
provide initial mechanical starting power for large gas turbine propulsion systems, and to
generate electricity. Power is generated by combusting fuel in a "gas generator" (commonly
referred to as a "combustor"). The combustor exhaust gas rotates the "power turbine," providing
the mechanical energy to either drive a propulsion shaft, start a larger turbine, or generate
electricity.1

Over extended periods of operation, residual lubrication oil and hydrocarbon combustion
by-product deposits can form on gas turbine internals. Since naval vessels operate in a marine
environment, salt water introduced with intake air can also lead to salt deposits on the gas turbine
internals. Washing the gas turbine internals periodically with a solution of freshwater and
cleaning compound maintains operating efficiency and prevents corrosion of the metallic
components. The cleaning compound that is currently used for this purpose is a petroleum-based
solvent referred to as "gas path cleaner."1

Two types of water wash systems exist on vessels with gas turbines. One is a dedicated
"hard-piped" system; the other type requires manual attachment of a hose to a hot water source
and placement of the other hose end into the turbine plenum. Both of these systems are designed
to introduce water wash into the turbine housing while the turbine starter motor is slowly rotated,
(i.e., cranked without combustion). The hard-piped system includes a rinse tank where
distilled/demineralized water and cleaning compound are mixed. The contents of the tank are
sprayed into the gas turbine under pressure, either by using a pump or by pressurizing the tank
with compressed air.1 Immediately following the wash, the engine is sprayed with water.
i|
Gas turbine engines are enclosed in a "module" with floor drains designed to remove
minor leakage of fuel and synthetic lube oil that may occur during normal turbine operation. The
floor drains also remove any water wash introduced into the turbine that is not discharged to the
atmosphere. Water wash from external scrubbing of the gas turbine also flows to these floor
drains. Inadvertent spills of synthetic lube oil that occasionally occur during turbine maintenance
activities are potentially capable of entering the drains; however, standard procedure is for ship
personnel to immediately contain and wipe up any spillage that occurs.1
i
On most Navy ships, gas turbine water wash effluent and any drainage of residual
material from leaks and spills are collected and held in a dedicated tank system for shore
disposal. The Navy refers to this system as the "Gas Turbine Waste Drain Collecting System."
The dedicated system includes a centrifugal pump and piping to transfer the water wash to a hose
connection topside. A hose is used to transfer the water wash to a pierside collection facility. On

Gas Turbine Water Wash
2
-------
vessels without this system, the drainage is discharged to the environment as a component of
other UNDS discharges (i.e., Surface Vessel Bilgewater/OWS, Welldeck, and Deck Runoff).1

The wash water effluent discharge from U.S. Coast Guard (USCG) vessel gas turbine
washing operations is to the bilge, from where it is processed as bilgewater (along with other
bilgewater contributors) through the shipboard OWS prior to overboard discharge. The gas
turbine water wash effluent for USCG vessels is addressed as a component of the Surface Vessel
Bilgewater/OWS Discharge NOD Report.

Gas turbine propulsion engines are also used aboard Navy landing craft air cushion
(LCAC) amphibious landing crafts. Two gas turbine auxiliary power units (APUs) are also
installed on LCACs to provide starter air. The LCAC gas turbine washwater discharge is
addressed as a component of the Welldeck Discharges NOD Report.

Water wash cleaning of aircraft gas turbine engines aboard an aircraft carrier is addressed
as a component of the Deck Runoff NOD Report.

2.2 Releases to the Environment

The water wash introduced into Navy propulsion turbines contains water and solvent-
based gas path cleaner. The discharge could be expected to contain components of the cleaner,
oil and grease (O&G), petroleum-derived fuel and lubricant constituents, synthetic lubricating
oil, constituents introduced into the turbine system with the incoming sea air, hydrocarbon
combustion by-products, and metals leached from gas turbine components. On most gas turbine
Navy and MSC ships, gas turbine washwater is collected in a dedicated tank and not discharged
overboard within 12 n.m. On ships without a dedicated collecting tank, this discharge is a
component of deck Runoff, welldeck runoff, or bilgewater as described in the previous section.

2.3 Vessels Producing the Discharge

Table 1 lists the vessel classes that have shipboard gas turbine systems. Vessel classes
equipped with a Gas Turbine Waste Drain Collecting System are denoted in Table 1. For the
other vessel classes listed in Table 1, the gas turbine water wash is discharged as a component of
another UNDS discharge. The maximum number of vessels with Gas Turbine Waste Drain
Collecting System is 127. Army and Air Force vessels do not have gas turbine engines and do
not generate this discharge.
3.0 DISCHARGE CHARACTERISTICS

Vessels with Gas Turbine Waste Drain Collecting Systems collect and store drainage
from normal turbine operations and water wash effluent for pierside disposal. On most gas
turbine Navy and MSC ships, gas turbine washwater is collected in a dedicated collecting tank
and not discharged overboard within 12 n.m. On ships without a dedicated collecting tank, this
discharge is a component of deck Runoff, welldeck runoff, or bilgewater as described in the
previous section.

3.2 Rate
I
I
Available information on gas turbine water wash usage rates is contained in gas turbine
IJI o •j A
design and operations and maintenance documentation. '' The frequency of water wash
cleanings and the quantity of water wash consumed per washing event is different between
USCG, Navy, and Military Sealift Command (MSC) vessels.

Navy and MSC vessel gas turbines used for propulsion are washed after each 48 hours of
operation or at least once per month.5 Two gallons of the gas path cleaner are initially mixed
with 38 gallons of distilled/demineralized water. Immediately following the wash, the turbine is
spray rinsed with 80 gallons of water. An additional 2 gallons of detergent/water mixture is used
to clean external turbine surfaces, as necessary. Each cleaning of the propulsion turbines
produces 122 gallons of water wash. Therefore a vessel with four propulsion gas turbines each
cleaned once every 48 hours of operation would generate an average of 244 gallons of water
wash per day.

3.3 Constituents

The chemicals used in gas turbine operation and maintenance that could potentially
contribute to contamination of turbine water wash are gas path cleaner, Naval distillate fuel F-76,
gas turbine fuel, JP-5, synthetic lube oil, copper, cadmium, and nickel.
6-10
The gas path cleaners used by the Navy include petroleum distillates (aromatic and
aliphatic hydrocarbons), assorted glycols, detergents, soaps, and water.6'7 The composition of
one such cleaner used by the Navy can be found hi its material safety data sheet (MSDS).6
According to the MSDS sheet, the cleaner can contain the aromatic hydrocarbon naphthalene at
concentrations of up to 3.9%. Other petroleum distillate hydrocarbon constituents that could be
present include aliphatic volatile organic compounds and other semivolatile compounds that are
priority pollutants. The priority pollutants that are potential constituents of gas turbine water
wash are cadmium, copper, nickel, and naphthalene. None of the constituents is a
bioaccumulator.

3.4 Concentrations
I
The addition of gas path cleaner containing 3.9% naphthalene to the wash water at a 2%
gas path cleaner concentration yields an estimated water wash naphthalene concentration of 800
Gas Turbine Water Wash
4
-------
milligrams per liter (mg/L). The following shows this calculation.
-' ,, > Naphthalene Concentration (mg/L) ==?
(% of cleaner in water)(% of naphthalene in cleaner)(density of naphthalene)
.where, " • .,"",' -v-; '• ,«-'/,'>,-_ ;- , : - '" -
% of cleaner in water = 2 ^ ,, ' I,' k?- '-**, - ' ,, -• " ^ x
% of naphthalene in cleaner=3.9 / '•• : ,''"••>„ -* -., ' -, ~
density_of naphthalene = (1.0253 g/cm3)(1000 mg/g)(iOOO cm3/L) = 1.025 * LO6 mg/L

Naphthalene Concentration = (0702X0.039X1.025 * 106) « 800 mg/L
Because naphthalene is a semivolatile organic compound that is not expected to volatilize
while the water wash is sprayed into the turbine, the maximum water wash effluent naphthalene
concentration is also estimated at 800 mg/L. Other constituents are variable and were not
estimated.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. hi Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The water wash volume estimate for a Navy ship propulsion turbine cleaning operation
and naphthalene concentration estimate of 800 mg/L were used to estimate the maximum annual
mass loading. The estimate is based on the assumption that one turbine cleaning for each vessel
is performed each day within 12 n.m.

Mass Loading of Naphthalene (Ibs/yr) ==
(naphthalene conc.)(discharge vol.)(365days/yr)(# vessels) (3.7854 L/gal) (2.2 Ib/kg) (10"6 kg/mg) -
(800 mg/L)(244 gal/day)(365 days/yr)(127)(3.7854 L/gal)(2.2 lb/kg)(10 kg/mg) « 75,400 Ibs/yr

The mass loading of O&G that can be introduced into the water wash effluent from
within the gas turbine depends on (a) the amount of residue present; and (b) the degree to which
the water wash spray removes the residue as it passes through the turbine.

4.2 Environmental Concentrations

Gas Turbine Water Wash
5
-------
Table 2 shows that the estimated naphthalene concentration exceeds the most stringent
state water quality criteria (WQC) for naphthalene. Concentrations of oil and grease are
expected to exceed WQC because the source of this discharge (gas turbine cleaning) is designed
to dissolve fuel, lubricant, and other hydrocarbon deposits.

4.3 Potential for Introducing Non-Indigenous Species

There is no potential of introduction, transport, or release of non-indigenous species
between different geographical areas, because the water wash system does not use seawater and
therefore does not involve the discharge of seawater originating hi another geographical region.
5.0 CONCLUSIONS

If discharged, gas turbine water wash has the potential to cause an adverse environmental
effect within 12 n.m. because:

1) Estimated concentrations of naphthalene exceed and the most stringent state WQC
and the mass loading of this priority pollutant would be significant; and

2) Concentrations of oil and grease are expected to be significant because the source of
this discharge (gas turbine cleaning) is designed to dissolve fuel, lubricants and other
deposits.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from the following sources was obtained to
develop this NOD report. Table 3 shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes. June, 20,1997.

2. Uniform Maintenance Procedure Card (MFC), WAGE 400 Main Gas Turbine, MPC M-
C-062, Amendment 3.

3. Uniform Maintenance Procedure Card (MPC), WHEC 378 Main Gas Turbine, MPC M-
C-017, Amendment 0.

4. Uniform Maintenance Procedure Card (MPC), WHEC 378 Emergency Generator, MPC
A-W-001, Amendment 0.

5. Maintenance Requirement Card (MRC), OPNAV 4790 (Rev. 2-82).
Gas Turbine Water Wash
6
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6. Gas Path Cleaner Material Safety Data Sheet, supplied by M. Galecki of DDG 51 Flight
Upgrade Office via facsimile to Malcolm Pirnie (C. Geiling) on June 12,1997.

7. Military Specification MIL-C-85704, "Cleaning Compound, Turbine Engine Gas Path".

8 Military Specification MDL-F-16884, "Fuel, Naval Distillate".

9. Military Specification MIL-F-5624, "Turbine Fuel, Aviation, Grades JP-4, JP-5, and JP-
5/JP-8 ST".

10. Military Specification MIL-L-23699, "Lubricating Oil, Aircraft Turbine Engine,
Synthetic Base, NATO Code Number 0-156".

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for rntrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by

Gas Turbine Water Wash
7
-------
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
i
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register,?. 15366. March23,1995.
Gas Turbine Water Wash
8
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Table 1. Vessels With Gas Turbine Systems
Branch
Navy
MSC
USCG
Class
AOE6
CG47
DD963
DDG51
DDG 993
FFG7
MCM1
T-AKR310
WAGE 399
WHEC378
No.'
3
27
31
18
4
43
14
1
2
12
.Vessel Type
Fast Combat Support Ship
Guided Missile Cruiser
Destroyer
Guided Missile Destroyer
Guided Missile Destroyer
Guided Missile Frigate
Mine Countermeasure Vessel
Fast Sealift Ship
Icebreaker
High Endurance Cutter
Comment
Dedicated collection system
Dedicated collection system
Dedicated collection system
Dedicated collection system
Dedicated collection system
Dedicated collection system
Unknown configuration
Dedicated collection system
Discharged to bilge
Discharged to bilge
No. = number of vessels in class
Table 2. Comparison of Gas Turbine Water Wash
Estimated Concentration and Water Quality Criteria (jig/L)
Constituent
Naphthalene
Maximum Estimated -
\ Concentration
800,000
Federal Acute
WQC ' _:
None
Most Stringent State.
Acute WQC
780 (HI)
Notes:
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.

HI = Hawaii
Table 3. Data Sources
NOD Section
2.1 Equipment Description and
Operation
2,2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
• - Data Source
Reported
Equipment Literature
OPNAVINST5090.1B
UNDS Database

Standard Operating
Procedures
MSDS
MSDS

Sampling

Estimated

X
X
X
X
X

Equipment Expert
X
X
X
X
X
X

X
Gas Turbine Water Wash
9
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-------
NATURE OF DISCHARGE REPORT
, „''/; Graywater
1.0 INTRODUCTION

This section describes the graywater discharge and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
!
2.1 Equipment Description and Operation
ij
Graywater is defined in section 312(a) of the Clean Water Act as wastewater from
showers, baths and galleys. On vessels of the Armed Forces, drainage from laundry, interior
deck drains, lavatory sinks, water fountains, and miscellaneous shop sinks is often collected
together with graywater. Therefore, this discharge covers graywater as well as mixtures of
graywater with wastewater from these additional sources.1 In this report, the term "graywater"
will be used to describe all of these related discharges. Graywater is distinct from "blackwater",
the sewage generated by toilets and urinals.

While pierside, most classes of Navy vessels direct graywater to the vessel's blackwater
Collection, Holding, and Transfer (CHT) tanks, via segregated graywater plumbing drains. Some
recently built ships (such as CVN 73 and CVN 74) do not have segregated blackwater/graywater
drains. These ships collect the blackwater/graywater mixture while inside 3 nautical miles
(n.m.). The blackwater and graywater mixture is then pumped to pierside connections for
treatment ashore. A typical CHT system is shown in Figure 1. Most navy surface vessels
without CHT systems have dedicated graywater tanks and pumps to collect and transfer this
discharge to shore facilities. Some vessels lack the means to collect all the graywater that is
generated while pierside. On these vessels a portion of the graywater plumbing drains run
directly overboard.1"4
I
While operating away from the pier, most Navy surface vessels that collect graywater in
CHT tanks divert graywater drains overboard to preserve holding capacity for blackwater in the
tanks. Vessels equipped with separate graywater collection and transfer systems are not designed
to hold graywater for extended periods of time and therefore drain or pump their graywater
overboard while operating away from the pier.

Submarines collect their graywater in the ship's sanitary tank while pierside and within 3
n.m. of land. Pierside, graywater mixed with blackwater is discharged to a shore facility for
treatment; when outside 3 n.m., graywater is discharged directly overboard. Unlike surface
vessels, holding capacity in the submarines' sanitary tanks is generally sufficient to allow
collection of graywater and blackwater up to 12 n.m. from shore.1
i

All Military Sealift Command (MSC) vessels are equipped with U.S. Coast Guard
(USCG) certified Marine Sanitation Devices (MSDs) designed to treat sewage to EPA and
USCG standards. On some MSC vessels, graywater can be collected and sent to the MSD for
processing, or diverted overboard. On other MSC vessels, graywater is neither collected nor
treated, but is discharged directly overboard.
Graywater
2
-------
Most USCG vessels are similar to Navy vessels since they can collect graywater while
pierside. However, some USCG vessels currently cannot collect graywater, but continually
discharge it overboard.

The majority of Army vessels collect graywater together with blackwater (sewage)* for
treatment by a USCG certified MSD. The MSD effluent is either sent overboard, held in an
effluent holding tank, or discharged to a shore facility.

2.2 Releases to the Environment

Contributions to graywater are described below. Three sources comprise the majority of
graywater flow: Galley and scullery (18% in port, 22% at sea); laundry (22% in port, 33% at
sea); and showers and sinks (60% in port and 45% at sea).5 In addition, other minor sources
include: filter cleaning discharges, deck drains, and medical/dental waste discharges.1

2.2.1 Galley

Food preparation occurs in a vessel's galley. Large Navy vessels have several galley
compartments. In smaller vessels, the galley can be a shared space with related functions (e.g.,
the scullery), and have a single sink through which wastewater is discharged. Galley discharges
specifically exclude food/garbage grinder wastes. Garbage grinders are required to be secured
inside 3 n.m.6

Wastewater from the galley is generated through food preparation, disposal of cooking
liquids, and cleaning of surfaces (bulkheads, appliances, sinks, and working surfaces). The
generation and discharge are periodic, with the majority of the flow occurring during the hours
preceding meal times. Galley graywater can contain highly biodegradable organics, oil and
grease, and detergent residuals.

2.2.2 Scullery

The scullery can be separate from or integral with the galley and is used for the cleaning
of dishes and cookware. Scullery wastewater also specifically excludes garbage grinder wastes,
as garbage grinders are required to be secured inside 3 run.6 Scullery graywater can contain food
residuals and detergents.

2.2.3 Showers and Lavatory Sinks

Lavatory sinks and showers drain to the vessel's graywater system and can contain soap
residues, shampoos, shaving cream, and other products resulting from personal hygiene.
Detergent residuals similar to those used in the galley can also be present.

2.2.4 Laundry
* The Army usually refers to bilgewater as "blackwater" and sewage as "sewage".

Graywater
3
-------
Graywater derived from laundering crew uniforms, linens, and other articles of clothing
can contain laundry detergents, bleaches, oils and greases, and traces of other constituents.
Detergent residuals similar to those used in the galley, lavatory sinks, and showers can also be
present.

2.2.5 Other Discharges
I
Other minor discharges which are collected with graywater include filter cleaning
discharges, deck drains, and medical/dental waste discharges. These discharges combined
represent less than 1% of the total shipboard generated graywater.5 Filter cleaning discharges
consist of detergents and small amounts of oil from commercial dishwashing machines or sinks
used to wash ship ventilation system air filters. Deck drains contribute small and intermittent
flows which can include detergents used for floor cleaning and other general space cleaning.
Small amounts of medical/dental wastes are collected with graywater on only a few Navy ships
with extensive medical and dental facilities such as aircraft carriers (CV/CVNs) and amphibious
assault ships (LHD/LHA/LPHs). This would include wastes from dental spit sinks and small
blood samples less than 7.5 milliliters (mL).7

2.3 Vessels Producing the Discharge

Vessels in the Navy, MSC, Army, Air Force, and USCG generate graywater. However,
there are some vessels that do not produce a separate and distinct graywater discharge. These are
the vessels not equipped with segregated graywater collection systems. Instead, they collect
graywater together with blackwater for combined treatment with a MSD.
3.0 DISCHARGE CHARACTERISTICS

Discharges of graywater incidental to normal operations occur under three circumstances:
(1) at the pier, for the ship classes lacking the means to collect graywater for shore treatment; (2)
between 0 and 3 n.m. for most Navy and USCG vessels and for some MSC vessels; and (3)
outside 3 n.m., where most graywater is discharged overboard.

3.2 Rate

The Navy uses a design figure of 30 gallons per capita-day (gal/cap/day) when designing
graywater collections systems.8
Graywater
4
-------
Table 1 presents estimates of discharge rates by vessel class for Navy, MSC, USCG, and
Army ships. The following assumptions are inherent in the table:
With the few exceptions noted in Section 2.1 and 2.3, vessels discharge graywater overboard
at all times when not pierside. It is assumed, for purposes of calculation, that USCG, MSC,
and Army vessels also discharge graywater overboard at all times when not pierside.

A typical vessel is estimated to require about four hours to transit 12 n.m. from shore, with a
per capita average rate of 1.25 gallons/hour (30 gal/cap/day). If this vessel undergoes 20
transits a year and has a crew size of 400, the annual graywater discharge rate while in transit
would be:
t ' s ' s *• « ^ v
(20 transits/year) (4*hours/transit) (L25 gal/capita-hour) (400 personnel) — 40,000 gallons/year
Some vessels of the USCG and Army operate on a routine basis within 12 n.m. of shore.
Annual graywater discharge rate calculations for these vessels are based, in part, on the number
of days each ship operates within 12 n.m. A vessel's graywater discharge that results from
operating within 12 n.m. is calculated by using the following general formula:
(personnel) (hours in operation/year) (L25gaUcapitd-Mowr) — gallons/year
USCG vessels that operate within 12 n.m. include: Mackinaw Class Icebreakers (approx.
150 days/year, 24 hours/day), Bay Class Icebreaking Tugs (approx. 150 days/year, 24 hours/day),
and Balsam Class Seagoing Buoy Tenders (approx. 100 days/year, 24/hours/day). Army vessels
that operate within 12 n.m. include: Logistic Support Vessels (approx. 30 days/year, 10
hours/day) and Landing Craft Utility (approx. 60 days/year, 10 hours/day). Due to the fact that
the majority of Army vessels collect most of their graywater with blackwater, approximately only
10% of the graywater generated is discharged separately.9

As shown in Table 1, the total estimated amount of graywater discharged overboard
annually inside 12 n.m. is 39 million gallons. Of that volume, 15.3 million gallons are
discharged pierside.

3.3 Constituents

hi graywater, soaps, shampoos, detergents, and cleaners contribute organics as well as
inorganic compounds such as nitrogen and phosphorous. Food waste will contribute oxygen
demand (as measured by Biochemical Oxygen Demand (BOD) and Chemical Oxygen Demand
(COD)), nutrients, and oil and grease. Metals, pesticides, and organics from adhesives, sealants,
lubricants, and cleaners can also be present in graywater. The constituents that have been
measured in previous graywater studies are shown in Tables 2 and 3. The priority pollutants

Graywater
5
-------
cadmium, chromium, copper, lead, nickel, silver, and zinc were identified. Mercury, a
bioaccumulator, was also identified. It is possible that certain parameters not tested for, and thus
not listed in Tables 2 and 3, could also be present in graywater.
,i
]
3.4 Concentrations

Table 2 shows the average values measured for classical water quality parameters in
various shipboard streams that contribute to graywater based on samples collected from three
classes of vessels. Data are shown for the following graywater discharge components: wash
basins and showers, food preparation, laundry, and dishwasher and deep sink. The ranges of the
average measured values are: pH (6.74 -10), total suspended solids (TSS)(94 - 4,695 milligrams
per liter (mg/L)), total dissolved solids (TDS)(225 - 8,064 mg/L), BOD (144 - 2618 mg/L), COD
(304 - 7,839 mg/L), total organic carbon (TOC)(59 - 1,133 mg/L), oil and grease (5 -1,210
mg/L), methylene blue active substances (MBAS) (0.1 - 4.1 mg/L), ammonia nitrogen (0.17 -
669 mg/L), phosphate (1.03 - 28.2 mg/L), and coliform bacteria (178 - >2,000,000 per 100 mL).
Flow-weighted average concentrations of these constituents are calculated in Table 2, based upon
the data presented therein and the relative contribution of the three major sources of graywater.
I
Table 3 shows the mean concentrations of metals in various graywater components based
on samples collected from three classes of vessels. Data are shown for the following graywater
components: potable water sink, galley drams, sink, and scullery. The ranges of the average
measured values are: silver (.007 - 0.012 mg/L), cadmium (0.004 - 0.017 mg/L), chromium
(0.002 - 0.03 mg/L), copper (0.25 - 3.4 mg/L), lead (0.042 - 1.56 mg/L), mercury (.0002 - .0095
mg/L), nickel (0.025 - 0.113 mg/L), and zinc (0.19 - 2.36 mg/L). Flow-weighted average
concentrations of these metals are calculated in Table 3, based upon the data presented therein
and the relative contribution of graywater sources involved.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented hi Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented hi Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria, hi
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Total flow, and therefore mass loadings, are influenced by the number of personnel
aboard, tune spent hi transit, and time spent operating within 12 n.m. Total loadings can be
estimated by multiplying concentration data by the total annual flow of graywater. Based on
typical constituent concentrations and the estimated total flow calculated in Table 1, annual
loadings of constituents are presented hi Table 4.

4.2 Environmental Concentrations

Graywater
6
-------
Screening for constituents was accomplished by comparing measured levels of
constituents to the lowest applicable water quality criteria. For graywater, the only constituents
for which both data and water quality criteria are available are metals. Parameters such as BOD
and nutrients are at levels that would be expected to cause localized adverse environmental
effects.

As shown in Table 5, concentrations of the priority pollutants copper, lead, nickel, silver,
and zinc (measured as total metals), in one or more graywater components, exceed the most
stringent water quality criteria. The bioaccumulator, mercury, exceeds the most stringent water
quality criteria. Ammonia also exceeds the most stringent water quality criteria.

4.3 Potential for Introducing Non-Indigenous Species

Graywater originates from potable water rather than seawater. Therefore, the potential
for introduction of non-indigenous species is not significant.
5.0 CONCLUSIONS

Graywater has the potential to cause adverse environmental effects because measured
concentrations and estimated loadings of nutrients and oxygen-demanding substances are
significant.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge. Based on this estimate
and on the reported concentrations of constituents, the mass loadings to the environment
resulting from this discharge were then estimated. Table 6 shows the source of the data used to
develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Graywater Discharge. 29 July 1996.

2. Aivalotis, Joyce, USCG. Personal Communication: USCG Photo Labs/Film Processing
and X-ray Capabilities, 14 April 1997, David Eaton, M. Rosenblatt & Son, Inc.

3. Aivalotis, Joyce, USCG. Personal Communication: USCG Ship Description for
Medical/Dental Waste Discharge, 14 April 1997, David Eaton, M. Rosenblatt & Son, Inc.

4. Cassidy, Brian. "Zero Discharge Study." February 1996.
Graywater
7
-------
5.

10.

11.
Whelan,Mary. "Graywater Characterization." TM-28-89-01. March
1989.
Naval Ship's Technical Manual (NSTM), Chapter 593, Pollution Control (Revision 3),
page 2-2. 1 September 1991.

UNDS Equipment Expert Meeting Minutes - Medical/Dental Waste Discharges. 15
October 1996.

NAVSEA Design Practices and Criteria Manual for Surface Ship Freshwater Systems,
Chapter 532. NAVSEA T9500-AA-PRO-120. October 1987.
I
I
SSG Huckabee, U.S. Army 7th Transportation Group, Fort Eustis. Personal
Communication: Information on Army Vessels' Graywater Discharge, 16 March 1998,
Russell Fisher, Booz, Allen & Hamilton.

UNDS Ship Database, August 1,1997.

Pentagon Ship Movement Data for Years 1991 - 1995, Dated March 4, 1997.
12. Tails, A. and D. R. Decker. Naval Ship Research and Development Center. "Nonoily
Aqueous Waste Streams on the USS Sierra (AD18), Volume 1." Bethesda, Maryland.
Report 4182, April 1974.

13. Naval Ship Research and Development Center. "Nonoily Aqueous Waste Streams on
USS Seattle (AOE 3), Volume I." Bethesda, Maryland. Report 4192, June 1974.
j
14. Van Hees, W., D. R. Decker, and A. Talts. Naval Ship Research and Development
Center. "Nonoily Aqueous Waste Streams on USS O'Hare (DD 889), Volume I."
Bethesda, Maryland. Report 4193, June 1974.

15. Attachment to Letter, Commander, Carderock Division, Naval Surface Warfare Center,
Philadelphia, PA., 9593 Ser 6222/291, December 6,1993, "Investigation of Metals From
Industrial Processes, Intake Waters & Pipe Corrosion Onboard U.S. Navy Vessels at
Norfolk Naval Base, Norfolk, VA.," November 22 1993.
i
General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for rntrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Graywater
9
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Table 4. Mass Loadings of Constituents*
Parameter
Copper
Lead
Mercury
Nickel
Silver
Zinc
TSS
BOD
COD
Oil and Grease
MBAS
N-Ammonia
N-NO3
N-Kjeldahl
P- Phosphate
Flow-Weighted Average
Concentration (mg/L)
0.936
0.247
0.0013
0.042
0.008
0.501
802
540
1443
164
1.1
102
3.2
140
6.5
Loading (Ifo/yr.)
:.- "• ' '- ••'/' . ,-
304
80.3
.423
13.7
2.60
163
260,900
175,600
469,400
53,340
358
33,180
1,040
45,540
2110
* Based on flow-weighted average constituent concentrations. See Tables 2 and 3
Graywater
14
-------
Table 5. Comparison of Graywater Concentration Data Versus Acute Water Quality
Criteria
/ Parameter
Ammonia
Copper
Lead
Mercury**
Nickel
Silver
Zinc
Concentration*
102
3,404
1,559
9.5
113
12
2,363
Federal Acute
WQC
None
2.4
210
1.8
74
1.9
90
^Most Stringent State Acute
WQC (State)
6(HI)A
2.4 (CT, MS)
5.6 (FL, GA)
0.025 (FL, GA)
8.3 (FL, GA)
1.2 (WA)
84.6 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.
A - Nutrient criteria are not specified as acute or chronic values.

CT = Connecticut
FL = Florida
GA = Georgia
MS = Mississippi
WA = Washington
(*) Highest concentration for any individual component from Table 3.
(**) Bioaccumulator
Table 6. Data Sources

. NOD Section
2.1 Equipment Description and
Operatioa
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate „ ,
33 Constituents
3.4 Concentrations
4.1 Mass Loadings
4;2 Environmental Concentrations
r4.3 Potential for fotroducingNon- .
Indigenous Species
Data Source '
Reported

UNDS Database

Data call
responses
X
X

Sampling

Estimated

X
X

Equipment Expert
X
X
X
X

X
Graywater
15
-------
In Port
Blackwater and Graywater to Tank, Discharge to Pier
TO PIER
OVBD-* O 4 *•

•~*=rr*m
0-3 n.m. from shore
Blackwater to Tank, Graywater Overboard
Beyond 3 n.m. from shore
Blackwater Overboard, Graywater Overboard
GRAYWATER
BLACKWATER
COMBINED GRAYWATER
AND BLACKWATER

DIVERTER VALVE
Figure 1. A Typical Collection, Holding, and Transfer System
Graywater
16
-------
NATURE OF DISCHARGE REPORT
Hull Coating Leachate
1.0 INTRODUCTION

This section describes the hull coating leachate discharge and includes information on the
coating systems used and how they function (Section 2.1), a general description of the
constituents of the discharge (Section 2.2), and the vessels that produce this discharge (Section
2.3).

2.1 System Description and Operation
I
Underwater hull coating systems typically include a base anticorrosive (AC) coating
covered by an antifouling (AF) coating. The function of the AC coat, in conjunction with
cathodic protection (described in the Cathodic Protection NOD report), is to prevent hull
corrosion. The AC coat also provides bonding between the hull and the AF topcoats. Since the
AC coating is not exposed directly to the seawater, unless the AF coating has been damaged, the
AC coatings do not leach. The AF topcoat inhibits the development of marine growth on the
hull. Marine fouling is undesirable because it increases drag and fuel consumption, while
decreasing vessel speed.1
ii
2.1.1 Types of AF Topcoats
:i
Several different types of AF topcoats, qualified to MIL-PRF-24647 or MEL-P-15931, are
used on the hulls of the Armed Forces vessels.2'3 Within MIL-PRF-24647, they are categorized
by:

• action;
• type of substrate;
• volatile organic compound (VOC) content of the coating; and
• service life requirement and color.
ii
Action - The coating may work through ablative (Type I) or nonablative (Type IT) action.
An ablative coating thins as it erodes or dissolves. Through this action, a fresh layer of
antifouling agent (e.g., copper) is exposed, maintaining the antifouling properties of the paint.
Type n nonablative AF coatings do not thin during service. Some of these coatings function by
leaching metals that prevent marine fouling.1

Type of Substrate - Most hulls of major vessels in the Armed Forces are steel. Hulls of
smaller vessels and some specialty vessels (e.g., minesweepers and minehunters) are often
constructed of alternate materials such as aluminum, fiberglass sheathing, glass reinforced plastic
(GRP), rubber, or wood. The coating system applied will vary with the hull material. For
instance, steel, fiberglass, GRP, and wood hulls are typically coated with copper-based coatings,
and aluminum hulls with tributyltin (TBT) or biocide-free silicone-based coatings.1'4 Rubber
craft are left unpainted and, therefore, do not contribute to this discharge.
Hull Coating Leachate
2
-------
VOC Content - Coalings are classified into four grades based on their maximum VOC
content. The upper limits for each grade are 3.4 pounds per gallon (Ibs/gal), 2.8 Ibs/gal, 2.3
Ibs/gal, and zero Ibs/gal.2

Service Life Requirement and Color - Coatings are also classified based on the desired
service life of the coating system and their color. A vessel's coating system may have a five-,
seven-, or ten-year service life. Vessels also may use either red, black, or gray coatings (and
white on some smaller craft). Therefore, there are a number of different coating combinations,
based on service life and color.1

2.2 Releases to the Environment

AF topcoats control biological growth by ablating and/or releasing antifouling agents into
the surrounding water. This release is gradual and continuous. The release rate depends on the
type of paint, water temperature, vessel speed, frequency of vessel movement in and out of port,
and coating age. The type of material released is dependent on the type of topcoat employed.
Most hulls use copper-based coatings; therefore, copper and zinc (another biocide commonly
found in antifouling paints) are the most common releases. Those aluminum-hulled vessels with
TBT-containing coatings will release TBT and small amounts of zinc, and may release copper,
depending on the TBT coating formulation.l

2.3 Vessels Producing the Discharge

Most vessels of the Armed Forces use AC paints or AC/AF coating systems. Selected
boats and craft may not be coated with AF paint if they spend most of their time out of the water.
The Navy, Military Sealift Command (MSC) and United States Coast Guard (USCG) use paint
systems qualified to MIL-PRF-24647. The Army uses paint systems with AF topcoats qualified
to MIL-P-15931. Additional guidance for Navy vessels is contained in Naval Ships' Technical
Manual (NSTM) Chapter 631.5'6 It should be noted that paint types and applications vary for
each vessel, depending on where the vessels are docked and the port in which they are painted,
which influences paint availability.

2.3.1 Copper-Based Coatings

Most Navy, MSC, USCG, and Army ships have steel hulls with copper-based AF
coatings. The Navy ships that do not have steel hulls are the mine countermeasure vessels
(MCM 1 and MHC 51 Classes), consisting of 26 ships. MCM 1 Class vessels have wood hulls
sheathed with fiberglass and MHC 51 Class vessels have GRP hulls.7 However, these vessels are
still protected with AC coats and copper ablative AF paints similar to those applied to steel
vessels.1

MSC vessels use two types of Navy-approved copper-based AF paints, ablative and
nonablative. Approved MSC underwater hull coatings are listed in MSC Instruction 4750.2C.8
The USCG utilizes Navy-approved hull coating systems qualified to MIL-PRF-24647, as listed
in the USCG Coatings and Color Manual.9 The Air Force uses copper ablative paints similar to
Hull Coating Leachate
3
-------
those used by the Navy. AF topcoats used on Army watercraft are qualified to MIL-P-15931,
as listed in Department of the Army Technical Bulletin TB 43-0144.3
j
2.3.2 TBT-Based Coatings
i
The predominant use of TBT-based coatings in the Armed Forces has been on aluminum-
hulled vessels. Copper-based AF paints can accelerate the rate at which aluminum hulls corrode,
especially if defects or damage to the AC coating are present. Currently, all Navy ships with
aluminum hulls (i.e., hydrofoils) have been decommissioned.1 However, the Navy does have
approximately 280 small boats and craft with aluminum hulls. Approximately 10-20% of the
aluminum-hulled small boats and craft in the Navy (28-56 vessels; e.g., special warfare patrol
craft) could still have TBT-based hull coatings.11 The USCG estimates that 50 aluminum-hulled
small boats and craft are coated with AF paint containing TBT.12 The MSC has no vessels with
aluminum hulls.13 The Air Force has six large vessels with aluminum hulls, the MR Class
missile retrievers. These vessels are coated with TBT-free, copper-based coatings.7'10 The Air
Force also has approximately 50 small craft that may have TBT-containing coatings. The Army
has approximately 11 small boats and craft that may have TBT coatings.13 The numbers of
vessels from the respective Armed Forces branches estimated to have TBT coatings are listed
below.
Navy - 56
USCG-50
MSC-0
Air Force - 50
Army- 11
3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists
the discharge, and Section 3.4 gives the concentrations of the constituents in the
3.1 Locality
harbors and near-
constituents in
discharge.
the i
This discharge occurs within harbors, rivers, and coastal waters from every surface vessel
and submarine, as well as most boats and craft. This discharge is continuous and will occur any
time a painted vessel is waterborne.
i
3.2 Rate

This discharge is not a flow; rather, it is the release of AF agents from hull coatings into
the surrounding water. This rate of release, which is the combined effect of ablation and
leaching, has been the subject of previous Navy studies. In these studies, painted panels were
Hull Coating Leachate
4
-------
submerged in San Diego Bay and copper and zinc release rates were calculated for two of the
most frequently used ablative copper AF paint systems.

Dynamic exposure tests included intervals of simulated vessel movement (cruising) at 17
knots followed by periods of no movement, in order to simulate actual vessel operations. The
calculated long-term average release rates (from both test coatings) for simulated vessel
operation exposures were 17.0 micrograms per square centimeter-day ((|j.g/cm2)/day) for copper
and 6.7 (ug/cm2)/day for zinc. Release rates were highest at the initial stages of the exposures,
when the coatings were new.14
Long-term average release rates for panels remaining in a static position (no simulated
movement) for the entire test were 8.9 (|j.g/cm2)/day for copper and 3.6 (fig/cm2)/day for zinc.14
It is assumed that the static tests underestimate the actual average release rate from vessels
because they do not account for vessel movement and the resulting ablation effects.

A comparison of the above dynamic and static release rates shows that dynamic
conditions resulted in increased release of copper and zinc. The higher release rates are
presumably caused by continuous re-exposure of fresh copper and zinc. The dynamic tests may,
however, overestimate actual conditions for some vessels, as the dynamic intervals used in the
test may have been more aggressive than in actual practice.

rn-situ release rates of TBT from vessels in Pearl Harbor were collected by the Navy in
1987 and 1988.15 These studies reported an average steady-state TBT release rate of 0.38
(|ig/cm2)/day.

3.3 Constituents

The primary antifouling agent in most AF topcoats is copper. Because copper is toxic to
marine organisms, it inhibits their accumulation and growth on the hull. Other than copper
compounds, the constituents that can be released from approved, underwater hull paint systems
include acrylate (in ablative coatings), vinyls (in non-ablative coatings), rosin, zinc compounds,
and anticorrosive compounds.16'17 The discharge from aluminum-hulled vessels may also
contain TBT. Of the known constituents in AF coatings; copper, zinc, TBT, and ethyl benzene
are priority pollutants, and there are no known bioaccumulators.

3.4 Concentrations

Most copper-based AF coatings contain 40 to 50 weight percent (wt%) cuprous oxide.16
Some ablative AF paints also contain as much as 20 wt% zinc, which may act as a mild co-
biocide.16 Concentrations within TBT-based AF coatings range from less than 5 wt% to 25 wt%
for TBT compounds and 25-50 wt% for copper. Some TBT-based coating formulations contain
1-10 wt% ethyl benzene.18
4.0 NATURE OF DISCHARGE ANALYSIS
Hull Coating Leachate
5
-------
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.
i
4.1 Mass Loadings
|
4.1.1 Copper and Zinc Loadings

The mass loadings for copper and zinc were calculated for Navy, MSC, USCG, Army,
and Air Force vessels based on the reported release rates.14 Loading for a single vessel was
calculated by the following equation:
Copper Loading = (release rate)(surface area)(time)

•where: release rate = dynamic release of copper and zinc (Section 3,2)
surface area=wetted surface area of vessel
time =» number of days vessel is within 12 nauticalmiles (run.)
The wetted surface area of the vessels were either taken directly from a naval manual or
were estimated by the following formula presented in the same source:19
S-L7(LXd)-f-(V/d)

where: S = wetted surface area (ft2)
L = length between perpendiculars (ft)
d ^ molded mean draft at full displacement (ft)
V = molded volume of displacement (for seawater, 35 ft3 per tort displacement)
Calculations were performed for each vessel class. A sample calculation of the mass
loading of copper from a destroyer is provided in Calculation Sheet 1 at the end of the report.
From actual vessel movement data compiled for 1991 through 1995, the sum of the average
number of days in port, the average number of transits, and time of operation within 12 n.m. was
determined for each vessel class.20 The number of vessels in each class are listed in conjunction
with the total calculated loadings per vessel class hi Table 1. A total annual copper loading of
216,657 Ibs (98,257 kilograms (kg)) and a total annual zinc loading of 85,389 Ibs (38,725 kg)
were calculated. The mass loadings calculated represent the worst-case conditions.

The approach used overestimates the mass loading for the following reasons:
Hull Coating Leachate
6
-------
• Calculations were based on the dynamic release rate, and vessels are not in motion
while pierside.
• All vessels were assumed to be deployed at ports within the jurisdiction of the United
States, while many are actually deployed overseas.
• All vessels are assumed to be fully operational; that is, no reduction was made to
account for the number of vessels which may be in dry dock during the year.
• All small workboats and utility craft were assumed to be in the water at all times,
when they may actually be stored on land.
• Amphibious assault craft of both the Army and Navy, which are capable of being
transported or otherwise held within larger amphibious ships, were assumed to be in
the open water at all times.

4.1.2 TBT Loadings

Table 2 presents mass loadings of TBT from Navy, USCG, Army, and Air Force vessels,
based on the study of TBT concentration measurements from five vessels in Pearl Harbor.15 The
average release rate measured during this study was 0.38 (|j,g/cm2)/day. The mass loading value
was estimated to be 24 Ibs/yr (11 kg/yr) based on the following assumptions:

• Small boats and craft were estimated to be within 12 n.m. at all tunes and to spend
10% of the year out of the water. This assumption leads to an overestimate of the
mass loadings for TBT because many small boats and craft spend much more than
10% of their time out of the water.
• Twenty percent of the Navy's aluminum-hulled small boats and craft were assumed to
still have TBT-based AF coatings, although the actual number may be as low as 10%.
• All of the 50 Air Force and 11 Army small craft were assumed to be painted with
TBT coatings.

Use of these assumptions also overestimates the potential TBT loading since the use of
TBT coatings is being phased out, and the number of TBT coated craft hi the Armed Forces is
continually declining.

4.2 Environmental Concentrations

The estimated quantities of constituents released to the environment are shown in Tables
1 and 2. Using the mass loadings and a tidal prism model for analyzing mixing within specific
harbors, the resulting concentration of constituents in the environment were estimated hi the
manner described below.
_
4.2.1 Copper and Zinc Concentrations

Table 3 lists the Federal and most stringent state water quality criteria for the constituents
of the hull coating leachate discharge. Using the annual copper and zinc loadings and annual
tidal excursion volumes, the average copper and zinc concentrations caused by these vessels were
calculated for each port. The approach used to estimate concentrations uses a simplified dilution

Hull Coating Leachate
7
-------
model based on tidal flow in three major Armed Forces ports and hereafter referred to as the
"tidal prism" approach. The tidal prism approach uses the mass of the constituent generated by
vessels and mixes this mass with a volume of water. The mass is calculated by determining the
number of vessels in a particular homeport, the wetted surface area of each vessel's hull, and the
number of hours each vessel spends in port (both pierside and in transit). Together, these factors
are used to calculate an annual loading to the harbor. The water volume used is the sum of all
outgoing tides over a year times the surface area of the harbor. The sum of outgoing tides is
called the "annual tidal excursion." This can be calculated by subtracting the annual mean low
tide from the annual mean high tide and multiplying the difference by the number of days in the
year. Annual tidal excursion data is readily available from the National Oceanographic and
Atmospheric Agency (NOAA) and the 1996 data 21 was used for these calculations. The
following is the equation used to estimate concentrations of copper and zinc contributed to
harbors by hull coating leachate:
Concentration increase = Annual load /Annual tidal prism volume
where: annual load = (kg/yr)/(109 jig/kg) = (ng/yr)
annual tidal prism volume = (m3/yr) (103 i/m3) = (L/yr)
Concentration increase = p.g/L
The three ports used for the tidal prism model are Mayport, FL, San Diego, CA, and Pearl
Harbor, HI. These ports were selected because they have minimal river inflow, small but well-
defined harbor areas, and a high number of vessels of the Armed Forces. Each of these factors
will tend to provide higher concentrations of copper and zinc, either due to less volume of water
or higher numbers of potential sources. Other major ports, such as Norfolk (VA) and Bremerton
(WA), were considered, but not included because of large river effects and very large harbor
areas. The 1996 annual tidal volumes (annual tidal excursion times the harbor surface area) for
the three ports are shown below:
San Diego, CA,
Mayport, FL,
3.78 xlO10 m3 per year;
6.7 x 108 m3 per year; and
• Pearl Harbor, HI, 3.42 xHrnr per year.

The tidal prism model assumes steady-state conditions, where copper and zinc are
completely mixed with the harbor water and are removed solely by discharge from the port
during ebb tides. The outgoing tidal volumes are assumed to be carried away by long-shore
currents (i.e., those moving parallel to shore) and do not re-enter the harbor. The tidal prism
model also does not assume removal or concentration by other factors such as river flow,
precipitation, evaporation, or sediment exchange. By not accounting for removal or dilution due
to river flow, precipitation, and sediment exchange, the results depict a higher water column
concentration than expected. The effect of evaporation could be to increase concentration due to
water loss, or the effect could be neutral since water loss by evaporation is replaced by
(additional) water inflow from the sea. While the model assumes complete mixing, there will be
areas in the harbors with higher concentrations, primarily near the source vessels, along with
areas of lower concentration.
Hull Coating Leachate
8
-------
To estimate the annual load for the same three ports, the number and types of vessels in
each of these locations were obtained.22 The ratios of Navy vessels at each of these ports to the
total number of vessels per respective ship class were multiplied by the copper and zinc mass
loadings of Table 1 and summed. The estimated contribution of Armed Forces' AF paint to the
existing copper and zinc concentrations in each port is provided in Table 4. The actual annual
load attributable to hull coating leachate for each of these ports should be smaller than estimated
for two reasons. First, the calculated mass loadings are based upon dynamic release rates, yet the
vessels in port are primarily static. Also, the mass loadings of copper and zinc were determined
using the total amount of time that the vessels are within 12 n.m., not just in port. Therefore, the
actual concentrations in port will be lower than stated.

The calculated copper concentration increases are shown in Table 5 and range from 0.19
ug/L at San Diego to 3.0 |ag/L at Mayport, the latter of which exceeds Federal and state water
quality criteria. Copper from AF paint adds to the ambient copper concentrations from other
sources. In other words, these concentrations represent the ambient copper concentration if hull
coating leachate were the only source of copper in each harbor. Ambient copper concentrations
in San Diego Harbor have been reported to average near 3.7 pg/L, with locally impacted areas
near vessels at twice the average.23

As demonstrated by Table 5, the estimated copper contributions from hull coating
releases are a significant contributor to total copper levels within the Navy ports analyzed. In
addition, some of these ports are already near or above ambient water quality criteria levels for
copper. Therefore, dilution of copper to levels below the water quality criteria cannot be
expected. By contrast, the three ports analyzed were all well below the water quality criteria for
zinc, and estimated zinc concentration increases were not large enough to cause the zinc levels in
these ports to approach the zinc water quality criteria.24

4.2.2 TBT Concentrations

As discussed in Section 2.3.2, only small boats and craft of the Armed Forces still use
TBT-containing coatings. A tidal prism approach can also be used to estimate TBT
concentrations, assuming that the TBT loading in each harbor is proportional to the copper
loading, as might be the case if the locations of small boats and craft parallel that of larger
vessels. As shown hi Calculation Sheet 2, TBT is estimated to range from 0.02 nanograms per
liter (ng/L) to 0.30 ng/L in the harbors analyzed. TBT does not have specific Federal water
quality criteria at the present; however, criteria have been proposed.25 Table 3 lists the proposed
Federal and most stringent state water quality criteria for TBT.

4.3 Potential for Introducing Non-Indigenous Species

Although it is possible for non-indigenous species to be transported on vessel hulls, AF
coatings reduce the amount of marine growth on vessel hulls. The discharge itself (released
components of AF coatings) does not provide the opportunity for transport of non-indigenous
species.
Hull Coating Leachate
9
-------
5.0 CONCLUSIONS
Hull coating leachate has the potential to cause an adverse environmental effect because
estimated mass loadings of copper from hull coatings are significant and could cause
environmental copper concentrations to exceed water quality criteria in some ports.
6.0 DATA SOURCES AND REFERENCES
i
I
To characterize this discharge, information from various sources was obtained, reviewed,
and analyzed. Process information and assumptions were used to estimate the rates of discharge.
Table 6 shows the sources of data used to develop this NOD report.
Specific References
'!
1. UNDS Equipment Expert Meeting Minutes - Hull Coating Leachate, 20 August 1996.

2. Military Specification, MIL-PRF-24647B, Paint System, Anticorrosive and Antifouling,
Ship Hull, August 1994.
i.
3 . Department of the Army Technical Bulletin, Painting of Watercraft, TB 43-0144, 5
October 1990.

4. Material Safety Data Sheets for Courtaulds Coatings Inc. International Paint Mersleek®
Tie Coat BXA 386/BXA 390/BXA 391 and rntersleek® Finish BXA 816/BXA 821/BXA
822, June 1992.

5. Naval Ships' Technical Manual (NSTM) Chapter 631, Vol. 3, Preservation of Ships in
Service, Section 8, Shipboard Paint Application, 1 November 1992.

6. Naval Sea Systems Command (NAVSEA), Advance Change Notice (ACN) No. 3/A, to
Naval Ships' Technical Manual Chapter 631, S9086-VD-STM-030, Preservation of Ships
in Service. September 1996.

7. Polmar,N. The Naval Institute Guide to the Ships and Aircraft of the U.S. Fleet.
Sixteenth Edition. Naval Institute Press, Annapolis, MD, 1997.
i
8. Commander Military Sealift Command, COMSC Instruction 4750.2C, Preservation
Instructions for MSC Ships, Appendix A, 3 November 1989.
i
9. United States Coast Guard, Coatings and Color Manual, Commandants Instruction
M10360.3A, August 1995.

10. Department of the Air Force, HQUSAF/ILTV, Memo to M. Rosenblatt and Son, Inc., 21
August 1997.

Hull Coating Leachate
10
-------
11. Holmes, B. S., Naval Sea Systems Command. Vessels with TBT Coatings based on
conversations with Fleet representatives, June 1997, K. Thomas, M. Rosenblatt and Son,
Inc.

12. Aivalotis, J., USCG, TBT on USCG Ships, 28 May 1997, L. Panek, Versar, Inc.

13. UNDS Ship Database, 1 August 1997.

14. Marine Environmental Support Office, Naval Command, Control & Ocean Surveillance
Center, RDT&E Division (NRaD), UNDS Hull Coating Evaluation, 28 February 1997.

15. Naval Command, Control & Ocean Surveillance Center (NRaD). "Butyltin
Concentration Measurements in Pearl Harbor, Hawaii, April 1986 to January 1988, Pearl
Harbor Case Study," April 1989.

16. Material Safety Data Sheets for the following products:
17.
18.
19.
Product/Trade Name:
Manufacturer:

Product/Trade Name:

Manufacturer:

Product/Trade Name:

Manufacturer:

Product/Trade Name:

Manufacturer:

Product/Trade Name:
Manufacturer:
BRA 640 Interviron, Red Antifouling Paint
Courtaulds Coatings

283S5772 ABC #3 - Red Ablative Antifouling Paint
Product Number 406940
Ameron Protective Coatings Group

283S5773 ABC #3 - Black Ablative Antifouling Paint
Product Number 407150
Ameron Protective Coatings Group

Epoxy Adhesives 2216 B/A Gray, 2216 B/A Tan NS, and
2216 B/A Translucent
3M Scotch-Weld™, March 1995

Epoxy Adhesives
3M Innovation, March 1996
Qualified Products List (QPL-15931-14) of Products Qualified Under Military
Specification MDL-P-15931, Paint, Antifouling, Vinyl (Formulas No. 121, 121A, 129, and
129A). January 1995.

Material Safety Data Sheets for International Paint Intersmooth Hisol Plum BFA254,
November 1996; and Devoe Coating Company ABC #2 Red Ablative Antifouling
Coating, September 1995.

Naval Ships' Technical Manual (NSTM) Chapter 633, Section 4.3.1 and Table 633-5.
Cathodic Protection. 1 August 1992.

Hull Coating Leachate
11
-------
20. Pentagon Ship Movement Data for Years 1991-1995, Dated 4 March 1997.

21. National Oceanic and Atmospheric Administration, 1997.

22. United States Navy, List of Homeports, Effective 30 April 1997.
I
23. Valkirs, A.O., B.M. Davidson, L.L. Kear, R.L. Fransham, A.R. Zirino, and J.G.
Grovhoug; Naval Command, Control and Ocean Surveillance Center, RDT&E Division.
"Environmental Effects from In-Water Hull Cleaning of Ablative Copper Antifouling
Coatings." Tech. Doc. 2662. 1994.

24. U.S. Environmental Protection Agency, Office of Wetlands, Oceans and Watersheds,
Assessment and Watershed Protection Division, Retrieval from STORET Database,
1997.

25. Proposed Water Quality Criteria, 62 Federal Register 42554, 7 August 1997.
i
ii
General References
i
I
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.
i
i
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
|
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. 62, Number 150. August 5,1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.
i
i
Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.
i

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.
I

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
Hull Coating Leachate
12
-------
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Naval Command, Control and Ocean Surveillance Center, RDT&E Division, San Diego, CA.
"Dynamic and Static Exposure Tests and Evaluations of Alternative Copper-Based
Antifouling Coatings." September 1993.

Military Specification, MIL-PRF-15931, Paint, Antifouling, Vinyl, January 1995.

Qualified Products List (QPL-24647-3) of Products Qualified Under Military Specification MTT.-
PRF-24647, Paint System, Anticorrosive and Antifouling, Ship Hull. 2 April 1996.

Aivalotis, J., United States Coast Guard, USCG Ship Movement, 27 May 1997, L. Sesler,
Versar, Inc.

UNDS Equipment Expert Round 2 Meeting Minutes - Hull Coating Leachate, 1997.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
_
Hull Coating Leachate
13
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-------
_
-------
Table 3. A Comparison of Estimated Concentrations Versus Water Quality Criteria
Constituent
Copper
(dissolved)
Zinc
(dissolved)
TBT
Estimated Environmental
Concentration (ug/L)a
0.19-3.0
5.0-12.8
0.00002 - 0.0003
Federal Chronic Water
Quality Criteria (pg/L)
2.4
81
0.01"
Most Stringent State Chronic
Water Quality Criteria (ug/E)
2.4 (CT, MS)
76.6 (WA)
0.001 (VA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
:i
l|
CT - Connecticut
MS - Mississippi
VA83 Virginia
WA- Washington
* Range is for three high use Navy ports: San Diego, CA; Mayport, FL; and Pearl Harbor, HI.
b Proposed water quality criteria, August 7,1997
-------
Table 4. Copper and Zinc Loading into San Diego, Pearl Harbor, and Mayport for Use in
Concentration Estimate
>**• :'\'.^&f*^i^^^-

CG47
CV63
DD963
DDG51
LHA1
LHD1
LPD4
LSD 41
LSD 49
PC
FFG7
SSN
SSN
LSD
AGF
AS
LPH

AO177
ARS50
CG47
DD963
SAN DIEGO HARBOR |
Ticonderoga Class Guided Missile Cruisers
Kitty Hawk Class Aircraft Carrier
Spruance Class Destroyers
Arleigh Burke Class Guided Missile Destroyers
Tarawa Class Amphibious Assault Ships
Wasp Class Amphibious Transport Docks
Austin Class Amphibious Transport Docks
Whidbey Island Class Dock Landing Ships
8
2
6
5
2

813
623
616
263

320
245
243
104
524 207
2 ! 532 210
5
743 293
2 281 111
Harpers Ferry Dock Landing Ships \ 1
Cyclone Class Coastal Defense Ships 4
Oliver Hazard Perry Guided Missile Frigates 1 1
Los Angeles Class Attack Submarines 9
144 57
26
10
590 233
914
Sturgeon Class Attack Submarine 1 79
Anchorage Class Dock Landing Ships 3
Raleigh Class Miscellaneous Flagship 1
472
123
Emory S Land Class Submarine Tender 1 278
Iwo Jima Class Assault Ship

1
Total Loading =

PEARL HARBOR
Jumboised Cimarron Class Oilers 2
Safeguard Class Savage Ships i 2
Ticonderoga Class Guided Missile Cruisers 1 3
Spruance Class Destroyers 4
DDG51 ! Arleigh Burke Class Guided Missile Destroyers | 3
FFG
SSN
SSN
SSN

CG47
CV63
DD963
DDG51
FFG

Oliver Hazard Perry Guided Missile Frigates
Los Angeles Class Attack Submarine
Sturgeon Class Attack Submarine
Benjamin Franklin Class Submarines

MAYPORT HARBOR
Ticonderoga Class Guided Missile Cruisers
Kitty Hawk Class Aircraft Carrier
Spruance Class Destroyers
Arleigh Burke Class Guided Missile Destroyers
Oliver Hazard Perry Guided Missile Frigates
2
15
4
1
Total Loading =

5
1
5
2
10
| Total Loading =
i
150
7,171

382
91
360
31
186
48
109
59
2,826

150
36
305 | 120
411
158
107
1,524
316
129
3,423

508
311
514
162
63
42
601
125
51
1,350

200
123
202
105 41
537
212
1,975 778

-------
Table 5. Estimated Copper and Zinc Contributions to Some Ports of the Armed Forces
Port
San Diego
Mayport
Pearl Harbor
Ambient Cu
Concentration
(ug/L)
3.7"
Unknown0
1.76a
Cu from Hull
Coating Leachate

0.074
1.16
0.39
a Information from STORET database.
b For San Diego Bay, information from prior Navy Studies.
c Available STORET information was insufficient to make estimate.
Table 6. Data Sources

NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
23 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
33 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
43 Potential for Introducing Non-
Indigenous Species
: -Data, Source- ' • . •.,.--. ..'. ' ..v. -'
Reported

X
UNDS Database

X
MSDS
X

Sampling

Estimated

X
X

Equipment Expert
X
X
X
X

X
-------
Copper Loading^ (release rateXsurfece acea)CNmrf5eE of shipsXtime); where:

release rate =daily dynamic release {irate- of copper kg/cat!^ % -> ,.
surface arear= wetted surface area of a DD 963 Class slap, (cm2)
; time = ££ (time in port 4- time iti transit + time in operation witfiia 12 Q.m.)}(number of DD 96& Class
sMps)(numbefofdaj«wilianl2anj*eachyearpersMp) „„ *~
,V * ' ' - •, / *' ''- '
1) Daily dyaamic release late of copper .(From NRaD study) , , * , > -
^ -
2) Wetted surfece area of a DD 963 Class ship in cm2 (From NSW Chapter 633) '- ' ~ ' ~ \
= (35,745 fi2) (929 cufrft2)- 33,207405 cm2/sWp " >1 , ' * -^ "*'- '
' -.^ - - *~ '-, '< * » 4
3)~ Number of DD 963^CIass ships— 3 1 ships (From ship faivenfory ^latabsuse)

4) Number of days within 12 run. each year per ship~(From ship movementdtetabase)
= days kport/year + [(teansits/year) ^2,Iegs/transit) (4 hrs/Ieg) (I day/24 hours)] •+• days, operation withml2 n.m./yr
= 178 days/yr + [(12 transits/yr) (2 legs/transit) (4 hrs/Ieg) (1 day/24 hrs)] + 0 days/yr * 182 days/yr

Thus: ,, -' - ' ' ;/ ' • - *-' " ^ , "
Copper Loading = (17 xlO-9(kg/cm2)7day)(33J207)105.cm2/sMp)(31 ships)(182 days/yr) -
• =3,185 kg/yr =7,007 Ibs/yr ^ /; > . >
Calculation Sheet 1. Mass Loading of Copper from DD 963 Class Vessels
-------
Copper loading in San Diego = 7,171 kg/yr (See Table 4)
Copper loading in Pearl Harbor = 3,423 kg/yr (See Table 4)
Copper loading in Mayport = 1,975 kg (See Table 4)

Total copper loading = 98,257 kg/yr (See Table 1)
/ ' >, .-.'''•,• ^
Proportion of copper loading in each harbor to the total copper loading:
San Diego = (7,171 kg/yr) / (98,257 kg/yr) = 0,073 (or 7.3%)
Pearl Harbor=0.035 (or 3.5%)
Mayport=0.020 (or 2%)

Total estimated TBT loading = 11.4 kg/yr (See Table 2)

Estimated TBT loading in each harbor = (copper proportion) (total TBT loading):
San Diego = (0.073) (11.4 kg/yr) = 0.8 kg/yr
Pearl Harbor=(0.035) (11.4 kg/yr) = 0.4 kg/yr
Mayport=(0.020) (11.4 kg/yr) = 0.2 kg/yr

Proportion of copper concentration in each harbor (Table 5) to annual copper loading
in the respective harbon
San Diego = (0.19 x 10* g/L Cu) / (7,171 x 103 g Cu) = 2.7 x 10'14
Pearl Harbor = (1 x IV6 g/L Cu) / (3,423 x 10s g Cu) = 2.9 x 10"13
Mayport = (3 x 10* g/L Cu) / (1,975 x 103 g Cu) = 1.5 x 10'12

Estimated TBT concentration in each harbor is proportional to copper ratio:
San Diego: (0.19 ug/L Cu) / (7,171 kgCu) = (X ug/L TBT) / (0.8 kg TBT)
X=(2.7 x 10'14 ) ( 0.8 x 103 g TBT) = 2.2 x Iff* ug/L TBT
PearlHarbor. X=(2.9 x 10'13 ) (0.4 x 103 g TBT) = 1.2 x KT* ug/L TBT
Mayport X = (1.5 x l(Ttt ) (0.2 x 103 g TBT) = 3.0 x KT4 ug^L XBT
Calculation Sheet 2. Estimates of Contributed TBT Concentrations by Harbor
-------
HULL COATING LEACHATE
MARINE POLLUTION CONTROL DEVICE (MPCD) ANALYSIS
Several alternatives were investigated to determine if any reasonable and practicable
MPCDs exist or could be developed for controlling discharges from hull coatings. An MPCD is
defined as any equipment or management practice, for installation or use onboard a vessel,
designed to receive, retain, treat, control, or eliminate a discharge incidental to the normal
operation of a vessel. Phase I of UNDS requires several factors to be considered when
determining which discharges should be controlled by MPCDs. These include the practicability,
operational impact, and cost of an MPCD. During Phase I of UNDS, an MPCD option was
deemed reasonable and practicable even if the analysis showed it was reasonable and practicable
only for a limited number of vessels or vessel classes, or only on new construction vessels.
Therefore, every possible MPCD alternative was not evaluated. A more detailed evaluation of
MPCD alternatives will be conducted during Phase n of UNDS when determining the
performance requirements for MPCDs. This Phase n analysis will not be limited to the MPCDs
described below and may consider additional MPCD options.

MPCD Options

Hull coating leachate refers to the transfer by diffusion or ablation of coating constituents
from the underwater portion of a vessel's hull into the water. The anticorrosive (AC) and
antifouling (AF) coating system minimizes adhesion and propagation of marine fouling organisms
on the hull surface which increase drag, and prevents costly structural damage to the hull (metal
or material loss) which would otherwise result from long-term exposure to seawater. Without
effective antifouling coatings, ships' hulls would have to be cleaned or dry docked and repainted
much more frequently; thereby expending time, money, and manpower, while compromising
operational readiness.

To determine the practicability of mitigating the potentially adverse environmental effects
of hull coating leachate, three potential MPCD options were investigated. The purpose of these
MPCDs would be to reduce or eliminate the release of antifouling agents, specifically copper and
tributyltin, from antifouling hull coatings. The MPCD options were selected based on initial
screenings of alternate materials, equipment, pollution prevention options, and management
practices. They are listed below with brief descriptions of each:

Option 1: Use Less Toxic Fouling Release Coatings - This option would require that
hulls be coated with less toxic paints that may initially foul, but readily release fouling
organisms when the vessel reaches a target speed.

Option 2: Control the Maximum Allowable AF Release Rate - This option would set
limits on the maximum allowable release rate of copper from fouling resistant coatings to a
level known to effectively control fouling but not cause an excess of copper to be released.
Hull Coating Leachate MPCD Analysis
1
-------
Option 3: Limit or Eliminate Use of Tributyltin (TBT) Paints - The goal of this
option is to further reduce or eliminate the use of TBT paints on Armed Forces vessels.

MPCD Analysis Results
l
Table 1 shows the results of the MPCD analysis. It contains information on the elements
of practicability, effect on operational and warfighting capabilities, cost, environmental
effectiveness, and a final determination for each option. Based on these findings, Option 2 -
establishing the maximum release rate of copper in AF coatings, and Option 3 — further restricting
the application of TBT paints on vessels of the Armed Forces, offer the best combination of these
elements and are each considered to represent a reasonable and practicable MPCD.
Hull Coating Leachate MPCD Analysis
2
-------
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REFERENCES

1 Naval Ships' Technical Manual S9086-CQ-STM-010 R3 Chapter 081, Waterbome Underwater
Hull Cleaning of Navy Ships. 4 August 1997. Page 1-1.

2 EPA and the Secretary of the Navy. "Congressional Report on Alternatives to Organotin
Antifoulants and Alternative Antifoulant Research." December 1996. Pages 8,29.
Hull Coaling Leachate MPCD Analysis
5
-------
-------
NATURE OF DISCHARGE REPORT
Mine Countermeasures Equipment Lubrication
1.0 INTRODUCTION

The purpose of the NOD report is to describe the discharge in detail, including the system
that produces the discharge, the equipment involved, the constituents released to the
environment, and the current practice, if any, to prevent or minimize environmental effects.
Where existing process information is insufficient to characterize the discharge, the NOD report
provides the results of additional sampling or other data gathered on the discharge. Based on the
above information, the NOD report describes how the estimated constituent concentrations and
mass loading to the environment were determined. Finally, the NOD report assesses the
potential for environmental effect. The NOD report contains sections on: Discharge
Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data
Sources and References.
Mine Countermeasures Equipment Lubrication
1
-------
2.0 DISCHARGE DESCRIPTION
1 i
This section describes the mine countermeasures discharge and includes information on:
the equipment that is used and its operation (Section 2.1), general description of the constituents
of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
I
2.1 Equipment Description and Operation
ij
The Navy is the only branch of the Armed Forces with a mine countermeasures mission.
To accomplish this mission, mine countermeasures vessels use towed sonar and video arrays,
cable cutters, and mine detonation equipment. During training exercises, the mine
countermeasures equipment is deployed and towed behind the ship as it practices sweeping the
area for mines.

Specific types of mine countermeasures equipment are:

• devices to detonate acoustic mines, such as acoustic hammers and vibrating
diaphragms;
• robotic devices (mine neutralization vehicles) which locate and destroy mines;
• devices which generate magnetic fields to explode magnetic mines;
• minehunting sonar; and
• cables fitted with mechanical or explosive cutters to cut the cables of moored
mines.
:i
Mine countermeasures equipment is normally located at the stem or fantail portion of
mine countermeasures vessels. Most equipment is non-magnetic, and winches and cranes are
hydraulically powered. Brief descriptions of the specific mine countermeasures equipment used
by the Navy are presented below:1
i
A-MK4-V and A-MK6-B mine detonators use vibrating diaphragms and
acoustic hammers, respectively, to generate noise and detonate acoustic mines.
When deployed, both types of acoustic detonators are towed astern on buoyant
1,600-foot-long cables. Both types of detonators are not deployed simultaneously
but rather, one detonator type is selected for a given minesweeping event,
depending on the type of mine targeted.
:i
Magnetic minesweeping cables float, are trailed astern of the ship, and generate
large electric currents through the water. This creates a magnetic field around the
cable which detonates magnetic mines. Several cable configurations are used and
all are carried on a common cable reel drum with three sections. Cable lengths
range from 450 to 1,800 feet for the various configurations.

AN/SLQ-48 mine neutralization vehicles (MNVs) are cable-controlled,
unmanned robotic devices used to locate and destroy mines. They contain closed-
circuit television cameras and close-range sonar for locating mines, that are then
I
Mine Countermeasures Equipment Lubrication
..2
-------
destroyed using cable cutters or small explosive charges. A crane with a lifting
cable is used to deploy and recover the AN/SLQ-48 MNV on some vessels. A
5,000-foot-long cable is used to supply power.

AN/SQQ-32 sonar tow cables and reels are used to tow and supply power to
AN/SQQ-32 variable-depth, mine-hunting sonars.

AN/SQQ-30 sonar tow cable and reels are used to tow and supply power to
older, less-capable mine hunting sonars used on some ships. These systems will
eventually be replaced with AN/SQQ-32 sonars.

O-type mechanical gear is used to sweep moored mines. It consists of wire
cables towed through the water at depths where it can strike the mine's mooring.
The mooring slides along the cable until it contacts mechanical or explosive
cutters, which sever the mooring. The mines then bob to the surface where they
are detonated by gunfire.

A typical layout of mine countermeasures equipment on the fantail of a mine
countermeasures ship is provided in Figure 1. Figure 2 shows a schematic of an O-type setup
used to sweep moored mines.1

2.2 Releases to the Environment

This discharge consists of the lubricating grease and oil removed by the mechanical
action of seawater as the equipment is towed. Greases and oils are used externally on wetted
equipment (e.g., blocks, swivels, and cutters) to minimize wear and to prevent the mine
countermeasures equipment from binding as it is deployed.2 Tow cables are made of stainless
steel and are not lubricated, with the exception of the lifting cable on the crane of MHC 51 Class
vessels, which is grease-lubricated.3'4 Grease and oil application procedures are discussed in
Section 3.

Lubricants used on mechanical components inside the water-tight compartments of towed
acoustic and electromagnetic devices are not released from the devices to the-sea. Neither are
leaks and spills of lubricants to the deck from non-wetted, on-board mine countermeasures
equipment; these are cleaned-up and contained using rags or other sorbents.5

2.3 Vessels Producing the Discharge

Mine countermeasures equipment is found on only two classes of Armed Forces vessels:
the Navy's Osprey (MHC 51) Class, and the Navy's Avenger (MCM 1) Class.1 The nine MHC
51 Class coastal minehunters perform harbor clearing, channel clearing, and deep-water coastal
mine countermeasures. The MCM 1 Class has 14 vessels designed to locate and destroy mines
that cannot be countered by conventional minesweeping techniques. Table 1 shows the vessels
producing the mine countermeasures equipment lubrication discharge.1
Mine Countermeasures Equipment Lubrication
3
-------
Both the MCM and the MHC classes are equipped with a hull-mounted, variable-depth
sonar (YDS) (either a SQQ-30 or a newer SQQ-32) as their primary means of mine detection,
and a cable-controlled and powered SLQ-48 Mine Neutralization Vehicle (MNV) for the
examination and clearing of mines.

MHC 51 Class vessels are equipped only with the SLQ-48 MNV and the SQQ-32 sonar.
The SQQ-32 is retained in its hull-mounted position unless the vessel is actually engaged in
mmehunting, when it may be towed. An MHC conducts minehunting operations at speeds of five
to seven knots. At these speeds, depending upon its deployed depth, the 7,846-pound towed body
of the SQQ-32 tows directly beneath or sometimes slightly astern of the MHC.6 To sweep or
neutralize mines, the SLQ-48 is deployed. It is a self-propelled vehicle, controlled and powered
through a 5,000-ft cable, and is remotely 'piloted' by an operator on the MHC.
i
In addition to a SQQ sonar and a SLQ-48 MNV, MCM 1 class vessels are equipped with
the O-type mechanical gear, magnetic minesweeping cables, and A-MK4-V and A-MK6-B mine
detonators described in Section 2.1.7 Like the MHCs, MCMs retain their SQQ sonar hi the hull-
mounted position unless the vessel is engaged in minehunting. MCMs generally deploy their gear
based on the type of mine being targeted: the SLQ-48 MNV for deep bottom mines, O-type
mechanical sweep gear for shallow moored mines, and acoustic and magnetic detonators for
acoustic and magnetic mines.
|
The SQQ sonar is mostly operated in the hull-mounted position. It is not towed while any
of the sweeping gear is deployed. The MNV is usually deployed by itself. However, because it is
controlled and can remain clear of streamed gear whenever it must be deployed, it can be deployed
with any of the other gear.6 Although they may be streamed together, the O-type and magnetic-
acoustic gear are usually streamed individually. The O-type gear fans out when streamed (see
Figure 2), while the magnetic-acoustic gear streams directly astern hi the absence of current. The
only chance for interference between O-type and magnetic-acoustic gear, when streamed together,
is during ship's turns, which must be wide and slow.

3.0 DISCHARGE CHARACTERISTICS
I
This section contains qualitative and quantitative information that characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and near-
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
!|
3.1 Locality
i
Discharges from mine countenneasures equipment incidental to normal operations occur
only during training exercises usually held between five and 12 n. m. from shore, and sometimes
as far as 20 to 50 n. m. from shore.8
Mine Countenneasures Equipment Lubrication
4
-------
3.2 Rate

This discharge is not a flow; rather, it is the release of lubricant to the surrounding
seawater by mechanical erosion or dissolution when equipment is towed. During training
exercises, the conventional mine countermeasures equipment is deployed and towed behind the
ship as it sweeps the area.2 Based on information from the Naval Undersea Warfare Center and
on planned maintenance system (PMS) requirements, small amounts of lubricants are applied to
various parts of the towed equipment.2'9 Thus, there is a potential for these lubricants to be
released to the surrounding waters.

Due to differences in equipment and mission assignments between the two vessel classes,
the discharges produced by the MHC 51 and MCM 1 Class vessels are different. For this reason,
the two vessel classes are discussed individually, and producing the greatest discharge scenarios are
developed for each vessel class. Calculations are based on all mine countermeasures vessels
operating in U.S. waters (i.e., none are under repair or deployed overseas).

3.2.1 MHC 51 Class Vessels

An MHC 51 Class vessel averages about five training days per month, with a maximum of
four two-hour exercises each training day.10 Thus, for a given ship, the total number of exercises
per year is equal to:
(5 days/month)(4 exercises/day)(12 months/year) = 240 exercises per year for each ship
For the nine existing MHC 51 Class vessels (Section 2.3), this is a total of 2,160 exercises
per year.

MHC 51 Class vessels are equipped with SQQ-32 sonar and the SLQ-48 MNV. The sonar
has no lubricated areas exposed to seawater during operation and, as discussed in Section 2.2, tow
cables are not greased. Therefore, there is no potential for grease being released during SQQ sonar
deployment.

The SLQ-48 MNV has two arms which are controlled by a remote operator, or "pilot", to do
work. Each arm has a cavity which receives approximately 2 ounces of DOD-G-24508 grease to
prevent equipment binding.11 A conservative assumption, however, is that all of the grease in the
cavities is washed out during deployment (i.e., 4 ounces per deployment).

The lifting cable used for deploying the SLQ-48 MNV is lubricated with approximately 3
ounces of MIL-G-18458 grease. This cable is in contact with the water only during the vehicle's
launching and recovery, during which time the vessel is stationary. Equipment experts estimate
that during deployment this cable is in the water less than 1 minute, and during recovery for 3 to
5 minutes.12 Therefore, the total amount of time the lift cable is in contact with seawater is
approximately 5 minutes during each exercise.

The specification for the lift cable grease requires conforrnance with several chemical and

Mine Countermeasures Equipment Lubrication
5
-------
physical standards, one of which is an adhesion test. In this test, grease is applied to a concave
disk of known weight. The greased disk is then weighed to determine the weight of grease
applied. The disk is submerged in 151°F water for 15 minutes, and then rotated at approximately
150 revolutions per minute for an additional 15 minutes. The disk is then weighed to determine
the quantity of grease which has either eroded or dissolved. To pass this test, a minimum of 95%
of the applied grease must remain on the disk as determined by the final weight of the disk after
the test."
I
I
For the deployment of the SLQ-48 MNV, the grease on the lift cable is exposed to
comparatively milder conditions. The water temperature will be lower, the exposure time will be
less, and because the vessel is stationary, there will be little or no mechanical erosion. The
maximum estimate of the grease discharged from the lift cable is 5 percent of the applied grease.
This would be equal to 0.15 ounces of grease discharged per deployment.

3.2.2 MCM1 Class Vessels
!
MCM 1 Class vessel training exercises consist either of a sweeping or a hunting task, and
the dimensions of the exercise area vary with each exercise. For example, an assigned area may
measure as much as 30 by 90 miles. Each MCM is assigned one sweeping and one hunting task
each month. Thus, as a conservative estimate, each MCM on average deploys various
combinations of its countermeasures equipment 24 times a year, and performs each type of
operation 12 times per year. Unless some problem is experienced with the equipment while
deployed, it remains in the water for the duration of the exercise, which may last 24 hours a day for
up to 5 days.10'11
I
For minehunting, the MCM Class 1 vessels use the same equipment as the MHC 51 Class
vessels; the SQQ sonar and the SLQ-48 MNV. However, the MCMs use non-greased nylon lifting
cables when launching and recovering the SLQ-48 MNV, so no potential exists for the release of
cable grease to the surrounding water.
12
The MCM mine neutralization vehicle hoist arrangement provides three weight-bearing
cables to handle the 2,750 pound vehicle. This allows nylon cables to handle the load. The crane
of the MHC 51 Class vessel attaches to the vehicle with only a single cable, which precludes the
use of a nylon cable.

Neither the SQQ-30 nor the SQQ-32 sonar expose lubricants to the surrounding seawater.
As noted previously, the largest discharge is a four ounce discharge of DOD-G-24508 grease from
the arms of the SLQ-48 MNV during each of the 12 exercises conducted annually.

For minesweeping operations, either O-type gear is deployed, or magnetic and acoustic
detonators are deployed. For the 12 sweeping exercises conducted annually, operational experience
shows that O-type gear is deployed half of the time (six out of 12) and magnetic and acoustic
detonators are deployed half of the time (six out of 12). In an O-type gear double sweep array, there
are cables, chains, and wires, which are not lubricated. In addition, there are eight cutters, two
snatch blocks, three shackles, and 13 swivels that are lubricated. The swivels have fittings through
|i
Mine Countermeasures Equipment Lubrication
6
-------
which MIL-G-23549 grease is applied; each swivel is then wiped clean. Only the threads of the
shackles are greased. The bearing surfaces of the snatch block rollers are given a light coat ofMTL-
L-3150 oil. Since the bearing surfaces are recessed within the block, they are minimally exposed to
seawater turbulence while being towed. The cutters are fabricated of a non-ferrous alloy. When
retrieved, they are washed with freshwater, dried, and given a light coat of MIL-L-9000 oil before
being stowed. No additional lubrication is applied before they are re-deployed.14

An estimate of the amount of lubricant (combined oil and grease) that is discharged is 1
ounce for each component, or 26 ounces during each of the six exercises using O-type gear.

: 8 cutters •*• 2 snatch blocks+3 shackles•*•13 swivels = 26 components total '

For the six magnetic and acoustic exercises conducted each year, the MCM streams the
magnetic minesweeping cable and either a high frequency A-MK4-V or a low frequency A-MK6-B
acoustic detonator.6 The only lubricant exposed to the turbulence of the seawater while streaming
the magnetic and acoustic detonators is on the 30-inch diaphragm of the A-MK4-V detonator,
which is coated with about 4 ounces of DOD-G-24508 grease.8'15 The A—MK6-B low frequency
detonator does not have a diaphragm that requires grease. The magnetic minesweeping cable and
the power cable to the acoustic detonators are buoyant; however, the streamed acoustic detonator
does require a large O-type float in order to stream properly. A wire pendant of the desired length
secures each acoustic detonator to its large float by a swivel whose zerk fitting has about 1 ounce of
MIL-G-23549 grease pumped into it.10 Therefore, when a high frequency acoustic detonator is
streamed with the magnetic minesweeping cable, approximately five ounces of grease (four from
the diaphragm and one from the swivel) are exposed to the sea. When the low frequency acoustic
detonator is used, the amount of grease that could be released is one ounce (from the detonator's
swivel to its buoy float).

3.3 Constituents

Several types of lubrication oils and greases are used on wetted mine countermeasures
equipment based on information in maintenance requirements cards. Table 2 shows a list of the
lubricant types and the lubrication schedules for the mine countermeasures equipment.9 The
greases are made from lubricating stocks generated during petroleum fractionation. These
fractions contain organic compounds each generally having more than seventeen carbon atoms.
Lubricating oils are composed of aliphatic, olefinic, naphthenic (cycloparaffinic), and aromatic
hydrocarbons depending on their specific use. Lubricating oil additives include antioxidants,
bearing protectors, wear resistors, dispersants, detergents, viscosity index improvers, pourpoint
depressors, and antifoaming and rust-resisting agents.16

Until recently, lead was contained in the MIL-G-1845 8B grease procured by the Navy to
lubricate the MHC's lift cable which deploys and recovers the SLQ-48 MNV. However,
Amendment 5 to MIL-G-1845 8B dated 26 March, 1996, prohibits heavy metals (including lead)
and salts of heavy metals as constituents of MIL-G-1845 8B grease.13 As such, the Navy is no
longer procuring grease containing lead or any heavy metals for use in lubricating mine
countermeasures equipment. Consequently, lead will not be considered a constituent of this

Mine Countermeasures Equipment Lubrication
7
-------
discharge.
I
There are no known bioaccumulators in this discharge.

3.4 Concentrations

Table 3a shows the percentages of the constituents in oils and greases used on the mine
countermeasures wetted equipment. The total of the base constituents of oils and greases (i.e.,
the hydrocarbons — mineral oils through the asphalts and waxes (e.g., the heavy paraffinic
distillates)) range in concentration from approximately 25% to greater than 90%, with additives
making up the balance of these lubricants. Tables 3b through 3d show the maximum
concentrations from SLQ-48 arms, O-gear and cutters, and acoustic and magnetic devices,
respectively.
4.0 NATURE OF DISCHARGE ANALYSIS
:i
I
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality standards. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.
4.1 Mass Loadings
II
The estimated annual lubricant mass loading shown in Table 4 is based upon the
discharge scenarios described in Section 3.2, the number of exercises performed annually, and
the number of vessels involved.
I
4.2 Environmental Concentrations
I
The estimated quantities of lubricant released to the environment during each mine
countermeasures training exercise are shown in Table 4. The concentration after dilution in the
environment can be estimated using the mass loadings from Table 4 and estimates of the
volumes of water through which the equipment is towed during various exercises. These
estimates are provided in Sections 4.2.1 through 4.2.4 for each of the source/vessel combinations
identified in Section 3.2 and Table 4. Section 4.2.5 provides information on applicable water
quality standards.

4.2.1 SLQ-48 MNV Arms
ij

As shown in Table 4 and discussed in Section 3.2, the estimated maximum amount of
grease discharged from the SLQ-48 MNV is 4 ounces (0.25 pounds (Ibs)). This assumes that the
screws that seal both cavities come unscrewed and fallout undetected, allowing all of the applied
grease to be released. While this is based on equipment failure and does not reflect typical

Mine Countermeasures Equipment Lubrication
8
-------
operating conditions, it does provide a conservative assumption regarding the amount of grease
released during operations.

For MHC 51 Class vessels, minehunting operations are performed at a speed of 5 knots
(30,381 feet per hour (ft/hr)) for a duration of 2 hours. The calculated concentration of
lubricant in the environment from SLQ-48 MNV arms assumed that:

• the SLQ 48 MNV creates a nine square feet (three feet by three feet) area of turbulence in
the wake of the vehicle, as determined by dimensions of the vehicle's cross-sectional
area;
• the discharge rate of grease is uniform throughout the exercise;
• the grease is uniformly dispersed throughout the traversed water volume

Based upon operational experience, it was determined that the SLQ-48 MNV generates a
wake in the same manner as a surfaced submarine. Thus the frontal area of the vehicle, as
determined by the dimensions of its cross-sectional area, creates a ninesquare feet (three feet by
three feet) area of turbulence17 where complete mixing occurs. Therefore, an area of nine square
feet was used in the following formula to calculate the mixing and dispersion of oil and grease
caused by the turbulence of the vehicle's wake rather than the frontal area of the arms.

The volume of water through which the equipment operates during a single exercise was
calculated using the following formula:
-Volume — (Area)(T«neXSpeid)
Volume —(9 square feet)(2 hoars)(30,381 ft/hr),
Volume = 546,858 cubic feet (8?) of water "
Based on the assumptions listed above and the volume of water through which the
equipment operates, the lubricant concentration in the environment was estimated as follows:
Mass lubricant

Volume of water
Concentration
= (0.25 Ibs lubricant)(453,6 grams (g)/lb)(1000 milligrams/g)
= 113,400 milligrams (mg) lubricant
= (546,858 ft3)(28.32 liters (Lyft3) = 15,487,019 L
= 113,400 mg Iubricant/15,487,019 L
= 0.0073 mg/L» or 7:3 micrograms per liter (p.g/L)
The calculated value of 7.3 p.g/L is three orders of magnitude less than the most stringent
state water quality criteria of 5,000 ug/L (Florida).

4.2.2 SLQ-48 MNV Lift Cable

From Table 4 and the discussion in Section 3.2.1, the maximum amount of grease
released from the lift cable during each deployment of the SLQ-48 MNV is 0.15 ounce (0.0094
Mine Countermeasures Equipment Lubrication
9
-------
Ibs). The grease would be released to the water in the immediate vicinity of the lift cable during
deployment/retrieval of the SLQ-48 MNV since the vessel is stationary. The potential for
environmental impact from this operation was estimated by determining the volume of water into
which the grease would have to be dispersed to attain a concentration equal to the most stringent
state water quality criteria: Florida's criteria of 5,000 pg/L, or 5 mg/L.
j
The calculated volume required for dilution of lubricant in the environment from the
SLQ-48 MNV lift cable was based on the following assumptions:
i
• the top of the vehicle is covered by one foot of water during launching;
• the grease released is directly above the vehicle; and
* the lubricant disperses only in the horizontal plane; that is, the body of the vehicle
prevents vertical dispersion
I
Based on these assumptions, the distance from the source beyond which the concentration
is less than the most stringent water criteria (Florida), was estimated as follows:
1) (0.0094 Ibs grease)(453.6 g/lb) = 4.3 g; equal to 4300 mg grease
2) 4300 mg-^ (Vol.) = 5.0 mg/L; Vol. = 860 L required
3) (860 LK1ft*/28.32 L) = 30.36 ft3
4) 30.36 ft3 = (1 ftfHXK^); rearranging and solving for r, r = 3.1 feet
ii
At a distance of approximately 3 feet beyond the lifting cable, the concentration of the
grease is less than the most stringent water quality criteria.
j
4.2.3 O-type Mechanical Gear

From Table 4 and the discussion in Section 3.2, the maximum amount of lubricant
released from O-type mechanical gear is 26 ounces (1.63 Ibs). Each lubricated component (26
total components) of the O-type gear is a separate discharge point, has a cross-section of 48 in2
(0.33 ft2), and sweeps a volume of water equal to its cross-section multiplied by the distance
towed through the water at seven knots. Operations with O-type gear deployed are limited to
speeds of 7 to 8 knots (42,533 to 48,609 ft/hr).'"
14
The equipment may remain deployed for several days (Section 3.2). Thus, the lubricants
that are released from the equipment to the environment during minesweeping exercises with O-
type mechanical gear will be dispersed over several miles.
i
i
An estimate of the concentration of lubricant in the environment was made based on the
following assumptions:

Mine Countermeasures Equipment Lubrication
10
-------
At 7 knots (42,533 feet per hour), the volume of water swept by the equipment during the
training exercise was estimated as follows:
Volume = (# of componentsXCross^sectional area of each, cbmponent)(Time)(Speed)
^ Volume = (26X0.33 square feet)(24hours)(42,533 Mir)
^Volume = 8.76 x ia6 cubic feet (ft3) of water r
Based on the assumptions listed above and the volume of water through which the
equipment is towed, the lubricant concentration in the environment was estimated as follows:
Mass lubricant

Volume of water
Concentration ,
= (1.625 Ibs lubricant)(453.6 g/lb)(1000 mg/g),
= 737^100 mg lubricant *,;, / . "
* = (8 J6 x* 10* 1^(28.32 L/ft3) « 2.48 x 108 L
= 737,100 mg/2.48 xJO8 L
= 2.97, x 10~3 mg/L; or 2.97 fig/L in a 24-hour period
This concentration is three orders of magnitude less than Florida's discharge standard of
5,000 fig/L and is based on the conservative assumption that the equipment is in the water for
only 24 hours.

4.2.4 Acoustic and Magnetic Mine Detonators
Volume =, (Number of components)(Crossrsectiorial area of each,
component)(Time)(Speed),
Volume = (26 components)(0.33 ft)(24 hours)(42,533 ft/hr) ,
Volume = 8.76 x 106 ft3 of water
From Table 4 and the discussion hi Section 3.2, the maximum amount of lubricant
released from acoustic and magnetic mine detonation devices is five ounces (0.3125 pound).
Operations are usually performed at speeds of 7 to 8 knots (42,533 to 48,609 ft/hr). As with the
O-type mechanical gear, the equipment may remain deployed for several days. Thus, any
lubricant removed from the equipment will be dispersed into a large volume of water.

An estimated lubricant concentration was made based on the following assumptions:

• the equipment is deployed for 1 day; or 24 hours
• the rate of lubricant discharge is uniform throughout the exercise;
• the lubricant is uniformly dispersed throughout the traversed water volume;
• the acoustic device has a frontal area equivalent to a 36-inch diameter disk (7.07
square feet) (this assumption is based on allowing space for the housing around
Mine Countermeasures Equipment Lubrication
11
-------
II
the acoustic device), plus a 2- by 4-inch (0.055 ft2) swivel.
i

At 7 knots (42,533 ft/hr), the volume of water swept by the equipment during the training
exercise was estimated as follows:
Volume = (Area)(Time)(Speed) "
Volume = (7.07 -H 0.055 square feet)(24 hours)(42,533 ft/hr)
Volume = 7.27 x 106 ft* of water
Based on the assumptions listed above and the volume of water through which the
equipment is towed, the lubricant concentration in the environment was estimated as follows:
Mass lubricant

Volume of water
Concentration
= (0.3125 Ibs lubricant)(453.6 g/lb)(1000 mg/g)
= 141,750 mg lubricant
= (7.27 x 106 ft3)(28.32 I/ft3) « 205,886,400 L
= 141,750 mg/205,886,400 L
= 6.88 x lO'Vg/L; or 0.688
This estimated concentration of 0.688 ug/L is three orders of magnitude below the most
stringent water quality criteria.

4.2.5 Water Quality Criteria and Discharge Standards

Table 5 shows water quality criteria and discharge standards that are relevant to the mine
CQuntermeasufes equipment lubrication discharge and the estimated environmental
concentrations of the constituents of the discharge.
|
4.3 Potential for Introducing Non-indigenous Species

Mine countermeasures operations do not result in water being transported from one
geographical region to another. Any non-indigenous species which may become attached to
countermeasures equipment while deployed are removed during equipment retrieval operations
or subsequent preventive maintenance activities. For example, automatic cable layers remove
virtually all of the water from the cable(s) as they are retrieved, and maintenance procedures
require freshwater washdowns of the retrieved equipment such as cutters and swivels. Further, it
is unlikely that any attached aquatic species would survive while the countermeasures equipment
is stored on deck. Therefore, there is no significant potential for transporting non-indigenous
species.
5.0 CONCLUSIONS

Mine countermeasures equipment lubrication discharge has little potential for causing
Mine Countermeasures Equipment Lubrication
12
-------
adverse environmental effects because the small amounts of lubricants that are released disperse
into very large volumes of water. The resulting concentrations are below the most stringent
water quality criteria.

Further, most discharges from mine countermeasures equipment occur beyond 5 n.m.
from shore in high-energy waters (i.e., those with significant wave energy to rapidly and widely
disperse releases) and are unlikely to affect more sensitive coastal environments.

This conclusion is based on estimated environmental concentrations of lubricants
resulting from each of the mine countermeasures operations. For each operation, the estimated
concentration was below the most stringent water quality criteria. Estimates were based on either
the volume of water through which mine countermeasures equipment operates, or the volume
required to dilute the discharge to levels below the most stringent water quality criteria.

Finally, for mine countermeasures operations there is no potential for transporting non-
indigenous species.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained, reviewed,
and analyzed. Process information and assumptions were used to estimate the rates of discharge.
Based on these estimates, the concentrations of lubricants in the environment resulting from this
discharge were then estimated. Table 6 shows the sources of data used to develop this NOD
report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Mine Countermeasures Equipment
Lubrication. 5 September 1996.

2. BM2 Hamilton, USS Champion (MCM 4), Information on Oil and Grease Lubrication
Procedures, 23 July 1997, Jim O'Keefe, MR&S.

3. CDR Burdon, OPNAV Mine Warfare Branch (N852), Information on Mine
Countermeasure Training Areas and Operations, 6 August 1997, Jim O'Keefe, MR&S.

4. UNDS Round 2 Equipment Expert Meeting Minutes, Mine Countermeasures Equipment
Lubrication, 6 March 1997.

5. LCDR Sentlinger, XO on an MCM 1 Class Ship Based in Ingleside, TX, Information on
Lubrication Procedures, 19 March 1997, Sanjay Chandra, Versar Inc.

6. LCDR Shaun Gillilland, OPNAV, Mine Warfare Branch, Information on SQQ Sonars
and Acoustic Detonator Operations, 20 January 1999, Jim O'Keefe, MR&S.
Mine Countermeasures Equipment Lubrication
13
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II
7. Polmar, Norman. The Naval Institute Guide to the Ships and Aircraft of the U.S. Fleet,
16th ed., Naval Institute Press, 1997, Chapter 22.
I
8. Andy Tatem, Naval Undersea Warfare Center, Panama City, FL, Information on Oil and
Grease Lubrication Procedures, 24 July 1997, Jim O'Keefe, MR&S.
i
9. Maintenance Requirements Cards (MRCs) for Minesweeping Systems 4761.
I
i
a. MRC Control No. 47 8GGD N - Clean, inspect, and lubricate snatch blocks.
b. MRC Control No. 47 8GGE N - Clean, inspect, and lubricate swivels.
c. MRC Control No. 47 8GGF N - Clean, inspect, and lubricate shackles.
d. MRC Control No. 47 4MNR N - Inspect A Mk 4 (V) acoustic device diaphragm.
e. MRC Control No. 86 2WTT N - Clean cutter assembly.
f. MRC Control No. 86 2WTR N - Clean, inspect, and lubricate cutter.
g. MRC Control No. 86 2WTQ N - Clean and inspect cutter assembly.

10. STG1 KeUy, Fleet Liaison Office, Naval Surface Warfare Center (NSWC), Coastal
Systems Station, Panama City, Florida, Information on Oil and Grease Lubrication
Procedures, 12 August 1997, Jim O'Keefe, MR&S.
1! '!" jj
I
11. William Coffhian, NSWC, Coastal Systems Station, Panama City, Florida, Information
on Mine Neutralization Vehicle, 12 August 1997, Jim O'Keefe, MR&S.
1 i
12. CDR Piper, OPNAV Mine Warfare Branch (N852), Information on Mine Neutralization
Vehicle, 6 August 1997, Jim O'Keefe, MR&S.
ij
i
13. Military Specification MIL-G-18458B; "Grease Wire Rope, and Exposed"; March 1981,
Revision B, Amendment 5; and March 1996 Revision B.

14. STG1 Kelly, Fleet Liaison Office, NSWC, Coastal Systems Station, Panama City,
Florida, Information on Oil and Grease Lubrication Procedures, 13 August 1997, Jim
O'Keefe, MR&S.

15. Andy Tatem, NSWC, Coastal Systems Station, Panama City, Florida, Information on Oil
and Grease Lubrication Procedures, 23 July 1997, Jim O'Keefe, MR&S.

16. Patty's Industrial Hygiene and Toxicology, Volume OB, 3rd. ed., John Wiley & Sons,
1981, pp. 3369, 3397.

17. Quang Tran, NAVSEA Equipment Expert, Information on Mine Neutralization Vehicle,
20 August 1997, George Heiner, Malcolm Pirnie Inc.
Mine Countenneasures Equipment Lubrication
14
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General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance — Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
Mine Countermeasures Equipment Lubrication
15
-------
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Mine Countermeasures Equipment Lubrication
16
I,
-------
Figure 1. Mine Countermeasures Equipment on Deck
Mine Countermeasures Equipment Lubrication
17
-------
Float
Sweep Wire
-------
Table 1. Vessels Producing Mine Coimtermeasures Equipment Lubrication Discharge
';:^r""Snip;:^ss
MHC 51 (Osprey)
MCM 1 (Avenger)
^ * Mission- * , _~"
Harbor and channel clearing; deep water coastal
minehunting
Non-conventional minesweeping and detonation
Number of Vessels
9
14
Table 2. Lubricant Type and Schedule for Wetted Mine Countermeasures Equipment
- Component
Cutters
Snatch blocks
Swivels
Shackles
Towed acoustic device
(diaphragm)
Multi-purpose crane lift wire
for handling the SLQ-48 MNV
SLQ-48 MNV arms
' Applicable
-.Ship Classes
MCM 1 Class

MHC 51 Class
MHC 51 and
MCM 1 Class
Lubricant Mil
' Standard
MIL-L-9000
MIL-L-3150
MIL-G-23549
MIL-G-23549
DOD-G-24508
MIL-G-18458B
DOD-G-24508
Lubrication Schedule
After each use
Prior to and after each use
Quarterly, and prior to and after each use
Quarterly, and prior to and after each use
Quarterly, after each streaming, or as a
result of a sound measuring test
Annually, or as required
Prior to each use
*G = grease, L = lubrication oil
Mine Countermeasures Equipment Lubrication
19
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Table 3a. Percentage of Constituents of Military Specification Oils and Greases
Component
Base Constituents
asphalt
hydrocarbons
mineral oil (unspecified)
polyalphaolefins
solvent refined, hydrotreated heavy
parafiinic distillate
solvent refined, hydrotreated residual
oil
Additives
1-nsphthalencamine, n-phenyl
4-hydroxy-3, 5-di-tert-
butylphenylpropionic acid
thioclycolate
bcnzenepropanoic acid, 3,5-bis(l,l-
dimethylM-hydrooxyoctadecyl ester
calcium acetate
calcium phenate
calcium sulfonate
clay
Lithium Soaps
p,p-diocryldiphenlamine
pcntacrythritol
polymers (unspecified)
sodium chromatc, tetrahydrate
sodium nitrate
sodium phosphate, tribasic
MIL-G-18458B
wire rope
grease3

>54

MIL-k-9000
engine oil

55-70
20-30

<15

DOD-G-24508
ball and roller
bearing grease''

70-80

5-10

<1
<2

DOD-G-24508
ball and roller
bearing grease"

<2
<3

<10

<2
1

1
<1
.MlL-G-23549
-general purpose
grease

MIL-L-3150
general purpose
lube oil

45-50
30-60

Source: Ingredients/Identity Information section of lubricant-specific material safety data sheets from DoD
Hazardous Materials Information System
a Amendment 5 to MEL-G-18458B, March 26,1996, prohibits heavy metals (including lead) and salts of heavy
metals as constituents of MIL-G-18458B grease.
b As manufactured by Royal Lubricants Company Inc.
0 As manufactured by Mobil Oil Company Inc.

Mine Countermeasures Equipment Lubrication
20
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Table 3b. Maximum Concentrations from SLQ-48 Arms
TOTAL RELEASE PER EXERCISE: 4 oz. ; . . .- ' " ,
GREASE RELEASED: DOD-G-24508 (100%) ' . "V "/'
ESTIMATED TOTAL MAXMOM£ONC^^ , ' .• ' -
/ J"1
; f J * v
Component ",:, • ,?
Base Constituents
mineral oil (unspecified)
polyalphaolefins
Additives
1-naphthaleneamine, n-phenyl
benzenepropanoic acid, 3,5-bis(l,l-
dimethyl)-4-hydrooxyoctadecyl ester
calcium acetate
clay
p,p-dioctyldiphenlamine
pentaerythritol
sodium chromate, tetrahydrate
sodium nitrate
sodium phosphate, tribasic
-« ~
DOD-G-24508 bail and
• roller bearing grease3-- -
-

70-80
» "?™

<5
5-10

<1
<2

' *" '
DOD-G-24508 ball and
roller bearing grease^
^ * ' ' „
80

<2
<2
<3
<10
<2
1

1
<1

'' " Maximum .
Concentration (Mg/I-)
-
5.8
5.8
1
0.15
0.15
0.37
0.73
0.15
0.07
0.07
0.15
0.07
Table 3c. Maximum Concentrations from O-Gear and Cutters
TOTAL RELEASE PER EXERCISE: 26 oz. , • >
GREASE RELEASED: MIL-G-23549 (53.8%); MEL-L-3 150 (7 .7%)j MIL-L-9000 (30.8%) >,
ESTIMATED TOTAL MAXIMUM CONCENTRATION: 2.97 ns/L ,
*
Component
Base Constituents
hydrocarbons
mineral oil (unspecified)
solvent refined, hydrotreated heavy
paraffinic distillate
solvent refined, hydrotreated residual oil
Additives ' „
4-hydroxy-3, 5-di-tert-
butylphenylpropionic acid thioclycolate
calcium phenate
calcium sulfonate
* t t
MIL-L-9000
engine oil

55-70
20-30
-

<15

r -^
MIL-G-23549
genera! purpose
"grease
*

51
<
<1

4
,
MIL-L-3150
general purpose
iubeoil

45-50
30-60

••

-
\ t Maximum
Concentration
(VS/L)

0.11
0.14
0.64
1.09
t
0.02
0.14
0.06
a As manufactured by Royal Lubricants Company Inc.
b As manufactured by Mobil Oil Company Inc.
Mine Countermeasur.es Equipment Lubrication
21
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Table 3d. Maximum Concentrations from Acoustic and Magnetic Devices
TOTAL RELEASE PER EXERCISE: 6 oz. ;: ^ i
GREASE RELEASED: DOD-G-24508 (67%), MIL-G-23549 (33%) /
ESTIMATED TOtAL MAXIMUM CONCENTRATION: 0.688 ng/L i " ,
Component
Base Constituents
mineral oil (unspecified)
Polyalphaolefins
solvent refined, hydrotreated residual oil
Additives
1-naphthaleneamine, n-phenyl
4-hydroxy-3, 5-di-tert-
butylphenylpropionic acid thioclycolate
benzenepropanoic acid, 3,5-bis(l,l-
dimethyl)-4-hydrooxyoctadecyl ester
calcium acetate
calcium sulfonate
clay
p,p-dioctyldiphenlamine
pentaerythritol
sodium chromate, tetrahydrate
sodium nitrate
sodium phosphate, tribasic
DOD-G-24508
ball and roller
bearing grease3

70-80

5-10

<1
<2

DOD-G-24508
ball and roller
bearing grease"

<2
<3

<10
<2
1

1
<1
MIL-G-23549
general purpose
•• . '-grease' ",. '.•

Maximum
Concentration
: (W5/L>: ;

0.425
0.369
0.116

0.009
0.002
0.009
0.037
0.009
0.092
0.009
0.005
0.005
0.014
0.005
8 As manufactured by Royal Lubricants Company Inc.
b As manufactured by Mobil Oil Company Lac.
Mine Countermeasures Equipment Lubrication
22
-------
Table 4. Estimated Annual Lubricant Mass Loading
f - ^
/Source r
MHC 51 Class
SLQ-48 MNV arms
SLQ-48MNVLift
Cable
MCM 1 Class
SLQ-48 MNV arms
O-gear, cutters
Acoustic and Magnetic
Total Mass Loading
'jQuantityper-
Exercise (oz)

4
0.15

4
26
5

Yearly, Number
of Exercises

240
240

12
6
6

Number of.
Vessels

9
9

14
14
14

Total Release
(oz/yr)

8,640
324

672
2,184
420
12,240
1 Total Release
(Ibs/yr)

540
20

42
137
26
765
Table 5. Water Quality Criteria and Discharge Standards
Source and
, Constituent
SLQ-48 arms
oil and grease
SLQ-48 MNV Lift Cable
oil and grease
O-gear, cutters
oil and grease
Acoustic and Magnetic
oil and grease
Environmental
Concentration
(Hg/L>

7.3"

30ft3c

2.97

0.688
1 Federal Discharge
Standards (pg/L)

Visible sheen* 715,000**

Visible sheen* 715,000**
Most Stringent State Acute
Water Quality Criteria8
ftig/L) ,

5,000 (FL)

5,000 (FL)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)

* Discharge of Oil. 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen
on receiving waters.
** International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as
implemented by the Act to Prevent Pollution from Ships (APPS).
aFL = Florida
b Estimated
c Volume required to disperse to most stringent water quality standard

Mine Countermeasures Equipment Lubrication
23
-------
Table 6. Data Sources
Data Source
NOD report Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
23 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
43. Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
Reported

UNDS Database

PMS Cards
MSDS

Sampling

Estimated

X
X

Equipment Expert
X
X
X
X

X
Mine Countermeasures Equipment Lubrication
24
-------
NATURE OF DISCHARGE REPORT
Motor Gasoline (MOGAS) Compensating Discharge
1.0 INTRODUCTION

This section describes the MOGAS discharge and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3). This
discharge maybe referred to as "Motor Gasoline (MOGAS) and Compensating Overboard
Discharge" hi other documents.

2.1 Equipment Description and Operation
I
MOGAS is commercial gasoline identical to that supplied to gas stations for automobile
use. It is carried aboard certain Navy, U.S. Coast Guard (USCG), Military Sealift Command
(MSQ, and Army vessels as fuel for vehicles, special warfare operational craft, portable bomb
hoists, crash saws, and any other gasoline-operated, ship-support equipment.
i
i
The USCG, MSC, Air Force, and Army have no vessels with fixed MOGAS storage.
Most vehicles and equipment are brought aboard fully loaded with fuel, and additional MOGAS
is carried in portable drums or containers. On some Navy vessels, additional MOGAS is stored
for replenishment purposes hi permanently installed seawater-compensated tanks as shown hi
Figure 1. Compensating seawater is supplied at a pressure sufficient to force gasoline to the
suction side of the gasoline pumps, and keep the tank full to prevent potentially explosive
gasoline vapors from forming. Several methods are used to supply seawater to the tanks.
Aboard amphibious transport dock (LPD 4 Class) ships, two dedicated seawater pumps take
suction directly from the sea chest. On amphibious assault (LHA 1 Class) ships, seawater can be
supplied one of two ways: 1) a compensating tank with a capacity of 8,000 to 10,000 gallons of
seawater is installed such that water drains by gravity to the fuel tank as necessary; or 2) booster
pumps located hi the pump room supply seawater to the fuel tanks.
: ' I
Immediately before a major overhaul, and in accordance with existing management
practices, ships with permanently installed seawater-compensated MOGAS tanks will unload any
remaining fuel to tanker trucks on the pier and transit out to beyond 50 nautical miles (n.m.).
Using seawater pumps, the MOGAS tanks and system piping are flushed with three tank volumes
of seawater. Air pressure is used to force the seawater out of the tank, after which steam is used
to clean the tank and "cook-off' any remaining fuel remnants. The MOGAS tanks are then filled
with seawater and the ship returns to port for the overhaul.
!
i!
After overhaul and before re-deployment (approximately once a year) the vessel receives
MOGAS from pierside tanker trucks. MOGAS that is on-loaded displaces the compensating
seawater hi the tank, pushing it overboard. Several management practices are in place to ensure
that MOGAS is not discharged overboard during refueling operations. Without these
management practices, there is a potential to cause an oil sheen in the surrounding waters. First,
the MOGAS tanks are filled to no more than 80% of capacity.1 The amount of fuel needed is
calculated before loading, and the tanker truck is only filled with a volume of MOGAS such that
completely filling a MOGAS tank with the entire contents of the truck would not cause the tank
to overflow. Additionally, watch personnel are stationed at strategic locations on and around the
i
Motor Gasoline (MOGAS) Compensating Discharge
-------
ship and pier to observe refueling operations and report any abnormalities. Containment devices
are placed around all refueling hose connections to contain any fuel spills or leaks, and
containment booms are placed in the water around the ship being refueled.

An additional management practice controls the rate at which MOGAS is supplied from
the tanker trucks. Small-diameter hoses (usually two inches) are used to deliver fuel at a flow
rate of 50 gallons per minute (gpm) or less, that, in conjunction with diffusers built into the tank
filling system piping, reduces turbulence and minimizes mixing of gasoline and seawater.

2.2 Releases to the Environment

The discharge consists of seawater used to replace, or compensate for, the space created
in MOGAS tanks as the fuel is consumed. This seawater is discharged overboard as the
MOGAS tank is refilled with gasoline. It is possible that this compensating seawater discharge
overboard could contain traces of dissolved gasoline constituents.

2.3 Vessels Producing the Discharge

The USCG, MSC, Air Force, and Army have no vessels with fixed MOGAS storage, and
therefore do not contribute to this discharge.2'3'4 Eight LPD 4 Class, and five LHA 1 Class ships
currently have installed MOGAS storage tanks that discharge compensating water during
refueling. One LPD and one LHA Class ship are homeported overseas.

The most significant difference between LPD 4 and LHA 1 Class ships is MOGAS
capacity. LPDs have a capacity to carry 26,000 gallons of MOGAS. LHAs have a capacity to
carry 11,400 gallons of MOGAS.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Refueling always takes place pierside, and compensating seawater is discharged directly
overboard as oncoming fuel displaces the seawater.

3.2 Rate

Tanker trucks with small diameter hoses (usually two inches) are used to deliver MOGAS
to ships. The fill rate from these trucks is normally limited to 50 gpm or less. With the MOGAS
tanks always full of seawater and fuel, compensating water is displaced directly overboard at the

Motor Gasoline (MOGAS) Compensating Discharge
3
-------
same rate as the incoming fuel.
ii

The estimated amounts of compensating seawater discharged annually from ships with
MOGAS storage tanks are presented in Table 1. The values in Table 1 are based on the
operational experience of one refueling per ship per year, with a maximum of 80% of the tank
capacity being displaced overboard by onloaded fuel.
» |i
3.3 Constituents
i
MOGAS is a hydrocarbon based unleaded fuel containing over 150 individual
compounds. The types of compounds found in gasoline include alkanes, alkenes, aromatics,
metals, and additives. Most of these compounds are a very small fraction (less than 2%) of
gasoline. The compounds that individually comprise at least 2% of gasoline include butane,
pentane, hexane, isopentane, methylpentane, dimethylpentane, trimethylpentane,
trimethylhexane, benzene, toluene, xylene, methyl-3-ethylbenzene, trimethylbenzene, and
ethylbenzene. The exact composition of gasoline is unknown because gasoline manufacturers
constantly adjust theh" product to meet performance, emissions, and cost demands.5 Due to the
variable composition and the different water solubilities of the individual components of
gasoline, it is difficult to determine the solubility of MOGAS.
i!
To identify the constituents in this discharge, two studies that determined the water
soluble components of gasoline, as well as their solubilities, were used. The first study was
conducted by the Naval Biosciences Laboratory in 1983, and the second was conducted in 1992
for a workshop on petroleum hydrocarbons.5'6 Both studies measured the water soluble
constituents of gasoline by placing gasoline on top of water, agitating the water, allowing
equilibrium to be established, and analyzing the water through gas chromatography. In these
analyses, a water fuel interface was established very similar to the interface within MOGAS
tanks, m both cases, the water was removed from the bottom of the container to be analyzed,
ensuring that emulsified fuel was not being measured. Since gasoline composition has changed
over the years, the study performed in 1992 is considered to be more representative of current
MOGAS constituents. The constituents identified in this study that are soluble hi water are listed
hi Table 2.5 Benzene, toluene, ethylbenzene, phenol, and naphthalene are priority pollutants.
None of these compounds are bioaccumulators.
!!
3.4 Concentrations
I .
i
The concentrations of the water soluble gasoline constituents hi the MOGAS
compensating discharge are estimated from the studies performed to determine the solubility of
gasoline components in water. The 1983 study reported a range of constituent concentrations
based on the source of the gasoline. Benzene concentrations ranged from 19.1 to 42.5 milligrams
per liter (mg/L), toluene from 17.3 to 61.4 mg/L, and xylenes from 9.5 to 27.7 mg/L.6 The 1992
study provided a more detailed account of the concentrations, which all fell within the ranges
reported in the 1983 study.5 The estimated concentrations of MOGAS components present in the
compensating overboard discharge are shown hi Table 2.
Motor Gasoline (MOGAS) Compensating Discharge
4
-------
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. hi Section 4.2, the concentrations of discharge constituents
are compared with the water quality criteria, hi Section 4.3, the potential for the transfer of non-
indigenous species is discussed.

4.1 Mass Loadings

Using the fleet wide MOGAS compensating water annual discharge volumes presented hi
Table 1, and the estimated constituent concentrations in Table 2, the total mass loadings for the
priority pollutants present in this discharge were calculated using the following formula:
Mass Loading (lbs/yr),=
- -. (Concentration (
Table 3 provides the resulting mass loadings on a maximum discharge per event basis and
on a total annual fieetwide basis.

4.2 Environmental Concentrations

As identified in Section 3.3, the constituents of concern are benzene, toluene,
ethylbenzene, xylene isomers, phenol, and naphthalene. The estimated constituent
concentrations in MOGAS compensating water discharges, and the corresponding most stringent
state water quality criteria (WQC), are presented hi Table 4. Benzene, toluene, ethylbenzene,
phenol, and naphthalene concentrations exceed the most stringent state WQC. There are no
relevant Federal or state WQC for xylene isomers.

4.3 Potential for Introducing Non-Indigenous Species

hi those instances where vessels receive MOGAS prior to deployment and no overhaul
period is pending, the possibility of non-indigenous species transport exists. Water from
different ports could have entered the tanks during the previous deployment to compensate for
consumed fuel. When shipboard MOGAS tanks are emptied of fuel, flushed, steam-cleaned, and
then filled with seawater while in deep water before returning to port for overhaul, there is no
significant possibility of non-indigenous species transport. Therefore, depending on the
operational procedures and the deployment of the vessels, there may be a potential for the
transfer of non-indigenous species.
5.0 CONCLUSIONS

MOGAS compensating discharge has the potential to cause an adverse environmental

Motor Gasoline (MOGAS) Compensating Discharge
5
-------
effect because there is a potential to cause an oil sheen in the waters surrounding the ship.
Additionally, the possibility exists for the transfer of non-indigenous species, depending on the
operational procedures of a particular vessel and the deployment schedule.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information was used to estimate the volume of discharge. Table 5 shows the source of the data
used to develop this NOD report.

Specific References
1 i
1. UNDS Equipment Expert Meeting Minutes. Motor Gasoline (MOGAS) Storage and
Compensated Overboard Discharge. October 23,1996.
I
2, Personal Communication Between LT Joyce Aivalotis (U.S. Coast Guard) and David
Ciscon (M. Rosenblatt & Son). May 28,1997.

3. Personal Communication Between Penny Weersing (Military Sealift Command Central
Technical Activity) and Don Kim (M. Rosenblatt & Son). October 24,1996.
' i
I
4. US Army Input to Equipment Expert Meeting, Motor Gasoline (MOGAS) Storage and
Compensated Overboard Discharge. February 7,1997.

5. Bruya, James E., Petroleum Hydrocarbons: What are they? How much is present? Where
do they go? Friedman & Bruya, Inc., Seattle, WA. April 1992.
i
6. Guard, Harold E. and Roy B. Laughlin, Jr., Characterization of Gasolines, Diesel Fuels &
Their Water Soluble Fractions. Naval Biosciences Laboratory, Oakland, CA., September
1983.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Motor Gasoline (MOGAS) Compensating Discharge
6
-------
Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. 62, Number 150. August 5,1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii, Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Motor Gasoline (MOGAS) Compensating Discharge
7
-------
GASOLINE LINE
SEAWATER LINES
GASOLINE
FIGURE 1
SEAWATER COMPENSATED
MOGAS
STOWAGE TANK
Motor Gasoline (MOGAS) Compensating Discharge
8
-------
Table 1. Estimated Total Amounts of MOGAS Compensating Seawater Displaced
Overboard Annually by Vessel Class in U.S. Ports
Vessel
Class
LPD
LHA
No. of ,
Vessels in
~ , U.S.
7
4
jMOGAS Tank
Capacity Per
Vessel (gal)
26,000
11,400
Total Tank
Capacity (gal)
* /"
182,000
45,600
Volume of Compensating
, ^Seawater Discharged ,
Overboard Per Year*
145,600
36,480
Estimated Total: 182,080
Based on one complete in-port refueling per year per vessel, and a maximum of 80% of the tank capacity being
displaced overboard by onloaded fuel
Table 2. Estimated Constituent Concentrations in MOGAS Compensating
Overboard Discharge5
Compound
Methyl-t-butyl ether (MTBE)
Benzene
Toluene
Xylene Isomers (3)
Ethylbenzene
Cs and Ce Alkenes and Alkadienes
Ci to C4 Phenols
Ca to Cs Benzenes
Co to Cs Anilines
Co to C2 Thiophenes
Co to C2 Indanes and Indenes
Co to Cz Naphthalenes
Co to €2 Pyridines
Co to €2 hidoles
Concentration (mg^Ef I
116
29.5
42.6
14.7
2.4
0.5
1.2
6.8
3.7
1.3
1.2
1.2
0.4
0.3
Motor Gasoline (MOGAS) Compensating Discharge
9
-------
Table 3. Estimated Annual Mass Loadings
Constituent
Benzene
Toluene
Xylene Isomers (3)
Ethylbenzene
Phenols
Naphthalenes
Estimated
Concentration In
Discharge (mg/L)
29.5
42.6
14.7
2.4
1.2
1.2
Maximum Discharge
Event Mass Loaduig*
(Ibs)
5.1
7.4
2.5
0.4
0.2
0.2
Total Fleetwide
Mass Loading^* (Ibs)
45
65
22
4
2
2
* Based upon a maximum discharge event volume of 20,800 gallons from an LPD 7 (assuming a maximum of 80%
of the 26,000 gallon tank capacity being displaced overboard by onloaded fuel)
** Based upon a total annual discharge volume of 182,080 gallons
Table 4. Comparison of Estimated Discharge Concentrations with Water Quality Criteria
Constituent
Benzene
Toluene
Ethylbenzene
Phenols
Naphthalenes
Concentration
(mg/L)
29.5
42.6
2.4
1.2
1.2
Federal Acute
WQC (mg/L)
None
None
None
None
None
Most Stringent State Acute
WQC(mg/L>
0.07128 (FL)
2.1 (HI)
0.14 (HI)
0.17 (HI)
0.78 (HI)
Notes:
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.
I
FL = Florida
HI = Hawaii
I
Motor Gasoline (MOGAS) Compensating Discharge
10
-------
TableS. Data Sources
•*'"«/* v
>-~ ^ NOD Section
2,1 Equipment Description and
Operation - -
2.2''Releases4otheEnviroan»ent ,""/
2.3 Vessek producing flie Discharge
3.1 Locality
3.2 Rate
3,3 Constituents '"
3,4 Concentrations
4,1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
^ - ' Data Source /n ~
Reported

UNDS Database
X

X
X

, Sampling

Estimated

X
X
X
X
X

Equipment Expert
X
X
X
X
X
X
X
X
X
X
Motor Gasoline (MOGAS) Compensating Discharge
11
-------
-------
NATURE OF DISCHARGE REPORT
Non-oily Machinery Wastewater
1.0 INTRODUCTION

This section describes the non-oily machinery wastewater and includes
the equipment that is used and its operation (Section 2.1), general description of the
of the discharge (Section 2.2), and the vessels that produce this discharge (Section

2.1 Equipment Description and Operation
information on:
constituents
2.3).
,i
The primary purpose of the non-oily machinery wastewater system is to segregate
machinery wastewater from the wastes that collect in bilges so that non-oily machinery
wastewater can be directly discharged overboard. This reduces the amount of bilgewater that
needs to be treated with oil water separators (OWS) prior to discharge. Dedicated drip pans,
runnels, and deck drains comprise the non-oily machinery wastewater system and collect non-
oily machinery wastewater that is generated below the ship's waterline in machinery spaces.
Non-oily machinery wastewater from systems and equipment located above a ship's waterline is
often drained directly overboard. By separately collecting and preventing non-oily machinery
wastewater from mixing with oily wastewater, non-oily wastewater is discharged without going
through an OWS system.
I
; i
For the systems below the waterline, non-oily machinery wastewater drains into the non-
oily machinery wastewater drain tanks (generally one per machinery space) which have dedicated
pumps that discharge directly overboard. These pumps normally operate automatically under
control of high- and low-level sensors. Non-oily machinery wastewater tanks range in size from
100 gallons for smaller ships to 2,500 gallons for aircraft carriers. Figure 1 is a diagram of a
typical non-oily machinery wastewater system.

The main sources of water to the non-oily machinery wastewater are:
• distilling plants start-up
discharge,
• bleed air system leaks,
• chilled water condensate drains,
• fresh and saltwater pump
drains,
• potable water tank overflows,
• leaks from propulsion shaft
seals,
• low & high pressure air compressor
condensate,
• leaks from valve stems and manifolds,
• seawater and freshwater relief valve
leaks,
• leaks from pump packing gland seals,
• seawater duplex strainer leaks,
• propulsion engine jacket water cooler
drains.
Non-oily Machinery Wastewater
2
-------
In limited cases, steam condensate is combined with non-oily machinery wastewater in the non-
oily machinery wastewater drain tank. The combined wastewater are discharged overboard
below the waterline. Information on steam condensate is provided in the steam condensate NOD
report.

Of these listed non-oily machinery wastewater sources, distilling plants may be the major
source of non-oily machinery wastewater. Distilling plants desalinate seawater to produce
potable, boiler feed, and equipment cooling water. The freshwater initially produced by the
distilling plants during start-up is normally discharged either overboard or to the non-oily
machinery wastewater system until acceptable specified salinity levels are achieved. This period
normally lasts about 15 minutes, at which time the discharge is discontinued. Also, the quality of
the water produced during the normal operation of the distiller plants may occasionally be
unsatisfactory; this water is discharged in the same manner as during start-up.

2.2 Releases to the Environment

The constituents of this discharge include potable water and seawater, metals from
contact with tanks and piping, and other constituents associated with the construction and
operation of the non-oily machinery wastewater system and equipment served by the system.
The discharge either drains directly overboard continuously as it is produced, or is pumped
overboard intermittently from non-oily machinery wastewater tanks.

2.3 Vessels Producing the Discharge

Non-conventionally powered Navy surface vessels and all newly constructed and some
older conventionally-powered vessels have dedicated non-oily machinery wastewater systems.
Most Military Sealift Command vessels and some of the older conventionally powered Navy
ships do not have a separate non-oily machinery wastewater system, so the non-oily wastewater
drains to the bilge.1 U.S. Coast Guard vessels and small boats and craft of the Armed Forces do
not have any dedicated non-oily machinery wastewater collection systems; instead, the non-oily
machinery wastewater, which is mixed with bilgewater, is generally collected for shore side
treatment as bilgewater. In addition, Army and Air Force vessels do not have separate non-oily
machinery wastewater systems; this type of wastewater is drained directly to the bilge.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

This discharge occurs in port, during transit, and at sea.

Non-oily Machinery Wastewater
3
-------
3.2 Rate
j
The generation rate and discharge frequency of non-oily machinery wastewater varies
considerably according to the mode of ship operation and its equipment operating status. This
was demonstrated by the results of the recent flow characterization study of non-oily machinery
wastewater onboard the following vessels: CVN 74, DDG 67, LHD 5, and LSD 44.2 A
cumulative discharge flow rate of 97,057,740 gallons/year was estimated for the vessel classes
that these vessels represent. Non-oily machinery wastewater flow rates by vessel class were
established by using the following formula:
Vessel Class Flow Rate = (# vessels/ship class)(flow rate)(# of days in port/ year)

CVN 68 Class = (7 vessels)(41,200 gal/day)(147 days in port/year) = 42,394,800 gal/year
Machine-specific non-oily machinery wastewater sources can generate volumes ranging
from a few drips per minute in the case of small pumps and valves, to several thousand gallons
per hour (gph) in the case of distilling units releasing their output during plant start-up. The
volume of distillate directed to the non-oily machinery wastewater system during start-up ranges
from less than 100 gph to about 4,000 gph depending on the size of the plant.

3.3 Constituents
li
Non-oily machinery wastewater discharge samples were obtained from four Navy ships.
Samples were collected aboard an aircraft carrier (CVN 74), an amphibious assault ship (LHD 1),
a dock landing ship (LSD 51) and a guided missile destroyer (DDG 57).3 See Table 1 for the
concentrations of constituents detected in shipboard non-oily machinery wastewater discharge
samples. Table 2 lists a bioaccumulator and constituents that were detected in the non-oily
machinery wastewater samples at concentrations that exceed Federal and/or state ambient water
quality criteria (WQC). The priority pollutants bis(2-ethylhexyl) phthalate, copper, nickel, silver,
and zinc were identified as being present in concentrations exceeding WQC. The only
bioaccumulator identified in the discharge was mercury.
||
3.4 Concentrations
!
Concentrations of constituents detected in non-oily machinery wastewater samples
collected from an aircraft carrier (CVN 74), an amphibious assault ship (LHD 1), a dock landing
ship (LSD 51) and a guided missile destroyer (DDG 57) are presented in Table 1.
Concentrations of a known bioaccumulator and the constituents that exceeded Federal and/or
most stringent state WQC are presented in Table 2.
Non-oily Machinery Wastewater
4
-------
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The mass loadings and
the concentrations of discharge constituents after release to the environment are discussed in
Sections 4.1 and 4.2, respectively. In Section 4.3, the potential for the transfer of non-indigenous
species is discussed.

4.1 Mass Loadings

Non-oily machinery wastewater discharge volumes (recorded by pump running time
meters/event counters) were recorded daily aboard four ships from different ship classes over
periods of tune ranging from 22 to 29 consecutive days.2 These were the same four ship classes
that were sampled. The discharge flow data and log-normal mean concentrations were used to
estimate mass loadings for those analytes detected. Mass loadings of all constituents detected are
presented in Table 1. Table 2 shows mass loadings for constituents with log-normal mean
concentrations that exceed water quality criteria and for the loan bioaccumulator detected,
mercury. A sample calculation of the estimated mass loading for copper is shown below:
Mass Loading for Copper (Total): * ( ,' - /
Mass Loading = (Log-normal mean concentratioii)(F10w Rate) <; — *
, = (599.96 mg/LX97,057,740 gal/y^)(3.785 L/gal)(lkg/109mg)(2.2 lb/1 kg)
Mass loadings were determined using log-normal averages because the concentration data
are expected to follow a log-normal distribution.

4.2 Environmental Concentrations

The log-normal mean discharge concentrations are compared to the Federal and most
stringent state WQC in Table 3. Copper, nickel, silver, zinc, bis(2-ethylhexyl) phthalate,
ammonia, nitrogen (as nitrate/nitrite and total kjeldahl nitrogen), and total phosphorous were
present in shipboard non-oily machinery wastewater discharge samples, with log-normal mean
concentration levels hi excess of the most stringent established water quality criteria. Mercury
was detected in two of four shipboard samples, but the log-normal mean concentration did not
exceed WQC.

4.3 Potential for Introducing Non-Indigenous Species

The discharge from freshwater non-oily machinery wastewater originates from the
potable water system and therefore, cannot introduce, transport, or release non-indigenous
species. Non-oily machinery wastewater of seawater origin is pumped overboard in the same
geographical area hi which the seawater was taken. Therefore, transporting aquatic species from
one geographic area to another as a result of this discharge is unlikely.
Non-oily Machinery Wastewater
5
-------
5.0 CONCLUSION
I
i
It is not clear whether non-oily machinery wastewater has the potential to cause an
adverse environmental effect. Copper, nickel, silver, zinc, bis(2-ethylhexyl) phthalate, ammonia,
nitrogen, and phosphorous exceed federal or most stringent state water quality criteria. However,
flow rate data are not adequate for estimating the fieetwide generation rate for this discharge, and
consequently, the mass loadings of these constituents for the fleet could not be calculated.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the discharge volume. Based on this estimate
and on the reported concentrations of constituents, the mass loadings to the environment
resulting from this discharge were then estimated. Table 4 shows the source of the data used to
develop this NOD report.

Specific References
i
1. Point Paper, "Supplemental Information for Miscellaneous UNDS Discharge Streams", P.
Weersing, Military Sealift Command Central Technical Activity, Code N72PC1, January
9,1997.

2. Uniform National Discharge Standards Non-Oily Machinery Wastewater (NOMWW)
Flow Characterization Report, CDNSWC-TM-63-98/62, March 1998.

3. UNDS Phase 1 Sampling Data Report, Volumes 1 - 13, October 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
I
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. 62, Number 150. August 5,1997.
Non-oily Machinery Wastewater
6
-------
Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for rntrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

UNDS Equipment Expert Meeting Minutes - Non-oily Machinery Wastewater. 12 September
1996.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.

UNDS Ship Database, August 1,1997.

Pentagon Ship Movement Data for Years 1991-1995, Dated March 4,1997.
Non-oily Machinery Wastewater
7
-------
SHIP'S
HULL
SHIP'S
HULL
PUMP PACKING
GLANDS
NON-OILY MACHINERY
WASTEWATER TANK
FIGURE 1
TYPICAL NON-OILY MACHINERY
WASTEWATER SYSTEM
Non-oily Machinery Wastewater
8
-------
Table 1. Summary of Detected Analytes
Constituent -• , 1

CLASSJCALS
Alkalinity
Ammonia as Nitrogen
Biochemical Oxygen Demand
Chemical Oxygen Demand
Chloride
Hexane Extractable Material
Nitrate/Nitrite
SGT-HEM
Sulfate
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (TOC)
Total Phosphorous
Total Recoverable Oil and
Grease
Total Sulfide (lodometric)
Total Suspended Solids
Volatile Residue
MERCURY .
Mercury
METALS i
Aluminum
Dissolved
Total
Antimony
Dissolved
Total
Arsenic
Dissolved
Total
Barium
Dissolved
Total
Boron
Dissolved
Total
Cadmium
Dissolved
Total
Calcium
Dissolved
Total
Copper
Dissolved
Total
Log Normal
J'"Mean ^-v

(ng/L)-
13.96
0.34
4.76
63.89
94.29
5.02
0.38
5.91
139.13
431.32
1.05
4.27
1.03
4.73
6.45
11.34
287.25
(ng/L>
4.48
fe/L)

30.83
53.47

2.81
2.57

0.94
0.57

5.17
7.03

80.88
89.19

2.78
2.80

3587.66
4117.59

148.76
599.96
Frequency of.
Detection -

^ s
4 of 4
4 of 4
Iof3
3 of 4
4 of 4
Iof4
4 of 4
Iof3
4 of 4
4 of 4
4 of 4
3 of 4
4 of 4
4 of 4
4 of 4
3 of 4
4 of 4
Z'
2 of 4

Iof4
Iof4

3 of 4
3 of 4

Iof4
Iof4

4 of 4
4 of 4

4 of 4
4 of 4
~" Minimum
Concentration

(mg/L) "
6
0.1
BDL
BDL
2
BDL
0.19
BDL
9.8
46
0.55
BDL
.14
.6
2
BDL
54
- -Cng/D
BDL
Gtg/L)

BDL
BDL

131.5
173

34.35
34.2
Maximum
Concentration

-fragflL.)- '
62
1
12
285
3050
40.5
0.56
33
1710
6300
2.3
21
11
19.75
16
46
6350
(ngflL)
2135
(H8/L)

68
372.5

7.55
5.5

1.8
1.2

21.8
34.95

754
833

5.2
5.4

74650
97950

1065
3045
Mass Loading

(lBs/yr)
11284
275
3696
49608
73213
3898
295
4589
112457
348630
8.49
3451
833
3823
5213
9166
232180
(Ibs/yr)
0.0036
(Ibs/yr)

24.92
43.22

2.27
2.08

0.760
0.461

4.18
5.68

65.4
72.1

2.25
2.26

2900
3328

120
485
Non-oily Machinery Wastewater
9
-------
Iron
Dissolved
Total
Lead
Dissolved
Total
Magnesium
Dissolved
Total
Manganese
Dissolved
Total
Molybdenum
Dissolved
Total
Nickel
Dissolved
Total
Silver
Total
Sodium
Dissolved
Total
Thallium
Dissolved
Total
Tin
Total
Titanium
Total
Zinc
Dissolved
Total
ORGANICS
2-Propanone
Bis(2-Ethylhexyl) Phthalate
Chloroform
N,N-Dimethylformamide
N-Hexacosane
Toluene

20.90
110.28

4.59
5.10

7775.80
9258.79

7.40
9.91

2.47
2.79

76.10
92.63

5.41

69616.18
62604.54

4.72
1.43

4.14

4.05

140.24
621.47
(WS/L)
36.00
10.78
6.93
6.67
6.06
10.91

2 of 4
3 of 4

Iof4
Iof4

4 of 4
4 of 4

3 of 4
3 of 4

Iof4
Iof4

3 of 4
3 of 4

Iof4

4 of 4
4 of 4

3 of 4
Iof4

Iof4

2 of 4

4 of 4
4 of 4

Iof4
Iof4
Iof4
Iof4
Iof4
Iof4

BDL
BDL

316
455

BDL
BDL

BDL

3365
1948.75

BDL
BDL

BDL

23
90.85
-------
Table 2. Estimated Annual Mass Loadings of Constituents
Constituent
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen^
Total Phosphorous
ORGANIGS
Bis(2-Ethylhexyl)
Phthalate
MERCURY- •-.::
Mercury*
a*EiALs-iXf K -.'.:-•?
Copper
Dissolved
Total
Nickel
Dissolved
Total
Silver
Total
Zinc
Dissolved
Total
Log Normal
Mean
(mg/L)
0.34
0.38
1.05
1.43
1.03
(US/L)
10.78
s; - - (ng/L) ,
4.48
:*H:%ig/L)

148.76
599.96

76.10
92.63

5:41

140.24
621.47
Frequency of
Detection
-
4 of 4
4 of 4
4 of 4
-
4 of 4
- -
Iof4
:,
2 of 4
/

4 of 4
4 of 4

3 of 4
3 of 4

Iof4

4 of 4
4 of 4
:. Minimum
Concentration
(mg/L) .
0.1
0.19
0.55

0.14
(WBflL)
BDL
(Bg/L)
BDL
- (HSW-

34.35
34.2

BDL
BDL

BDL

23
90.85
Maximum
Concentration
(mg/L)
1
0.56
2.3

11
- (MS/L)
75
Cng/L) L-,,
2135
(ug/L)

1065
3045

237
404

54.85

847
6125
Mass Loading
! */ r**~
(Ibs/yr)
275
295
8.49
303
833
- (Ibs/yr)
8.71
(Ibs/yr)
.0036
(Ibs/yr)

120
485

61.5
74.9

4.37

113
502
BDL = Below Detection Limit
A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

* Mercury was not found in excess of WQC; mass loading is shown only because it is a bioaccumulator.

Mass loadings were calculated based upon the results of the UNDS Non-Oily Machinery Wastewater Flow
Characterization Report involving four vessels: CVN 74, DDG 67, LHD 5, and LSD 44.2
Non-oily Machinery Wastewater
11
-------
Table 3. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituent
CLASSICALS
(mg/L)
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kfeldahl
Nitrogen
Total Nitrogen*
Total Phosphorous
ORGANICS (ug/L)
Bis(2-Ethylhexyl)
Phthalate
Mercury (ng/L)
Mercury*
Metals (ug/L)
Copper
Dissolved
Total
Nickel
Dissolved
Total
Silver
Total
Zinc
Dissolved
Total
Log-normal
Mean

0.34
0.38
1.05
1.43
1.03

10.78

4.48

148.76
599.96

76.10
92.63

5.41

140.24
621.47
Minimum
Concentration

0.1
0.19
0.55

0.14

BDL

34.35
34.2

BDL
BDL

BDL

23
90.85
Maximum
Concentration

1
0.56
2.3

2135

1065
3045

237
404

54.85

847
6125
Federal Acute
WQC

None
None
None
None
None

None

1800

2.4
2.9

74
74.6

1.9

90
95.1
Most Stringent State
Acute WQC

0.006 (ffl)A
0.008 (HI)A
-
0.2 (HI)A
0.025 (HI)A

5.92 (GA)

25 (FL, GA)

2.4 (CT, MS)
2.5 (WA)

74 (CA, CT)
8.3 (FL, GA)

1.2 (WA)

90 (CA, CT, MS)
84.6 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
!!
* - Mercury was not found in excess of WQC; concentration is shown only because it is a bioaccumulator.
II
CA «• California
CT «• Connecticut
FL s Florida
GA s Georgia
HI "• Hawaii
MS *• Mississippi
WA = Washington
Non-oily Machinery Wastewater
12
-------
Table 4. Data Sources
-
, NOD Section
2.1 Equipment Description and '
Operation • "' -• ->
2.2 Releases to fee Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations "
4. i Mass Loadings *
4.2 Environmental Concentrations
4.3 Potential for Introducing Non- .
Indigenous Species
- V -- - Data Source , , '* *
-' ' Reported

UNDS Database

Sampling

X
X
X
X
X

Estimated

Equipment Expert
X
X
X
X
X

X
Non-oily Machinery Wastewater
13
-------
-------
NATURE OF DISCHARGE REPORT
Photo Lab Drains
1.0 INTRODUCTION

This section describes the photographic laboratory drains and includes information on:
the equipment that is used and its operation (Section 2.1), general description of the constituents
of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
i1: i
' i
2.1 Equipment Description and Operation
: • i!
Shipboard photographic laboratory wastes result from the processing of color, black-and-
white, and X-ray film. The chemicals used aboard vessels for these purposes are the same as
those used at shore-based photographic facilities. This discharge is controlled by the Armed
Forces by current guidance which requires containerization of all photo processing wastes for
shore disposal when within 12 nautical miles (n.m.) of shore.1
i
The photographic wastewater processing system consists of three elements: a film
processor, a washwater recycle system, and a fixer recycle and silver recovery subsystem. The
film processor effluents include the developer and fixer solutions and the thiosulfate washwater
stream. After the film is fixed, it goes through the washwater recycle system, where it is
immersed hi thiosulfate washwater and then sprayed with freshwater (rinsewater).2 Black-and-
white and X-ray film effluents are then containerized for shore disposal or directly discharged
overboard via the ship's collection, holding, and transfer (CHT) system if outside 12 n.m. Fixer
solutions must always be containerized for shore disposal within 12 n.m. Beyond 12 n.m. the
fixer solution maybe discharged overboard, provided the fixer solution is processed through a
silver recovery unit, if one is available on-board.3 A silver recovery unit uses an electrolytic
recovery assembly to recover the silver from the recycled fixer solution.2 The effluent from the
recovery unit is then containerized, or discharged overboard if outside 12 n-m.1 Color film
processor effluent (small quantities) maybe discharged directly overboard beyond 12 n.m. via
the plumbing drain system.3 In port, or in transit within 12 n.m., the effluent is containerized for
shore disposal. In some cases, rinsewater is discharged to the CHT system in port for discharge
ashore if local regulations permit.
i
The amount and frequency of waste generation across vessel classes will vary depending
upon the vessels' photo processing capabilities (color and/or black-and-white), equipment, and
operational objectives. Color film processing waste is generated from batch quantities of
developer, fixer, and intensifier solutions. Black-and-white and X-ray film processing waste is
generated from processor effluent, stop bath, detergents, and hardener solutions. Many vessels
are now being outfitted with self contained automatic processors or digital processors.
Automatic processors do not produce a continuous rinsewater stream. Digital processors do not
use chemicals.4
i
2.2 Releases to the Environment

Photographic processing effluents are only discharged outside of 12 n.m. from shore.
Black-and-white and X-ray photographic processing effluent is discharged overboard via the
CHT system. Color film processor effluent is permitted to be discharged overboard above the
Photo Lab Drains
2
-------
waterline via the plumbing drain system.1 The discharge can consist of stop bath, detergents,
hardener, developer, fixer, and rinse solutions.

2.3 Vessels Producing the Discharge

Navy vessels such as aircraft carriers (CV/CVN), amphibious assault ships
(LHD/LHA/LPD/LCC), and submarine tenders (AS) have photographic laboratory facilities,
including color, black-and-white and X-ray photographic processors. Two Military Sealift
Command (MSC) hospital ships (T-AH) have photo processing equipment, but neither is used on
a routine basis or within U.S. contiguous or territorial waters. The U. S. Coast Guard (USCG)
currently has two WAGE 400 Class icebreakers with photographic and X-ray processing
capabilities, but does not discharge wastes overboard within 12 n.m. of shore.5 The Army and
the Air Force are not expected to produce this discharge because their vessels do not have
photographic developing capabilities.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Naval Ships' Technical Manual (NSTM), Chapter 593, provides uniform guidance in the
handling and disposal of photographic processing chemicals. While in port or in transit within
12 n.m., all discharges of X-ray, color and black-and-white photographic processing fixers, and
developers are containerized for shore-side disposal. Film rinsewaters are not containerized in
port due to their large volumes, but are disposed of in to the CELT system. The CHT system is
connected to the pierside collection piping while the vessel is docked. Therefore, overboard
discharges of photographic processing effluents do not occur from any vessel within 12 n.m. of
shore, and most vessels containerize their waste even beyond this point.

Beyond 12 n.m., all photo processing chemicals, if not containerized, are directed to the
CHT system where they are mixed with blackwater and discharged overboard.3 Wastes that can
be directed to the CHT system are black-and-white and X-ray film processing waste from
processor effluent, stop bath, detergents, hardener solutions, and silver recovery unit effluent.

3.2 Rate

Discharge flow rate data were not obtained.

3.3 Constituents
Photo Lab Drains
3
-------
Table 1 lists the chemical constituents identified in the most commonly used developing
solutions and fixers, and in rinse waters on vessels of the Armed Forces. Silver is the only
priority pollutant in this discharge. There are no known bioaccumulators identified in this
discharge.
i
i
3.4 Concentrations

The range of photographic processing chemical concentrations was not obtained.
4.0 NATURE OF DISCHARGE ANALYSIS

4.1 Mass Loadings

Constituent mass loadings were not calculated since the discharge does not occur inside
12 n.m. Furthermore, discharge concentrations and flow rates are unknown.

4.2 Environmental Concentrations
i
Concentrations released to the environment were not calculated since the discharge does
not occur inside 12 n.m. and the discharge concentrations are unknown.
T :. • !
4.3 Potential for Introducing Non-Indigenous Species

Potable water is used hi photographic laboratories; therefore, there is no possibility for
the introduction, transport, or release of non-indigenous species.
5.0 CONCLUSIONS
ij
Existing data are insufficient to determine whether drainage from shipboard photographic
labs has the potential (or has a low potential) of causing an adverse environmental effect.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources were obtained. Table 2
shows the sources of the data used to develop this NOD report.
Photo Lab Drains
4
-------
Specific References

1. Naval Ships' Technical Manual (NSTM) Chapter 593 Appendix D, pp D-9 and D-10,
Disposal Guidelines For Shipboard Hazardous Waste. September 1,1991.

2. Laboratory Evaluation of a Photographic Wastewater Processing System, prepared by
David W. Taylor Naval Ship Research and Development Center, Bethesda, MD. August,
1982.

3. UNDS Equipment Expert Meeting Minutes. Photo Laboratory Discharges - April 2,
1997.

4. Personal Communication Between John Julian, NAVSEA 03L13, and Sr. Chief Freeland,
Naval Imaging Command, on Self Contained Automatic Processors and Digital
Processors for use in Photographic Laboratory. September 23,1997.

5. Personal Communication Between LT. Joyce Aivalotis, U.S. Coast Guard and Dan
Mosher of Malcolm Pirnie, Inc., on USCG Photographic Processing Procedures. April
28,1997.

6. Personal Communication Between Albert Browne, NAVSEA 03L13, and Mr. Joseph
MacDonald, NAVSEADET (PERA-CV), on Kodak Processor Chemistry Listings for
Kreonite/Kodak RA-4, Black-and-White Jmagemaker, and Kodak C-41 Color
Imagemaker Processors. July 25,1996.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter

Photo Lab Drains
5
-------
62-302. Effective December 26,1996.
'!
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
1 • j,
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
i
Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.
" • ' \
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAG).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
!|

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Photo Lab Drains
6
-------
Table 1. Chemical Constituents Identified in the Most Commonly Used Photographic
Developing Solutions and Fixers, and in Rinse Waters on Vessels of the Armed Forces6
1,3 - propylenediaminetetraacetic acid
2- aDtiinoethanol
4-(N-ethyl-N-2-
methanesulfonylaminoethyl) - 2 -
methylphenylenediamine sesquisulfate
monohydrate
4 - (N-ethyl-N-2-hydroxyethl)-2-
methylphenylenediamine sulfate
4-(N-ethyl-N-2-
methanesulfonylaminoethyl) - 2 -
methylphenylenediomine sulfate
acetic acid
aluminum sulfate
Ammonia
ammonium (ethylenodinitrilo) tetraacete)
ferrate
ammonium acetate
ammonium bromide
ammonium citrate
ammonium ferric ethylenediaminetetra
acetic acid
ammonium ferric
propylenediaminetetraacetic acid
ammonium sulfite
ammonium thiosulfate
boric acid
Diethanolamine - sulfur dioxide
Diethanolamine - sulfur dioxide
complex
diethylene glycol
Formaldehyde
glacial acetic acid
Hydroquinone
Hydroxylamine sulfate
Isothiazolones
lithium sulfate
methyl alcohol
N,N-diethylhydroxylamine
nitric acid
Organosilicone fluid
penitetic acid
potassium bicarbonate
potassium carbonate
potassium chloride
potassium hydroxide
potassium sulfite
propylene glycol
silver*
sodium acetate
sodium bisulfite
sodium citrate
sodium metabisulfite
sodium sulfite
sodium sulfosuccinate
stilbene brightner
sulfuric acid
terra sodium ethylene
diamine tetraacetrate
triethanolamine

* Priority Pollutant
Table 2. Data Sources
-
, NOD Section
2,1 Equipment Description and Operation
2,2 Releases to the Environment
2.3 Vessels Producing 'the Discharge
3.1 Locality ^
3.2 Rate (NA)
: 3.3 Constituents
3.4 Concentrations (NA)
4.1 Mass Loadings (NA)
4^2 Environmental Concentrations (NA)
43 Potential for Introducing Non-
Indigenous Species
'-• Data Sources; ';'.>: '^-'- ••? ;/"• -::':: "?/'•
Reported

UNDS Database

Sampling*

Estimated

Equipment Expert
X
X
X
X

X
Note: NA = not applicable
Photo Lab Drains
7
-------
-------
NATURE OF DISCHARGE REPORT
Portable Damage Control Drain Pump Discharges
1.0 INTRODUCTION

2.1 Equipment Description and Operation
i
Damage control (DC) systems are the fluid, electrical, and ventilation systems that
contribute to combating fires, controlling or removing smoke and/or water, or transmitting power
and communications. Facilities for dewatering compartments in the event of an emergency
consist of fixed drainage systems within the vessel and portable equipment, such as electric
submersible pumps, P-250 or P-100 pumps, and eductors (Figure 1). Portable DC dewatering
equipment is used in emergencies to assist recovery from fire and flooding events by removing
fluids from damaged compartments or from compartments without drainage systems located
close to, or below, me waterline. Emergency situations are not incidental to the normal operation
of the vessel and therefore not considered in this report. The only required operation which
produces a discharge incidental to the normal operation of the vessel is during planned
maintenance system (PMS) activities for the equipment. This report addresses only planned
maintenance activity discharges from this equipment.

Three basic types of dewatering equipment used in damage control situations are
described below.
i
• Portable electric submersible pumps are used to dewater compartments that do not
have an installed drainage system. The pump is driven by an electric motor enclosed
in a watertight case that allows the pump to operate while submerged. These pumps
are fitted with strainers to prevent debris from clogging the impeller. This pump
does not use a suction hose, and the fluid is discharged through a fire hose.
! i
• Portable engine-driven pumps are designed for firefighting but can also be used for
dewatering operations. Engine-driven pumps take suction through a hard rubber hose
and discharge through a fire hose. The P-250 has a pumping capacity of 250 gallons
per minute (gpm). The P-100 pump is driven by an air-cooled diesel engine and has a
pumping capacity of 100 gallons per minute (gpm). The P-l (Figure 2) and P-5 (CG-
P1B and CG-P5) are gasoline-driven portable pumps used by the U.S. Coast Guard
(USCG). The P-5 is similar in design to the P-l, but it has a larger pumping capacity.
The P-l has a pumping capacity of 120 gpm, and the P-5 has a pumping capacity of
200 gpm.1'2

• Portable eductors Portable eductors are actuated from the discharge of a P-250 or P-
100 pump or through a fire hose using the vessel's installed firemain. A suction hose
is not used with portable eductors because the eductor is submerged during operation.
The eductor discharges through a fire hose which is lead directly overboard.

Portable Damage Control Drain Pump Discharges
2
-------
Maintenance schedules for the portable electric submersible pump and portable eductors
do not include a requirement for operation that will produce a discharge.3 The USCG P-l and P-
5 pumps are pre-packaged for transfer to a vessel in distress, and periodic maintenance schedules
do not include a requirement to operate the pumps to produce a discharge. The maintenance
schedules for the Navy, the Military Sealift Command (MSC), and Army P-l00 and P-250
pumps include a requirement to operate the pumps monthly for 10 minutes and annually for 15
minutes: the annual check is concurrent with a monthly check.4 Current USCG maintenance
schedules require P-250 pumps to be operated for 30 minutes each month, but the maintenance
procedures are expected to be changed to require only a 15 minute run each month.5'6

2.2 Releases to the Environment

During maintenance, P-250 and P-100 pumps are operated to demonstrate proper function
by pumping seawater adjacent to the vessel via a hard rubber suction hose through the system
and discharging it directly overboard through a fire hose.7

The P-250 pump uses a portion of the pump discharge to cool the engine exhaust. This
cooling water is discharged separately from the pump discharge and is not considered part of this
discharge stream. It is addressed in a separate NOD report entitled "Portable Damage Control
Drain Pump Wet Exhaust."

2.3 Vessels Producing the Discharge

All Navy, MSC, and USCG surface ships can discharge seawater from portable DC drain
pumps. There are 906 emergency fire pumps on Navy surface vessels. The MSC maintains 137
pumps, and the USCG has 370 pumps on its surface vessels. The Army is currently equipped
with 60 P-250 MOD 1 pumps and six P-100 pumps. The Air Force does not use portable pumps
on any of their water craft. The numbers of individual pumps within the fleets are: 8>9'10>n>12>13'14
Navy
MSC
USCG
Army
Totals
P-250 MOD 1
70
0
370
60
500
The Navy is completely converting to P-100 pumps, and it is estimated that all P-250's in
Navy service will be replaced by P-100's by the end of 1998.8 The Army has also begun to
replace P-250's with P-100 pumps, but a timetable for complete conversion has not yet been
developed

As mentioned previously, the USCG P-l and P-5 pumps are pre-packaged for transfer to
a vessel in distress. These pumps are not required to be operated during periodic maintenance so
these pumps produce no discharge incidental to normal vessel operations.
Portable Damage Control Drain Pump Discharges
3
-------
3.0 DISCHARGE CHARACTERISTICS

3.2 Rate

Individual vessel discharge volumes from emergency pumps will vary depending on the
numbers and types of pumps aboard each vessel. Therefore, flow rates will be calculated on a
fleet-wide basis instead of a ship-by-ship basis.
" ' ' i' •
Using standard maintenance operating schedules, pump inventory data, and pump
discharge rates, discharge flow estimates were calculated as shown in Table 1. During monthly
maintenance activities, the Navy, MSC, and Army run pumps for approximately 10 minutes and
for approximately 15 minutes during annual maintenance checks. The USCG currently operates
its pumps for 30 minutes per month. The resulting total annual discharge is approximately
49,062,500 gallons.

Approximate annual flow rates for representative ship types are listed below:
Ship Type
Surface Combatant
(DD, DDG, CG, FFG)
Large Auxiliary or
Amphibious Ship
(e.g.: AFS, AOE, LPD, LSD)
USCG Cutter (WHEC)
Army Watercraft (LCU-1600)
Pump Type
Carried and
Number per Ship
4-P-100's
6 - P-100's
3 - P-250's
1 - P-250's
Pump Flow
Rate (gpm)
100
100
250
250
Annual
Operating Time
(Minutes/Year)
125
125
360
125
Total Yearly
Flow rate
per Ship
50,000
75,000
270,000
31,250
3.3 Constituents

The portable DC drain pump discharge is seawater that is pumped during maintenance
activities. The seawater contacts rubber suction hoses and the rubber lining of firehoses. It also
contacts the wetted components of the pump (e.g. impeller). The pumps and hoses are not
Portable Damage Control Drain Pump Discharges
4
-------
expected to contribute measurable amounts of pollutants to the discharge because the residence
times of the seawater within the equipment is less than 5 seconds.

3.4 Concentrations

The discharge is expected to be seawater with no measurable contribution of constituents
from the pumping process.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings and environmental concentrations are discussed in Section 4.1 and 4.2. In Section 4.3,
the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The portable DC drain pump discharge is seawater that is pumped during maintenance
activities. The seawater contacts rubber suction hoses and the rubber lining of firehoses. It also
contacts the wetted components of the pump (e.g. impeller). The pumps and hoses are not
expected to contribute measurable amounts of pollutants to the discharge because the residence
times of the seawater within the equipment is less than 5 seconds.
4.2
Environmental Concentrations
The discharge is expected to be seawater with no measurable contribution of constituents
from the pumping process.

4.3 Potential for Introducing Non-Indigenous Species

There is an insignificant potential for introducing non-indigenous species from this
discharge. The seawater pumped through the portable DC drain pumps is discharged in the same
location from which it was taken.
5.0 CONCLUSION

The portable DC drain pump discharge has a low potential for causing an adverse
environmental effect because the discharge consists of seawater pumped and discharged at the
same location from which it was taken. The pumps and hoses are not expected to contribute
significant amounts of pollutants to the discharge because the residence time of the seawater
within the equipment is less than 5 seconds.
Portable Damage Control Drain Pump Discharges
5
-------
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the annual discharge volume. Table 2 shows
the source of the data used to develop this NOD report.
!
!!
Specific References

1. Gallagher, Larry, M. Rosenblatt & Son, Inc. Portable DC Dewatering Equipment, April
1997, Leslie Panek, Versar, Inc.
"! • j
I!
2. USCG COMDTINST M10470.10C - Chapter 2, Dewatering Pump Kit. Unknown date.
i
3. Maintenance Index Page (MTP) 6641/Z06-76, Damage Control Stations. April 1995.

4. Maintenance Index Page (MIP) 6641/008-B2, Portable Gasoline/JP-5 Driven Pump.
November 1992.

5. USCG Uniform Maintenance Procedure Card (UMPC) R-M-014.
p
6. Personal Communication, LT Joyce Aivalotis USCG to M. Rosenblatt & Son, June 5,
1997.
i
7. Steinberg, Bob, M. Rosenblatt & Son, Inc. Portable DC Dewatering Equipment, January
1997, Leslie Panek, Versar, Inc.

8. Personal Communication (Fonecon): Steinberg, Bob, M. Rosenblatt & Son. Status of
USN P-250 Replacement Program, 23 January 1998, Mark Hampson, NSWC

9. UNDS Equipment Expert Meeting Minutes - Emergency Fire Pump Wet Exhaust. March
26,1997.

10. Personal Communication between Chief Warrant Officer Dunbar, USCG and Doug
Hamm, Malcolm Pimie, Inc., January 26,1997 and March 27,1997.

11. Personal Communication (Fonecon): Steinberg, Bob, M Rosenblatt & Son. Status of
MSC P-250 Replacement Program, 5 February 1998, Joe Bohr, MSC Code N72PC

12. Saponara, N. et al. "UNDS Shipcheck of US Army Watercraft, Fort Eustis, VA, 21-22
January 1998: Trip Summary", undated

13. Personal Communication (Fonecon): Steinberg, Bob, M. Rosenblatt & Son, Inc. Army
Purchases of P-100 Pumps, 14 January 1998, Paul Darley, W.S. Darley & Co.

14. Personal Communication (VoiceMail): Chew, Don, LCOL, USAF, HQ, USAF (ILTV).
Portable Damage Control Dram Pump Discharges
6
-------
Portable damage control pumps on Air Force Watercraft, 21 January 1998, Bob
Steinberg, M. Rosenblatt & Son, Inc.
General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter

Portable Damage Control Drain Pump Discharges
7
-------
173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume
Register, p. 15366. March 23,1995.
60 Federal
Portable Damage Control Drain Pump Discharges
8
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P-250 PUMP (MOD 1 OR MOD2)
P-100 PUMP
PERIJETEDUCTOR
S-TYPE EDUCTOR
1-1/2" EDUCTOR
Figure 1. Dewatering Equipment
Portable Damage Control Drain Pump Discharges
9
-------
PUMP
1. INLET HOSE
2. OUTLET HOSE
3. CASE DRAIN PLUG
A. CARRYING CRADLE
5. OIL FILL
6. PRIME PUMP

ENGINE
7. FUEL TANK FILL CAP
8. FUEL TANK
9. CHOKE
10. AIR INTAKE
11. MUFFLER
12. FUELTANKVENT
13, FUEL FITTING
11
Figure 2. Portable Dewatering Pump (Model CG-P1B)
Portable Damage Control Drain Pump Discharges
10
-------
Table 1. Annual Discharge from Portable DC Drain Pumps
Service
Navy

MSC

USCG

Army

Pump Model
*• * •'" 'V-J' „

P-250 MOD 1
P-100

P-250 MOD 1

P-250 MOD 1
P-100

Number of Pumps

70
793

Navy Total:

0
137

MSC Total:

370

60
6

Army Total:
How
(GFM)

250
100

250

250
100

Annual
Pperatfrig.Tune*-
(Mhiuies/Year)

125
125

360

125
125

" , Annual Discharge
(Gallons/Year)

2,187,500
9,912,500

12,100,000

0
1,712,500

1,712,500

33,300,000

1,875,000
75,000

1,950,000
Cumulative Total: 49,062,500
Table 2. Data Sources
-
NOD Section
2,1 Equipment Description and Operation
2.2 Releases to the Environment - "
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate • ,
3.3 Constituents
3.4 Concentrations. > "
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Non-indigenous Species
Data Source ' • , ,
Reported
Equipment manuals
PMS cards

X
X
PMS cards
X

Sampling

Estimated

X
X
X
X
X
Equipment Expert
X
X
X
X
X
X

Portable Damage Control Drain Pump Discharges
11
_
-------
-------
NATURE OF DISCHARGE REPORT
Portable Damage Control Drain Pump Wet Exhaust
1.0 INTRODUCTION

2.1 Equipment Description and Operation l
... I

Portable, engine-driven pumps are used to provide fire fighting water in the unlikely
event that it is unavailable from the ship's installed fire pumps because of damage, loss of
electrical power, or other reasons. These pumps may also be used in an emergency to directly
dewater (drain) flooded compartments which have no installed drainage system. They can also
be used to provide driving water for portable eductors that dewater flooded spaces as well. The
two models of engine-driven pumps which produce this discharge are the P-250 and the P-100.
A portion of the sea water output from the P-250 portable damage control pump is directed to
cool the engine. A small portion of the cooling water is also injected into the engine exhaust to
cool and quiet the exhaust. This cooling water (called wet exhaust), containing some of the
burned and unbumed exhaust constituents, is discharged to receiving waters. Although the
engine which drives the P-100 pump is air-cooled, and no water is injected into the engine
exhaust of this pump, a small amount of water contacts the engine exhaust during pump priming
only. This water is also considered part of this discharge and is characterized in this report.
i
11 !!
Typical operations involving portable damage control drain pump wet exhaust discharge
include monthly planned maintenance system (PMS) activities and emergency situations such as
fire and flooding.
i
2.1.1 Wet Exhaust (P-250). The P-250 MOD 1 pump (Figure 1) operates at 250 gallons
per minute (gpm) and is driven by a 35-horsepower (HP), two-cylinder, water-cooled, two-stroke
per cycle, spark-ignition, vertical-shaft engine. It is fueled by gasoline and lubricated by oil that
is injected into the gasoline via a small injection pump. A later modification of the P-250, the P-
250 MOD 2 pump was similar to the P-250 MOD 1 model, but the engine was modified to run
ori JP-5, a kerosene-based fuel. All P-250 MOD 2 pumps have been removed from service
because of reliability, maintainability and availability issues.1'2
i
2.1.2 Discharge from pump priming. In the Navy, Army, and MSC fleets, the
remaining P-250 MOD 1 pumps are currently being replaced by P-100 portable damage control
pumps (Figure 2). The P-100 differs significantly from the P-250 pump models in that the P-100
has no wet exhaust discharge. The P-100 is smaller, rated at 100 gpm at 95 pounds per square
inch (psi). It is driven by a one-cylinder, air-cooled, four-stroke per cycle, diesel engine with a
horizontal shaft, the engine exhaust pipe is a double-walled, insulated, corrugated steel tube.
1 This discharge was formerly called "Emergency Fire Pump Wet Exhaust". References and other materials related to this
discharge can be found in the files under that title. These pumps are more properly called fire pumps, since they were designed
for fire fighting; however, they can be used for dewatering ("drainage") as well. The title of this discharge was changed to make
it clear that there are in fact two separate discharges from these equipments. The main discharge of sea water from these pumps
is covered in & separate NOD titled "Portable Damage Control Drain Pump Discharges".

Portable Damage Control Drain Pump Wet Exhaust
2
-------
No water is injected into the exhaust nor is the exhaust discharged into receiving waters.3

The P-100 pump is equipped with a unique exhaust-powered primer. (Priming of the P-
250 pump is accomplished with a hand-operated pump; the P-250 does not have an exhaust-
powered primer.) In priming the P-100 pump, the main engine exhaust port is blocked by the
exhaust primer valve, forcing the engine exhaust to flow through the priming jet. The priming jet
evacuates the air from the pump casing and suction hose, causing water to rise in the suction hose
and fill the pump casing. Priming is completed when water begins discharging from the priming
jet. When priming is complete, the primer shut off valve is adjusted to stop the water flow.4 Up
to 1/2 liter of exhaust-contaminated water may be discharged during pump priming. During a
typical priming event, the liquid discharge is just sufficient to puddle on the deck, and is wiped
up with rags.

2.2 Releases to the Environment

This discharge consists of water injected as a cooling stream into the exhaust system of
P-250 portable damage control pump internal combustion engines. Exhaust constituents
generated during the operation of the internal combustion engines can be transferred to the
engine's water cooling stream and discharged as wet exhaust. Wet exhaust discharges are
continuously routed overboard during pump operation, typically via an exhaust hose. The
purpose of the exhaust hose is to route the engine exhaust products from the vessel interior
spaces to the weather so that personnel are not overcome by the exhaust fumes. For maintenance
and any familiarization training that maybe performed on ships, the common practice is to
connect the exhaust hose so that the discharge goes directly overboard.

In addition, this discharge consists of less than 1/2 liter of water containing trace amounts
of exhaust which may be released during a P-100 priming event.

2.3 Vessels Producing the Discharge

There are 906 portable damage control pumps which produce this discharge on Navy
vessels.1'5 The Military Sealift Command (MSC) has 137 of these pumps on their vessels.2'5 The
Coast Guard (USCG) has 370 pumps, which are all P-250's.5'6 There are 66 pumps which
produce this discharge aboard U.S. Army (USA) watercraft.7'8 There are no pumps which
produce this discharge aboard U.S. Air Force watercraft.9 Pumps within the fleets are as
follows:1'2'3'7
Total by Service
906
137
370
66
1479
The Navy is completely converting to P-100 pumps, and it is estimated that all P-250's in
P-250 MOD 1
Navy
MSC
USCG
Army
Totals
70
0
370
60
500
P-100
836
137
0
6
979
Portable Damage Control Drain Pump Wet Exhaust
3
-------
Navy service will be replaced by P-100's by the end of 1998. The Army has also begun to
replace P-250's with P-100's, but a timetable for complete conversion has not yet been
developed.
3.0 DISCHARGE CHARACTERISTICS
j
This section contains qualitative and quantitative information that characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and near-
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
I

3.1 Locality
5
i
Wet exhaust discharges from portable damage control drain pumps occur during
maintenance activities. Maintenance activities can be initiated while in port or at sea. For
purposes of this analysis, it has been assumed that all discharges occur within 12 nautical miles
3.2 Rate

The P-250 pump discharges wet exhaust at 2 gpm. As previously stated in Section 2.1,
the P-100 pump has no wet exhaust, but may produce up to 1/2 liter of exhaust-contaminated
water during pump priming.
i ! ,
Using standard maintenance schedules, pump inventory data, and established pump wet
exhaust discharge rates, discharge volume estimates were calculated as shown in Table 1.
During monthly maintenance activities, the Navy runs pumps for approximately 10 minutes, and
during annual maintenance checks for about 15 minutes. The annual check is done concurrently
With a monthly check.10 The Army and MSC follow the Navy's maintenance procedures. The
USCG currently runs its pumps for 30 minutes per month, but the maintenance procedures are
expected to be modified to require only a 15 minute run time per month.1 1>12
1! ,!' ji
The calculation for the annual wet exhaust flow rate of 298,900 gallons per year from P-
250 MOD 1 pumps is shown below:
Portable Damage Control Drain Pump Wet Exhaust
4
-------
Annual wet exhaust flow rate = (per minute wet exhaust flow rale (gal/min)) (operating time
(minutes/year/pump))(numberofpumps) - ,', I t^ / rV'~ ^_ „
ForP-250MOD 1 Pumps:"" ,*-,---";- - ' - . >
V? "" * +- -' v<4" ^ *" '" - ^ -^ //f
;, 1. Wet exhaust flow = 2 gallons/minute , ^ " < *|-

"" 2. Operating time - „ / /_.', ' ' -^ ,"",,, " <"- , , "

Navy and Army pump monthly maintenance checks = (10 min/montb.) (11 months) = ). 10
min/yr/pump '_" ;", -^.'z/ " "'',>• "" s ;-_L ,""„ r,
Navy and Army pump annual mairitenance check =r!5 man/yr/pump " --^ '
Navy and Army pump total operating time = (110 min/yr/pump) + (15 minutes/yr/pump) *
,/ v '; 125minutes/yr/pump , .

USCG pump monthly checks = (30inmutes/montto) (12 months) =360 minutes/yr/pump

3. Number ofpumps - "^ * , ~> " ? " " '>\T.~^ }
, / i " ' " '- „ - V ,-' t (

Navy and Army vessels = 130 pumps „ : ?r , ;%
USCG vessels = 370 pumps , ^ - .

4. Annual wet; exhaust flow rate ~ • - "., -
/ ^ y

for Navy/Army=(2 gal/rain) (125 min/yr/pump) (130 pumps) - 32,500 gal/yr ,
for USCG = (2 gal/min) (360 min/yr/pump) (370 pumps) = 266,400 gal/yr
for Navy/Army/USCG = 32,500 gal/yr + 266,400 gal/yr=298,900 gal/yr ~ '
3.3 Constituents

The constituents of this discharge are fuel (gasoline or diesel), lubricants, or then-
combustion exhaust gases. Typical constituents of exhaust gases from small diesel or gasoline-
fueled engines include both organic and inorganic substances. Most of the substances that
originate from the fuel are combustion products. However, some fuel passes through the engine
unburned along with combustion products in the exhaust gases.13

Inorganic substances in portable damage control pump engine exhaust gases include
combustion products such as carbon dioxide (CO2), carbon monoxide (CO), oxides of nitrogen
(NOX), oxides of sulfur (SOX), and metals. The specific substances and their concentrations
depend on a number of factors, including the composition of the fuel, engine temperature, engine
use, and engine condition.

P-250MOD1: Engine wet exhausts contain oil and grease. The concentrations are
affected by the composition of the fuel, any additives used, and the efficiency of the engine, hi
1992, sampling was conducted by the Navy for metals in portable damage control pump wet
Portable Damage Control Drain Pump Wet Exhaust
5
-------
exhaust and the results are shown in Table 2. The metals analyses were only conducted on the P-
250 MOD 2 unit, which has since been removed from service; however, since P-250 MOD 1 and
MOD 2 pumps and cooling systems are of similar construction, the metals for both types of
engine exhausts are expected to be comparable. Chromium, cadmium, copper, lead, nickel,
silver, and zinc were all detected in the wet exhaust.14 All of these metals are priority pollutants.
As mentioned in Section 2.1, the P-250 MOD 1 pump is a two-stroke per cycle, spark ignition
gasoline powered engine. These types of engines are known to release high levels of gaseous
hydrocarbons (HC) relative to other engine types such as diesel or four-stroke per cycle engines.
The primary component of the HC in air exhaust which may impact water quality is volatile
organic compounds (VOCs).15
j|
While there is not a large body of information available on the impact of engine exhaust
on water, some studies have been done. A study in 1995 measured the rate of introduction of
VOCs into water during the operation of a gasoline powered two-stroke engine, hi this test, an
outboard engine was operated hi an enclosed tank and the increase in VOCs such as benzene was
measured. The results were given in terms of mg of compound/10 min of operation (e.g. 2800
mg benzene/10 min.). Therefore, the number was a bulk measurement of the rate of
accumulation of the compound in the water. The study reported that the VOC compounds
introduced into the water were almost exclusively aromatic hydrocarbons, hi most cases, other
types of hydrocarbons were not found. The amount of VOCs introduced into the water on a
power basis (grams/horse power-hr) was equivalent to approximately 10% of the total HC
emitted in the ah- exhaust. The VOC compounds measured in the 1995 study and the rate of
introduction are shown in Table 3.
15
The compounds listed in Table 3 are expected to be similar to that of the P-250 MOD 1
engine exhaust since both the test engine and the P-250 engine are two-stroke cycle, gasoline
powered engines. Of the compounds listed in Table 3, benzene, toluene, ethylbenzene, and
naphthalene are priority pollutants. None of the compounds are bioaccumulators.

3.4 Concentrations
i
!
P-250 MOD 1: Oil and grease concentrations in the exhaust from P-250 MOD 1
portable damage control pump wet exhaust is shown hi Table 4. These concentrations were
taken from laboratory analytical data provided by Naval Surface Warfare Center Carderock
Division (NSWCCD).14 The analyses were performed in April 1992 for oil and grease.

Concentrations of metals hi portable damage control pump wet exhaust are shown in
Table 2. Metals analyses were only conducted for the P-250 MOD 2,14 which has since been
removed from service; however, it is expected that the concentrations of metals in the P-250
MOD 1 unit will be comparable due to the similarity of the exhaust systems.

The 1995 study measured the VOC accumulation in water from the exhaust of a 10 hp
(7.3 kW) engine. Because the P 250 MOD 1 engine is a 35 hp (26 kW) engine, the results are
not directly transferable to this larger engine. However, one pertinent observation was reported
in this study which permits the results to be "scaled" for a different engine. This observation was

Portable Damage Control Dram Pump Wet Exhaust
6
-------
that the concentration of VOC in the water was related primarily to the level of HC emissions in
the exhaust. The higher the level of HC emissions in the engine exhaust, the higher the level of
VOC found in the water.15 This indicates that if the level of total HC emissions for a different
engine can be estimated, the VOC introduction rates for the compounds given in the 1995 study
can reasonably be adjusted by comparing the total HC emission rates.

In general, two-stroke cycle engines do not use fuel efficiently since a substantial portion
of unburned fuel and oil can be pushed out with the exhaust gases during scavenging. According
to EPA, two-stroke technology can result hi wasting more than 25-35% of the fuel consumed.13
However, the results presented in the 1995 study indicate that the percentages may be even
higher for smaller engines.

hi the 1995 study, the highest normalized HC emissions rates for the 7.3 kW (10 hp) and
15 kW (20 hp) engines tested were 267 g/kW-hr and 172 g/kW-hr respectively.15 Multiplying
these normalized emission rates by their respective engine sizes yields a total HC emissions rate
of 1949 and 2580 grams per hour. For typical outboard engines, the fuel consumption rates for
these two engines sizes are approximately 4199 and 7110 g/hr.16 Based upon these figures, the
ratio of HC emissions to fuel consumption for each engine can be estimated to be 0.46 for the 10
hp engine and 0.36 for the 20 hp engine.

Based on operational experience, the fuel consumption rate for the 35 hp P-250 MOD 1
pump is approximately 3.0 gallons per hour. Using a specific gravity (s.g.) for gasoline of 0.73,
fuel consumption rate of the P-250 MOD 1 pump is approximately:
Fuel consumption'
grams/hour
• (3.0 gallons/hour)(8.34 Ibs water/gallon)(0 J3 s,g.) = 18.26 Ibs/hr, or_8286
Since the P-250 MOD 1 is a larger engine (35 hp), it can be assumed that one-third of this
fuel is wasted and released as HC in the exhaust.13 Therefore, the HC emissions rate to the air
can be estimated as 2762 grams/hour. Using this number, the ratio of HC emissions was
calculated as shown below:
Total HC emissions rate- 10 hp engine (7.3 kW):,(267 g/kW-hr)(7.3 kW) = 1949 grams/hour
P-250 MOD 1 Emissions rate based on fuel consumption: (8286 g/hr)/3 = 2762 g/hr
Emissions ratio = 2762/1949 =1.418
If it is assumed that there is a direct relationship between the HC emissions rate and the
VOC introduction rate, the rates of VOC introduction measured hi the 1995 study can be
multiplied by the hydrocarbon emissions ratio. Using this approach, Table 5 provides the
estimated VOC introduction rates for the portable damage control drain pump wet exhaust. An
example calculation for benzene is provided below:
Portable Damage Control Drain Pump Wet Exhaust
7
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Benzene introduction rate for a 7.3 kW engine is 2800 mg/10 min (front 1995 study)
Hydrocarbon emissions ratio for a 26 kW engine equals 1.418 (from above calculation)
Benzene introduction rate for a 26 kW engine equals (i.418)(2800 mg/10 min) = 3970
: v :"' ' ' mg/10 min
To estimate the concentration of the constituents in the wet exhaust, the flow rate must be
assumed. From Section 3.2, the approximate wet exhaust flow rate is 2 gpm. A rough
approximation of the constituent concentrations can be made if it is assumed that all the VOC
introduced into the water is transferred into the wet exhaust. These concentrations are shown in
Table 6. A sample calculation is presented below:
Wet Exhaust Flow rate: 2 gpm
Benzene introduction rate: 3970 mg/10 min
Concentration = (3970 mg/10 min)(l min/2gal)(l gal/3.7854 L) - 52.4 mg/L
This approach is limited by several differences between conditions of the laboratory study and
the actual portable damage control pump wet exhaust discharge. These limitations are listed
below:

• The 1995 study was conducted on a typical outboard engine where the entire
engine cooling water flow is discharged through the engine exhaust pipe. For the
portable damage control drain pump, a much smaller amount of water is injected
into the exhaust hose. Therefore, mixing of the exhaust gases with water is not as
complete in the P-250 MOD 1 wet exhaust.

• The length of the exhaust hose is approximately 10 feet, allowing limited contact
time between the water and the exhaust.
!
• The 1995 study was performed on a fixed volume of water. During testing, the
temperature increased from 8.8 °C to 13.5 °C (48-56 °F). This was considered to
be ambient water temperature for central Europe.17 However, in many United.
States ports, ambient water temperature may be up to 10 °C higher. After
injection, the temperature of the wet exhaust will be higher still. As a general
rule, the solubility of a VOC in water will decrease threefold for every 10 °C
temperature rise.18 Therefore, the actual VOC concentrations may be as much as
nine times less than estimated due to temperature effects.
•
P-100: The P-100 does not have a wet exhaust discharge. It does release less than 1/2
liter of water containing trace amounts of exhaust during pump priming. This discharge usually
puddles on the deck and is wiped up with rags. P-100 priming discharge is expected to contain
less than 5 milligrams per liter (mg/L) of oil and grease.
Portable Damage Control Drain Pump Wet Exhaust
8
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4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria, hi
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Using the annual flow volumes shown in Table 1, annual mass loadings of constituents to
receiving waters from USCG, MSC, Navy, and Army fleets were estimated. A sample annual
mass loading calculation for benzene from P-250 MOD 1 pumps follows:
Mass loading (kg/yr) - (total flow fate(gal/yr))(concentratiok(mg/L))(3.785
Mass loading rXZWOpgaJ/vr^a^mg^XSJSSL/g^OO
'. Mass loading == 5k3 kilograms per year,(kg/yr)
For estimating mass loadings, the metals concentration for the P-250 MOD 1 wet exhaust
and the P-250 MOD 2 wet exhaust were assumed to be the same. Annual mass loadings for each
type of portable damage control pump are presented in Table 7. The table shows that the greatest
mass loadings are estimated to be toluene and xylene isomers, both of which are over 200 pounds
yearly. However, even for toluene, which is the greatest single component, the discharge per
event for a MOD 1 pump is only 0.08 pound based on a 30 minute operating period.

4.2 Environmental Concentrations

A comparison of maximum estimated constituent concentrations in the P-250 MOD 1
pump wet exhaust with water quality criteria (WQC) is presented hi Table 8. This table indicates
that the discharge is expected to exceed the criteria for five constituents. In addition, one of three
analyses of P-250 MOD 1 discharge indicate that the Florida WQC for oil and grease was
exceeded.

Environmental concentrations of the constituents in Table 8 will not be significant for
several reasons. The discharge from each of the 500 P-250 pumps occurs separately at different
discharge locations. On average, each P-250 pump discharges less than 0.3 pounds of pollutants
per discharge event. The duration of each discharge event is short, averaging less than 30
minutes. These three factors allow the pollutants to dissipate quickly.

4.3 Potential for Introducing Non-indigenous Species

Portable damage control pump wet exhaust does not involve the transport of sea water.
Therefore, it is unlikely that the pumps could introduce foreign species into receiving waters.
Portable Damage Control Drain Pump Wet Exhaust
9
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5.0 CONCLUSION

Wet exhaust from portable damage control pumps has a low potential for causing an
adverse environmental effect because mass loadings of benzene, toluene, ethylbenzene,
naphthalene, oils, and greases are not significant, although the discharge concentrations of these
constituents are expected to exceed water quality criteria. Additionally, environmental
concentrations of the above constituents are not expected to exceed water quality criteria because
they are expected to dissipate quickly because the mass loadings per discharge event are small
and the discharge locations are dispersed fleetwide.
6.0 DATA SOURCES AND REFERENCES
'!' ' I
To characterize this discharge, information from various sources was obtained. Process
information, equipment specifications, and projected equipment inventories were used to
estimate the rate of discharge. Based on this estimate and on the reported concentrations of oil
and grease constituents, the concentrations of the oil and grease constituents in the environment
resulting from this discharge were then estimated. Table 9 shows the sources of data used to
develop this NOD report.
i
Specific References
1
1. Personal Communication (Fonecon): Steinberg, Bob, M. Rosenblatt & Son. Status of
USN P-250 Replacement Program, 23 January 1998, Mark Hampson, NSWC

2. Personal Communication (Fonecon): Steinberg, Bob, M Rosenblatt & Son. Status of
MSC P-250 Replacement Program, 5 February 1998, Joe Bohr, MSC Code N72PC
: , '• ij
3. UNDS Equipment Expert Meeting Minutes. "Portable Damage Control Pump Wet
Exhaust". September 3,1996.
'' ,' ii
4. Naval Ships' Technical Manual (NSTM), Chapter 555, Vol. 1, Revision 4, Surface Ship
Firefighting. pp 4-23 to 4-32. 8 December 1997.

5. UNDS Round 2 Equipment Expert Meeting Minutes, Nature of Discharge Report
Review. March 26,1997

6. Personal Communication: Chief Warrant Officer Duribar(USCG) and Doug Hamm
(Malcolm Pimie, Inc.), January 26,1997 and March 27,1997.

7. Saponara, N. et al. "UNDS Shipcheck of US Army Watercraft, Fort Eustis, VA, 21-22
January 1998: Trip Summary", undated
Portable Damage Control Drain Pump Wet Exhaust
10
-------
8.
9.
10.
Personal Communication (Fonecon): Steinberg, Bob, M. Rosenblatt & Son, Inc. Army
Purchases of P-100 Pumps, 14 January 1998, Paul Darley, W.S. Darley & Co.

Personal Communication (VoiceMail): Chew, Don, LCOL, USAF, HQ, USAF (ILTV).
Portable damage control pumps on Air Force Watercraft, 21 January 1998, Bob
Steinberg, M. Rosenblatt & Son, Inc.

Maintenance Index Page (MJJP) 6641/008-B2, Portable Gasoline/JP-5 Driven Pump,
November 1992.
11. USCG Uniform Maintenance Procedure Card (UMPC) R-M-014.

12. Personal Communication, LT Joyce Aivalotis USCG to M. Rosenblatt & Son, June 5,
1997.

13. USEPA, Regulatory Impact Analysis: Control of Air Pollution Emission Standards for
New Nonroad Spark-Ignition Marine Engines. Office of Air and Radiation, Washington
DC. June 1996.

14. Laboratory Environmental Analyses Request Form, NAVSSES to C/194. April 29,1992.

15. Juttner, et. al, "Emissions of two- and four- stroke outboard engines-1. Quantification of
Gases and VOC". Water Resources, Vol. 29, pp. 1976-1982. November 1995.

16. Nissan Marine Corporation, "Nissan Outboard Fuel Consumption", Information from
website retrieved November, 1997, location
http://www.nissanmaiine.com/techtalk/mileage.htmL

17. Juttner, F., "Emission of Aromatic Hydrocarbons and Aldehydes into the Water by a
Four-stroke Outboard Motor: Quantitative Measurements, Chemosphere, Vol. 29, No.2,
pp. 191-200,1994.

18. Kavanaugh, M., and Trussell, R., "Design of Aeration Towers to Strip Volatile
Contaminants from Drinking Water", Journal of the American Water Works Association,
December 1980, pg. 684.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.
Portable Damage Control Drain Pump Wet Exhaust
11
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!
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. 62, Number 150. August 5,1997.
• .; i|
Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.
i
Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.
i
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Portable Damage Control Drain Pump Wet Exhaust
12
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RECOIL STARTER
HANDLE
AIR CLEANER
HOUSING
MANUAL
PRIMING POINT
PUMP
SUCTION
VARIABLE RATIO
OILER (VRO PUMP)
MUFFLER
ENGINE COOLING
WATER STRAINER
LOCATION
ENGINE EXHAUST
SKID PAD
FUEL PRIMER BULB
FUELTANK
RUN/START/STOP/ SWITCH

ELASPED TIME METER

THOTTLE LEVER

MANUAL PRIMER PUMP

PRESSURE GAUGE

DISCHARGE
VALVE HANDLE

ENGINE FUEL PRIMER

ENGINE COOLING
WATER FLOW INDICATOR

STRAINER FLUSH VALVE

—— I PUMP DISCHARGE
PUMP UNIT SERIAL
NUMBER PLATE
ENGINE OIL TANK
OIL LINE PRIMER BULB

AUTOLUBE FILL PLUG
Figure 1. P-250 MOD 1 Portable Gasoline Engine Driven Centrifugal Fire Pump
Portable Damage Control Drain Pump Wet Exhaust
13
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Figure 2. P-100 Portable Diesel Engine Driven Centrifugal Pump
Portable Damage Control Drain Pump Wet Exhaust
14
1 ,i',iii,:;! „„ ' a in,TV
-------
Table 1. Cumulative Wet Exhaust Discharge
P-250 MOD 1
P-100
TOTAL:
298,900
1,546
300,446
- From pump priming

Table 2. P-250 Metals Analyses14'b
_ Constituent
Cadmium
Total Chromium
Copper
Lead
Nickel
Silver
Zinc
Concentration (ppm)
O.001
0.08
0.23
0.85
0.21
0.01
3.90
- Data taken in 1992 from P-250 Mod 2 pumps. Although the Mod 2 pump is no longer in service, the exhaust and
cooling systems are identical to that of the Mod 1 pump; therefore this data should be representative of the Mod 1
pump.
Table 3. Wet Exhaust Constituents Emitted from Two-Stroke Gasoline Outboard Engines
15
Compound
Benzene
Toluene
Ethylbenzene
p/m-Xylene
o-Xylene
3/4-Ethyltoluene
2-Ethyltoluene
Indane
Indene
Naphthalene
2-Methylnaphthalene
1 -Methylnaphthalene
Formaldehyde
Amount in Wet Exhaust from Two-Stroke
' Outboard Engines (mg 710 min.) * ;
2800
8500
2000
6900
3600
3400
1200
840
270
1400
930
350
970
Portable Damage Control Drain Pump Wet Exhaust
15
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Table 4. Laboratory Analyses of Exhaust Effluent Oil and Grease Analyses
14
Pump Model
P-250 MOD 1 Sample 2A
P-250 MOD 1 Sample 2B
P-250 MOD 1 Sample 2C
Oil & Grease Concentration (ppm)*
less than 5
less than 5
6
* parts per million (ppm)
Table 5. Estimated Wet Exhaust Constituents from P-250 MOD 1 Portable DC Drain
Pump Engine
Compound
Benzene
Toluene
Ethylbenzene
p/m-Xylene
o-Xylene
3/4-Ethyltoluene
2-Ethyltoluene
Indane
Indene
Naphthalene
2-Methylnaphthalene
1 -Methylnaphthalene
Formaldehyde
Amount in Wet Exhaust from Two-Stroke
Outboard Engines (mg / 10 train.)
3,970

12,054
2,836
9,784
5,104
4,822
1,702
1,192
382
1,986
1,318
496
1,376
Portable Damage Control Drain Pump Wet Exhaust
16
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Table 6. Estimated Concentrations of P-250 MOD 1 Portable DC Drain Pump Exhaust
Constituents
Compound
Benzene
Toluene
Ethylbenzene
p/m-Xylene
o-Xylene
3/4-Ethyltoluene
2-Ethyltoluene
Indane
Ihdene
Naphthalene
2-Methylnaphthalene
1 -Methylnaphthalene
Formaldehyde
Estimated concentration in two-
stroke engine wet exhaust (mg/L)
52.4
159.2
37.4
129.2
67.4
63.6
22.4
15.8
5.0
26.2
17.4
6.6
18.2
Portable Damage Control Drain Pump Wet Exhaust
17
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Table 7. Estimated Maximum Annual Mass Loadings
Constituent
Concentration
(mg/L)
Mass, Loading
fkg/vr)
Mass Loading
- (Ibs/yr)
P-250 MOD 1 -Annual Flow Rate 298,900 gallons per year
Benzene
Toluene
Ethylbenzene
p/m-Xylene
o-Xylene
3/4-Ethyltoluene
2-Ethyltoluene
Indane
Indene
Naphthalene
2-Methyhiaphthalene
1 -Methykiaphthalene
Formaldehyde
Oil and Grease
Cadmium*
Total Chromium*
Copper*
Lead*
Nickel*
Silver*
Zinc*
52.4
159.2
37.4
129.2
67.4
63.6
22.4
15.8
5.0
26.2
17.4
6.6
18.2
6
<0.001
0.08
0.23
0.85
0.21
0.01
3.90
59.3
180
42.3
146
[ 76.3
72.0
25.3
17.9
5.66
29.6
19.7
7.5
20.6
6.79
0
0.09
0.26
0.962
0.238
0.0113
4.41
131
397
93.3
322
168
159
55.9
39.4
12.5
65.4
43.4
16.5
45.4
15.0
0
0.2
0.574
2.12
0.524
0.0249
9.73
P-100 - Annual Flow Rate 1,546 gallons per year
Oil and Grease
5
0.029
0.065
* - Data taken in 1992 fromP-250 Mod 2 pumps. Although the Mod 2 pump is no longer in service, the exhaust and
cooling systems are identical to that of the Mod 1 pump; therefore this data should be representative of the Mod 1
pump.
Portable Damage Control Drain Pump Wet Exhaust
18
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Table 8. Comparison of Environmental Concentrations and Water Quality Criteria (mg/L)
P-250 MOD 1
Constituent
Benzene*
Toluene*
Ethylbenzene*
Naphthalene*
Oil & Grease
Copper
Lead
Nickel
Silver
Zinc
Estimated
Concentrations
52.4
159.2
37.4
26.2
6*
0.23
0.85
0.21
0.01
3.9
- Federal Acute WQC
•C % V - - N '
none
none
none
none
visible sheena / 15b
0.0024
0.21
0.074
0.0019
0.09
Most Stringent State
Acute WQC
0.07128 (FL)
2.1(HI)
0.14(HI)
0.78(HI)
5(FL)
0.0024 (CT, MS)
0.0056 (FL, GA)
0.0083 (FL, GA)
0.0012 (WA)
0.0846 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.

* Highest of three separate samples. Remaining samples were <5 ppm.

CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
3 Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen
on receiving waters.
b International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as
implemented by the Act to Prevent Pollution from Ships (APPS)
Portable Damage Control Drain Pump Wet Exhaust
19
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Table 9. Data Sources

NOD Section
2.1 Equipment Description and
Operation
23. Releases to the Environment
23 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
33 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
43 Potential for Introducing Non-
Indigenous Species
Data Source
Reported
X
X
UNDS Database
X
X
X
X

Sampling

.
.X
X

Estimated

X
X
X
Equipment Expert
X
X
X
X
X
X

X
Portable Damage Control Drain Pump Wet Exhaust
20
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NATURE OF DISCHARGE REPORT
Refrigeration/AC Condensate
1.0 INTRODUCTION

This section describes the condensation discharge that is produced from air conditioner
(AC) units, refrigerated spaces, and stand-alone refrigeration units and includes information on:
the equipment that is used and its operation (Section 2.1), general description of the constituents
of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
j
2.1 Equipment Description and Operation
ii
AC units provide cooling for ship spaces. When warm, moist air passes over the
refrigeration coils of an AC unit, condensation forms that drips from the coils. This condensation
is produced continuously while the AC unit is operating. In addition to AC units, vessels have
refrigerated spaces for food and other perishable materials. These spaces are designed for both
frozen and chilled cargo and commonly range in temperature from below 0 °F to 35 °F.1
Condensation also forms from the normal operation of these refrigerated spaces when moist air is
cooled below the dew point on the cold evaporator coils of the refrigeration system. The
condensate is collected in drains hi these refrigerated spaces.
; i.
Two types of refrigerated space systems are used: gravity-coil units and forced-air units.
Gravity-coil units are typically used in older ships. They employ tinned-copper refrigerant piping
which runs back and forth along one or more bulkheads in the refrigerated space.1 Aluminum
fins are attached to the piping to provide a large surface area for the exchange of heat. As the air
cools, it becomes more dense and sinks below the comparatively warmer air, creating circulation
without the need for a fan. One disadvantage to this type of cooling unit is that the tubing is
bulky, so the use of gravity-coil units has been discontinued on newer Navy ships. Forced-air
refrigeration units are more compact, self-contained, and use a fan to blow air across the coils.
The forced-air units can be used not only in cold storage spaces, but also in other ship spaces.

On most surface ships, gravity coil refrigerant piping is made of tinned-copper.1'2'3 The
forced-air units Jiave brazed-copper piping. Submarine refrigerated space refrigerant piping and
evaporator coils are made of copper.1

Drip troughs (galvanized steel or tinned-copper) are installed under gravity-type cooling
coils to collect condensate or water during defrosting.1 The piping from these troughs is as short as
practicable and leads to compartment drain piping. The forced-air units have drip pans made of
galvanized steel or tinned-copper which are placed under the units to collect the condensate.
Valved deck drains are also installed in refrigerated spaces that have operating temperatures
above 32°F. Deck drains are installed in refrigerated spaces with operating temperatures below
32°F. At least one deck drain is installed in the passage or compartment outside the refrigerated
food storage spaces.1
;, , |. .
The condensate drainage is similar for vessels of all the Armed Forces: condensate
produced above the waterline is directed overboard; condensate produced below the waterline is
retained on board temporarily before it is pumped overboard. On most Navy ships, condensate is
routed directly overboard or combined in a common condensate drain and discharged overboard
Refrigeration/AC Condensate
2
-------
if the space is above the waterline or to a condensate drain tank if the space is below the water
line.2 Some condensate may also be directed to the machinery space wastewater drain system,
the wastewater receiving tank, the sewage collection, holding, and transfer (CHT) tank, or the
bilge. On Army watercraft, condensate from refrigeration and air conditioning systems is not
collected. Any condensate which forms is typically removed by natural evaporation; if a
significant amount of condensate accumulates, it may be removed by mopping or wiping. On
vessels of the other Armed Forces, the condensate is discharged to the bilge from spaces below
the waterline.

On submarines, drains are installed in chilled stores space decks to remove water from
condensation and defrosting. The drains are provided with an isolation valve and lead to a bilge
collecting tank or sanitary tank.

2.2 Releases to the Environment

Refrigeration/AC condensate is generally released to the environment by direct gravity
drainage overboard, or in some cases from a condensate drain tank or other collection points
below the waterline. hi addition to continuous condensate drainage, intermittent discharges from
refrigerated spaces include water and mild detergents used for cleaning (generally weekly), and
water from melting ice that is created when the spaces are defrosted (for gravity-coil units,
weekly or when the thickness of the frost on the refrigeration coils exceeds 3/16 inch).4 The
water from cleaning and defrosting is discharged into the space drains or the deck drains.

Organic materials can be an infrequent part of the discharge from residual spilled food
items that wash into the drainage. Although spilled food can be washed to drains occasionally,
spills would normally be cleaned and disposed of as solid waste or into graywater drains.

Navy supply ships that carry refrigerated cargo for at-sea replenishment of Navy combatants
use hot seawater spray to defrost the cargo spaces. This seawater, as well as the freshwater used to
flush out any residual seawater after defrosting, is discharged through the refrigeration condensate
drainage piping. The seawater is provided by the firemain and is heated to 100 °F by a dedicated
heater prior to being sprayed at a maximum rate of 100 gallons per minute on the refrigeration
coils. The vessel classes that employ heated seawater spray for defrosting are the AFS, AOE,
AO, and AOR classes.5

Refrigeration condensate could contain trace amounts of metal from the refrigerant coils
and drainage piping, but these concentrations are expected to be comparatively low (see Section
3.4).

2.3 Vessels Producing the Discharge

Navy and MSC vessels produce refrigeration and AC condensate; this includes 254 Navy
surface ships, 94 Navy submarines, and 70 MSC ships.2 hi addition, an estimated 228 Coast
Guard vessels and 4 Air Force vessels produce this discharge.
Refrigeration/AC Condensate
3
-------
The primary difference between ship classes is the amount of condensate that is
generated, which depends on ambient temperature, relative humidity, and the size and number of
units per ship. USCG vessels also produce refrigeration and AC condensate, and use
specifications similar to the Navy for refrigeration and AC units. Army watercraft have no
collection or discharge of condensate from refrigeration or air conditioning systems.
3.0 DISCHARGE CHARACTERISTICS
I
j
This section contains qualitative and quantitative information that characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and near-
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Flows from refrigeration units and AC units can be discharged at any time, both within
and beyond 12 nautical miles (n.m.) from shore. Operation of the refrigerated spaces and AC
units in port or in transit is not significantly different from operation beyond 12 n.m. from shore.

3.2 Rate

No measurements are available to fully characterize the flow for refrigeration/AC
condensate for all ship classes. The range of flow rates volumes will depend on the temperature
and humidity of the air and the capacity of the cooling units.

Amphibious ships and aircraft carriers of the Navy tend to have the most air conditioning
capacity because of their large contingent of personnel, and therefore, represent worst-case flow
rates for AC condensate discharge. An estimate of AC condensate volume was developed for an
amphibious ship and an aircraft carrier. The estimate was derived for typical ship operating
conditions. The worst-case scenario assumes an unlimited supply of humid air (above 60°F) to
the AC system. In reality, after the air has been dehumidified, the exchange rates with new air
art much lower and will limit available moisture for condensate to about half the worst case
amount. The estimate also assumed that condensate is generated when the outside air is 60°F dry
bulb or higher.6
I •
Based on the above conditions, an amphibious ship will generate no more than 3,840
gallons of condensate per day, and an aircraft carrier no more than 6,795 gallons per day.
Vessels of the other Armed Forces tend be smaller and have fewer personnel, and therefore, will
produce less AC condensate discharge.
i
3.3 Constituents
' !'
Refrigeration condensate could contain metals from the refrigerant coils and condensate
drainage piping, and mild detergents from the occasional cleaning of the refrigerated spaces. AC
i
I
Refrigeration/AC Condensate
4
-------
condensate could contain small amounts of metal from the AC coils or the drain piping. These
materials can include aluminum, bronze, copper, iron, lead, nickel, silver, tin, and zinc.

Food particles washed into the condensate drainage system from occasional food spills
would increase the Biochemical Oxygen Demand (BOD) in the discharged water. Seawater used
to defrost cargo spaces on Navy supply ships, and the freshwater used to flush residual seawater
from the cargo spaces are also intermittent constituents of this discharge.

The priority pollutants of this discharge are copper, lead, nickel, silver, and zinc. None of
the constituents of this discharge is a bioaccumulator.

3.4 Concentrations

Refrigeration/AC condensate can contain small amounts of metals from contact with
refrigerant coils and condensate drainage piping. These concentrations are expected to be low for
the following reasons:

1) Condensate is essentially pure water and is not a corrosive medium such as seawater;
2) Drainage lines are only fractionally full of condensate which indicates qualitatively
low flow and low residence time;
3) Condensate drainage flow velocities and turbulence are extremely low. Therefore,
erosion of metals hi drainage is not a factor as it could be in pressurized seawater
systems;
4) The residence time of condensate hi drainage systems is low. The negligible increase
hi the residence tune because of the slower flow does not increase the chance of
entrainment of metals;
5) Copper drainage piping forms a protective corrosion-inhibiting film of cuprous oxide
on surfaces in contact with water;7 and
6) The low temperature of this discharge, both on refrigeration coils and hi the
condensate drainage piping, would tend to inhibit the corrosion process.

Food spills which could contribute some organic matter to the discharge are hitermittent
and limited to small amounts. Therefore, they are expected to contribute very little BOD to the
discharge. Seawater is also a component of refrigeration condensate discharge of vessels with
cargo refrigeration spaces.
4.0 NATURE OF DISCHARGE ANALYSIS

Mass loadings were not calculated for this discharge.

4.2 Environmental Concentrations

Refrigeration/AC condensate is essentially atmospheric moisture which condenses on
refrigeration coils. For reasons stated in Section 3.4, concentrations of any of the
constituents in this discharge are expected to be low. Therefore, the probability that 1
discharge results in any measurable effect on environmental concentrations is

4.3 potential for Introducing Non-Indigenous Species
ie potential
this
low.
Because this discharge consists of atmospheric moisture, the potential for introducing
non-indigenous species is not significant.
5.0 CONCLUSION
j
Mass loadings and environmental concentrations cannot be calculated with existing
information; however, process information is sufficient to characterize the concentrations and
loadings of constituents of this discharge.

Refrigeration/AC condensate has a low potential for adverse environmental effect
because:

1) the liquid discharge is moisture condensed from the air;
2) concentrations of metals are expected to be low due to the non-erosive and non-
corrosive nature of this discharge, and its low temperature; and
3) the contribution from detergents and from food residues is expected to be small and
intermittent in nature.
6.0 DATA SOURCES AND REFERENCES
' !
To characterize this discharge, information from various sources was obtained. Table 1
shows the sources of data used to develop this NOD report.

Specific References
11 ' i!
1. Naval Sea Systems Command (NAVSEA), General Specifications for Ships of the United
States Navy, Section 516 - Refrigeration Plants. 1995 Edition.

2. UNDS Equipment Expert Meeting - Refrigeration/AC Condensate. 15 October 1996.
Refrigeration/AC Condensate
6
-------
3. Military Sealift Command (MSC), General Specifications for T-ships, Section 514 - Air
Conditioning Refrigeration Systems. 1991 Edition.

4. Maintenance Requirement Card (MRC) A3 8YVEN, Refrigeration Plant. October 1993.

5. Kitchen, Gary, NAVSEA 03L2. Cargo Space Refrigeration Coil Defrosting, 9 January
1998, Matthew Worris, M. Rosenblatt & Son, Inc.

6. Goodhue, John, NAVSEA 03L2. Estimate of Air Conditioning Condensate Rates for
UNDS, 23 April 1997, Leslie Panek, Versar, me.

7. Davis, Joseph R., et al., Metals Handbook Ninth Edition, Volume 13, Corrosion, ASM
International Handbook Committee, Metals Park, Ohio, 1990.
General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22, 1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Naval Sea Systems Command (NAVSEA), General Specifications for Ships of the United States
Navy, Section 528 - Plumbing, Plumbing Vents, and Space and Weather Deck Drains.
1995 Edition.

Naval Sea Systems Command (NAVSEA), General Specifications for Ships of the United States
Navy, Section 534 - Machinery and Piping Systems Drainage. 1995 Edition.
'! |l
Baumeister, Theodore; Eugene Avallone; and Theodore Baumeister JJI. Marks' Standard
Handbook for Mechanical Engineers. McGraw-Hill Book Company, Eighth Edition,
1978.
i
i
Harrington, Roy L. Marine Engineering. The Society of Naval Architects and Marine Engineers,
1971.

Sharpe, Richard. Jane's Fighting Ships. Jane's Information Group, Ltd., 1996.

Naval Sea Systems Command (NAVSEA), General Specifications for Ships of the United States
Navy, Section 514 - Air Conditioning Plants. 1995 Edition.

UNDS Equipment Expert Meeting - U.S. Army Input to Equipment and Expert Meeting,
Refrigeration/AC Condensate. 5 February 1997.
. : I i
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
i •
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Refrigeration/AC Condensate
8
-------
Table 1. Data Sources

NOD Section
2.1 Equipment Description and
Operation *-
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality - - » .
3.2 Sate - „
3.3 Constituents
3.4 Concentrations "
4,1 Mass Loadings
4.2 Environmental Concentrations -
4.3 Potential for Introducing'Non- '
Indigenous Species
^ - Data" Source — v
^-Reported

UNDS Database

MSDS

Sampling

Estimated

Equipment Expert
X
X
X
X
X
X
X
X
X
X
Refrigeration/AC Condensate
9
-------
-------
NATURE OF DISCHARGE REPORT
Rudder Bearing Lubrication
1.0 INTRODUCTION

The purpose of the NOD report is to describe the discharge in detail, including the system
that produces the discharge, the equipment involved, the constituents released to the
environment, and the current practice, if any, to prevent or minimize environmental effects.
Where existing process information is insufficient to characterize the discharge, the NOD report
provides the results of additional sampling or other data gathered on the discharge. Based on the
above information, the NOD report describes how the estimated constituent concentrations and
mass loading to the environment were determined. Finally, the NOD report assesses the
potential for environmental effect. The NOD report contains sections on: Discharge
Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data
Sources and References.
Rudder Bearing Lubrication
1
-------
2.0 DISCHARGE DESCRIPTION
• • • • • : !.
This section describes the rudder bearing lubrication discharge and includes information
on the equipment used, its operation (Section 2.1), general description of the constituents of the
discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
ij
2.1 Equipment Description and Operation
II
Rudder bearings support the rudder and allow it to turn freely. While there are small
variations among similar rudder bearings systems, there are generally two major types of rudder
bearings and two lubricating methods for each type, resulting in four different bearing/lubrication
method combinations. They are:

• grease-lubricated roller bearings,
• oil-lubricated roller bearings,
• grease-lubricated stave bearings, and
• water-lubricated stave bearings.
•i r
•. . i
Grease-lubricated Roller Bearings. The rudder stock arrangement for grease-lubricated
roller bearings includes a void space between the lower bearing and the hull seal (Figure 1). This
design prevents seawater from entering the bearing and causing damage. Water that leaks past
the hull seal, as well as grease that leaks past the bearing seals, will enter the void space and
drain to the bilge. Thus, discharges from grease-lubricated roller bearings contribute to the
bilgewater discharge which is covered in a separate NOD report. Since 1970, grease-lubricated
roller bearings have been preferred for use on rudder stocks.
1 !!
Oil-lub'riQated Roller Bearings. There is no void space in the rudder stock arrangement
used for oil-lubricated roller bearings and the bottom seal of the lower bearing serves as the hull
seal (Figure 2). To prevent water from entering the bearing and causing damage, the oil is kept at
a slight positive pressure relative to the surrounding seawater pressure by supplying the oil from
an elevated "head" tank located above the waterline. If a leak occurs, this positive pressure will
cause lubricating oil to leak directly into the sea.1

Stave Bearings (Grease and Water Lubricated). This type of bearing is typically
located outside of the hull (Figure 3). Stave bearings, which are similar in appearance to the
wooden staves that make up a barrel, are typically made of a phenolic-resin material. Depending
on the actual type, these stave bearings may be lubricated by grease or water. Grease, when used,
is forced into the bearing to lubricate the area where the rudder stock and staves meet. Water-
lubricated stave bearings are designed with passages which allow seawater to flow through the
bearing. For classification purposes, the bushings found on small boats and craft are included in
this subheading due to the similarities in function and design.

Hull seals are used with all types of rudder bearings. A hull seal is installed where the
rudder stock penetrates the hull. This seal prevents seawater from entering the ship and
damaging the lower bearing, while in the case of oil-lubricated roller bearings it also keeps the

Rudder Bearing Lubrication
2
-------
oil in the bearing cavity from leaking to the sea. la many cases this seal is a type of lip seal but
flax packing can be found on older ships. A lip seal consists of a rubber circular ring with a
flexible lip. This lip has a narrow contact area that rubs on the circumference of the shaft,
forming a seal. Flax packing seals in a similar fashion as several rows of the circular packing
material rubs along the rudder stock. Minor leakage can occur in both cases and their rubbing
contact will eventually cause wear on the rudder stock. Hull seals are inspected when the ship is
in dry dock, typically every four or five years.

The potential of oil leakage from lip seals and flax packing is greatest when a vessel is
underway and the rudder is in use rather than when pierside and the rudder is idle. When the
vessel is underway, the action of turning exerts forces on the rudder and rudder stock that can
cause a temporary gap in the seal or packing coverage. The harder the turn or higher the vessel
speed, the greater these forces are and the greater the potential is for oil leakage and the amount
of leakage.

The latest trend in rudder stock hull sealing is to use a face seal. These seals eliminate
the minor leakage sometimes associated with lip seals and flax packing. Face seals move the
sealing point away from the rudder stock to two circular, hard, mating faces. One half of the seal
rotates with the rudder stock while the other half is rigidly attached to the hull of the ship. These
mating faces are honed to very small tolerances and while rubbing together prevent liquids from
seeping through their very fine and smooth contact area. Face seals used on rudder stocks are
designed not to leak as a result of the forces placed on the rudder stock during turning.1

2.2 Releases to the Environment

The two releases possible are oil from oil-lubricated roller bearings and grease from
grease-lubricated stave bearings.

2.3 Vessels Producing the Discharge

All Navy surface ships have rudder bearings, except for those with steerable thrusters or
cycloidal propellers, such as the MHC 51 Class minesweepers.1 Vessels belonging to the
Military Sealift Command (MSC), U.S. Coast Guard (USCG), Army, and Air Force also have
rudder bearings.

Most rudder bearings (roller or stave) are grease-lubricated. Only the AS 36/39 Class and
AOE 1 Class ships, which form 4 percent of the total number of Navy ships, have oil-lubricated
rudder bearings. The T-AFS 1 and T-AE 26 Classes of MSC are also fitted with oil-lubricated
rudder bearings. USCG vessels do not have oil-lubricated rudder bearings. The rudder bearings
or bushings found on small boats and craft are typically made of self-lubricating materials and
are either not lubricated or use water for lubrication.

Surface ship rudders with oil-lubricated roller bearings and grease-lubricated stave
bearings have the potential to produce an oil or grease discharge. Table 1 lists the rudder bearing
type and lubrication method for each Navy ship class. There are currently five Navy ships that
Rudder Bearing Lubrication
3
-------
use oil lubrication for rudder bearings. Five AS 36/39 Class ships (submarine tenders) and four
AOE 1 Class ships (fast combat support ships) were originally fitted with lip seals. Of the
submarine tenders, AS 36 and AS 37 are being decommissioned.2 The three remaining ships
(AS 39-41) are currently scheduled to have their lip seals replaced with face seals. The
replacements are expected to begin in 1999 and conclude in 2002.1 Of the four AOE 1 Class
ships, AOE 2 and AOE 3 have been fitted with face seals. The other two ships in the class are
also scheduled to be fitted with the same type efface seal.3 Therefore, any discharges of oil from
the rudder bearings on Navy vessels is expected to be eliminated in the next 4 to 5 years. Of the
MSC ships, the T-AE 35 had the face seal installed in December 1997.4

USCG ships vise water- and grease-lubricated bearings on their rudder stocks, as
summarized in Table 2.5 Small boats and craft use bearings/bushings that are either self-
lubricated or water-lubricated. The lubricity of the materials used in self-lubricated
bearings/bushings is such that additional lubricants are not required; water-lubricated
bearings/bushings are also made of special materials, but require water to be present on then-
contact surfaces for proper lubrication. Table 3 lists the rudder bearings/bushings found in
USCG small boats and craft.6 The upper bearing/bushing of these small boats and craft is
typically self- or grease-lubricated because it may not contact the water, while the lower
bearing/bushing is lubricated by being submerged in the water. The USCG is increasing the use
of self-lubricated bearing material in its ships and is reducing the use of grease as a lubricating
material in all areas exposed to the sea and weather.5
: ,; . . . . j:.
Table 4 lists MSC vessels, including the type of bearing, method of lubrication, and
allowable leakage rates. Eight TAB 26 Class and eight TAPS 1 Class vessels have oil lubricated
bearings.
i
Army and Air Force vessels have rudder bearings similar to those found on Coast Guard
vessels of comparable size.
3.0 DISCHARGE CHARACTERISTICS
1! !
i
This section contains qualitative and quantitative information which characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and near-
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
li .
3.1 Locality
1!!
This discharge can occur in port and while operating within 12 nautical miles (n.m.).
1 ii
I
3.2 Rate

This discharge comprises the leaking of oil or the washout of grease from rudder
bearings. For the oil discharge, rules-of-thumb for characterizing hull seal failure limit the hull
Rudder Bearing Lubrication
4
-------
seal leakage rates to one gallon per day at sea and one pint per day in port.2 These rates are
abnormally high and are typically associated with a malfunctioning or failing seal. Little or no
leakage would be expected from a properly functioning and maintained seal.

3.3 Constituents

In general, greases and lubricating oils are made from lubricating stocks generated during
petroleum fractionation. These fractions contain organic compounds that are generally larger
molecules, containing more than 17 carbon atoms. Lubricating oils are composed of aliphatic,
olefinic, naphthenic (cycloparaffinic), and aromatic hydrocarbons, as well as additives,
depending on their specific use. Lubricating oil additives may include antioxidants, bearing
protectors, wear resistors, dispersants, detergents, viscosity index improvers, pourpoint
depressors, and antifoaming and rust-resisting agents.7 Not all the additives may be present at
one time. It is anticipated that the additives are similar to those found in commercial oils. There
are no bioaccumulators expected to be present in this discharge.

3.4 Concentrations

The greases and lubricating oils used conform to MDL-G-24139 specifications and
2190TEP (MDDL-L-17331) respectively.1 Based on MSDS information, MIL-G-24139 grease
contains 86% hydrotreated heavy paraffinic distillates, 6% clay, and 4% fatty acid amides.
Lubricating oil 2190 TEP contains greater than 99% heavy hydrotreated paraffinic distillates and
less than 1% additives.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality standards. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loading

4.1.1 Oil

At Sea. A high estimate of the oil released by a ship at sea is one gallon of oil per day, as
discussed in Section 3.2. It is also estimated that it takes 4 hours for a ship to cover the 12 n.m.
transit zone. Therefore, during each transit (either into or out of port), one-sixth of a gallon of oil
could be released. An AOE 1 Class ship averages 22 transits per year and an AS 36/39 Class
ship averages 12 transits per year. Under this scenario, an AOE 1 Class ship could release
(l/6)(22) = 3.7 gallons of oil and an AS 36/39 Class ship would release (1/6)(12) = 2.0 gallons of
oil to the surrounding seawater each year. As stated in Section 2.3, two AOE 1 Class ships and 3
AS 36/39 Class ships have oil-lubricated bearings. The maximum estimated amount of oil

Rudder Bearing Lubrication
5
-------
released from Navy ships fleetwide per year within 12 n.m. would be (3.7)(2) + (2.0)(3) = 13.4
gallons. Using a specific gravity of 0.89 for oil (MSDS for 2190TEP), this translates into
approximately 100 pounds per year (Ibs/year).
1 i] i •
I ,
Using the same logic for the MSC ships, eight T-AE 26 Class (8 transits) and eight T-
AFS 1 Class (14 transits), the total mass loading would be:
(1/6 gallonsXS transits)(8 ships) + (1/8 gallons)(14 transits)(8 ships) =
29.3 gallons or 218 Ibs/year
Therefore, the total mass loading at sea during transit would be 100 + 218 = 318 Ibs/year.
However, the actual release rates will be much less because all ships of a class will not leak oil at
such high rates, for such a long period of time, at the same time.

In Port. A high estimate of the oil released by a ship in port is one pint per day, as
discussed in Section 3.2. Assuming that each of the two AOE 1 Class and three AS 36/39 Class
ships spend 183 days per year in port, the total amount of oil released would be (1 pint)(5
ships)(183 days/yr) = 915 pints or 114 gallons per year. This translates into approximately 846
Ibs/year.

For the eight MSC ships, the total amount of oil released hi port would be:
(1 pint)(8 ships)(183 days/year) = 1,460 pints/year, 183 gallons/year, or 1,360 Ibs/year.
Therefore, the maximum estimated mass loading in port would be 846 + 1,360 = 2,206
Ibs/year. However, the actual release rates are expected to be much less because all ships of a
class will not leak oil at such high rates, for such a long period of time, at the same time.

4.1.2 Grease
;' ' !!
,. I,
Grease washout occurs only from grease-lubricated stave bearings and only when the ship
is moving and the rudder is in use. When the ship is first constructed or when the bearings are
overhauled, approximately 2 pounds of grease are used for the entire bearing.1 During the
required, biweekly lubrication of these bearings, the grease is topped-off to replenish the amount
lost while cruising at sea and, therefore, less than 2 pounds are used. Specifications for MIL-G-
24139 grease require that no more than 5 percent of the grease may wash out when tested in
accordance with the ASTM D-1264 method. It was estimated that for every two weeks underway
(in accordance with the biweekly maintenance requirement), 5 percent of the grease is washed
out and is subsequently replenished. Therefore, a maximum of 0.1 pounds of grease (5% of 2
Ibs.) are estimated to be washed out every two weeks underway.

Since the release of grease only occurs through erosion while the ship is moving through
the water, discharges of grease are not expected in port. The 0.1-pound biweekly washout
estimate can be used to calculate the grease washed out per transit. Based on vessel monitoring
data, each vessel, on average, makes 24 transits a year within the 12 n.m. zone.8 Each round trip
i
Rudder Bearing Lubrication
6
-------
transit (including inbound and outbound transits) lasts approximately 8 hours (0.024 weeks).
Therefore, on each transit, 0.0024 pounds of grease could be discharged (i.e. 0.1 pounds per
week multiplied by 0.024 weeks). Fleetwide, for the 56 vessels that have stave bearings, the
mass loading would be 3.23 pounds (0.0024 pounds per transit x 24 transits per vessel x 56
vessels) within the 12 n.m. zone.

4.2 Environmental Concentrations

4.2.1 Lubricating Oil

At Sea. An estimate was made of the amount of water swept by an AOE 1 Class ship
while in transit. Any rudder bearing oil leaking while underway will be churned into this volume
by the propellers. An AOE 1 Class ship is 107 feet wide. For a draft (depth of ship bottom) of
39 feet and a length of 12 n.m. (72,960 feet), the total volume of water swept is
(107)(39)(72,960) = 304 million cubic feet or 8 billion liters. Therefore, on each transit through
the 12 n.m. zone, for each AOE 1 Class ship, one-sixth of a gallon of oil (i.e., 630 mL) is
released in 8 billion liters of seawater. Using a specific gravity of 0.89 for oil (MSDS for
2190TEP), this translates into a maximum estimated concentration of 7 x 10"5 milligrams per
liter (mg/L).

A similar estimate can be made for an AS 36/39 Class ship that is 85 feet wide. For a
draft of 25.5 feet and a length of 12 n.m. (72,960 feet), the total volume of water swept is
(85)(25.5)(72,960) = 158 million cubic feet or 4.5 billion liters. Therefore, on each transit
through the 12 n.m. zone, for each AS 36/39 Class ship, one-sixth of a gallon of oil (i.e., 630 mL)
is released in 4.5 billion liters of seawater. This translates into a maximum estimated
concentration of 1.2 x 10"4 mg/L.

MSC ships with oil-lubricated rudder bearings (T-AE 26 and T-AFS 1 Classes) have an
average width of 80 feet and an average draft of 26 feet. Therefore, as calculated above for the
Navy ships, the oil concentration resulting from these ships would be approximately 1.3 x 10"4
mg/L.

In Port. While in port the ship is stationary. Any oil that leaks from the rudder bearings
will be mixed continuously with the water surrounding the rudder stock at the stern of the ship.
The leakage of oil will be continuous over the day, so if the maximum allowable release of one
pint daily (.125 gallons) were divided by l440 minutes per day, the discharge rate would be 8.68
x 10"5 gallons per minute. It is assumed that local currents will displace 5 cubic feet of water
(37.4 gallons) from the area around the rudder stock at least once per minute. Calculating the
concentration of oil within the volume displaced during one minute yields a local concentration
of about 2.1 mg/L.

4.2.2 Grease

Because grease-lubricated stave bearings are installed in several vessel classes, a vessel
width of 80 feet and a draft of 25 feet were assumed in the calculations. Following calculations
Rudder Bearing Lubrication
7
-------
similar to the ones in Section 4.2.1, the total volume of water swept would be 255 million cubic
feet or 7 billion liters. As calculated in Section 4.1, a maximum of 0.0024 pounds (or 1.1 grams)
of grease is released during each trip. This translates into a concentration of 1.6 x 10"10 mg/L.
r I
Based on the environmental concentrations estimated in Sections 4.2.1 and 4.2.2 above, a
high estimate of the oil and grease concentration in the surrounding water would be 1.3 x 10"4
mg/L at sea, and 2.1 mg/L in port. These concentrations do not exceed federal discharge
standards or the most stringent state water quality criteria, as shown in Table 5.
-, I'
4.3 Potential for Introducing Non-Indigenous Species
, . !
There is no potential for the transport of non-indigenous species since seawater is not
talcen aboard or discharged.
5.0 CONCLUSIONS

The rudder bearing lubrication discharge has a low potential for causing an adverse
environmental effect because the concentrations of oil and grease in the environment from rudder
bearing lubrication while the ship is within the 12 n.m. zone are below relevant federal discharge
standards and state water quality criteria.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources were obtained. Process
information and assumptions were used to estimate the rate of discharge. Based on this estimate
and on the reported concentrations of oil and grease components, the concentrations of oil and
grease in the environment resulting from this discharge were then estimated. Table 6 lists the
data sources used to develop this NOD report.
, I ' l: I ' •'",
Specific References
ij
1. UNDS Equipment Expert Meeting Minutes. Rudder Bearing Lubrication Leakage.
September 26,1996.
'.i i,i , , ii
2. UNDS Round 2 Equipment Expert Meeting Minutes. Rudder Bearing Lubrication
Leakage. March 6,1997.

3. Personal communication between Penny Weersing (MSC) and David Eaton (MR&S) concerning
Action Item RT1. April 16,1997.
o

4. Personal communication between Rich Machinsky (MSC) and Dick Soule (MR&S).
April 9,1998.
Rudder Bearing Lubrication
8
-------
5. Personal communication between LT Joyce Aivalotis (USCG) and David Eaton (MR&S).
May 2,1997.

6. Report of April 1997 Trip to USCG, Baltimore to Research Rudder Bearings on USCG
Small Boats and Craft. January 13,1998.

7. Patty's Industrial Hygiene & Toxicology, 3rd Ed., Volume 2B. 1981. John Wiley &
Sons, New York, pp 3369, 3397.

8. Pentagon Ship Movement Data for Years 1991-1995. March 4,1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
Rudder Bearing Lubrication
9
-------
Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
i, ' 'I;
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.
I

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
'!
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Rudder Bearing Lubrication
10
.llliliiil j. i..i,i,r iilililiiliil- iiillli, I..
! ,jjt .• ic..!.;:.!.-!!!.;!
-------
STERN
WATERLJNE
SEALS
—<^ 7* " '|- ROU
\ ^^Li i *~~HFu
Figure 1. Rudder Grease-Lubricated Roller Bearings Generic Sketch
Rudder Bearing Lubrication
11
-------
STERN
WATERUNE
SEALS-
Figure 2. Rudder Oil-Lubricated Roller Bearings Generic Sketch
Rudder Bearing Lubrication
12
-------
LIFTING RING

•TILLER

CARRIER ASSEMBLY FOUNDATION
K BEARING (STAVES)
BUSHING (TYP)
iREASE SUPPLY TO NECK SEARING
RUDDER STOCK
•SANO EXCLUDER
ICKEL-COPPER CLAD SEE NOTES tttf)
•RUOOER STOCK KEY

WATERTIGHT CLOSURE PLATE {7YPJ
RUOOER STOCK
i PINTLE

RUDDFR A ^TOCK PI FVATION
Figure 3. Rudder Stave Bearings (Example)
Rudder Bearing Lubrication
13
-------
Table 1. Navy Ships - Lower Rudder Bearing Type and Lubrication Method
Ship Class
AGF3
AGF11
AO177
AOE1
AOE6
ARS50
AS 36/39
ATS1
CG47
CGN36
CGN40
CV62
CV63
CV67
CVN65
CVN68
DD963
DDG51
DD993
FFG7
LCC19
LHA1
LHD1
LPD4
LPH2
LSD 36
LSD 41
MCM1
MCS12

Lower Rudder Bearing &
Type of Lubrication
Stave Brg., Grease
Stave Bra., Grease
Roller Bra., Grease
Roller Bra., Oil/Grease
Stave Bra., Grease
Stave Bra., Grease
Roller Bra., Oil
Stave Bra., Grease
Roller Bra., Grease
Stave Bra., Water
Stave Bra., Water
Stave Bra., Water
Stave Bra., Water
Stave Bra., Water
Stave Bra., Water
Stave Bra., Water
Roller Bra., Grease
Roller Bra.. Grease
Roller Bra-, Grease
Roller Bra-, Grease
Stave Bra., Grease
Roller Bra., Grease
Roller Bra., Grease
Stave Bra., Grease
Stave Bra., Grease
Stave Bra., Grease
Stave Bra., Grease
Stave Bra., Grease
Stave Bra., Grease

# in Class
1
1
13
2/2
3
4
3
3
27
2
1
1
2
1
1
7
31
18
4
43
2
5
4
9
2
5
11
14
1

223
Rudder Bearing Lubrication
14
-------
Table 2. U.S. Coast Guard Cutters, Types of Bearing, and Lubrication
Cutter Class
399 WAGB
378WHEC
270WMEC
210WMEC
140 WTGB
No. in Class "'
2
12
13
16
9
, Type of Bearing
Laminated Phenolic Staves
Micarta Bushing
Bushings
Micarta Bushing
Staves
Lubrication
Grease
Flax Packing/Grease
Grease/Water
Grease
Water
Note: There is no information available on the following classes:

225 WLB New production
175 WLM New production
180 WLB Decommissioned by 2001
157 WLM Decommissioned by 2000
133 WLM Decommissioned by 2000
160 WLIC No information
Rudder Bearing Lubrication
15
-------
Table 3. U.S. Coast Guard Small Boats and Craft
(Types of Bearings and Lubrication)
V ".''>!"' ''•
.Vsssef&raft
26* MSB
32' PWB
44' MLB
-------
Table 4. Military Sealift Command Ships
(Type of Rudder Bearings and Lubrication)
SHIP CLASS/NAME -.

T-AE 267 USNS KILAUEA
T-AFS1/USNSMARS
T-AG 1.94/
USNS VANGUARD
T-AGM 227
USNS RANGE SENTINEL
T-AGOS 217 USNS
EFFECTIVE
T-AGS45/USNS
WATERS
T-AGS60/USNS
PATHFINDER
T-AH 197 USNS MERCY
T-AO 1877
USNS HENRY J.
KAISER
T-ARC 77
USNS ZEUS
T-ATF 1667
USNSPOWHATAN
> AJHT
-
319010122
319010106

M319010192
N.A

- BEARING TYPE/LUBRICATION
,
UPPER & LOWER
RUDOER STOCK
ROLLER BEARING/
OIL
ROLLER
BEARING/OIL

AEROSHELL
GREASE 6SG6127
70026
ROLLER/GREASE
N.A

ROLLER/GREASE

PINTLE
BEARING
STAVE/
WATER

STAVE/
WATER
N.A

ALLOWABLE SEAL LEAKAGE
WATER OR OIL

1 PINT/DAY IN PORT/ANCHOR.
1 GALLON/DAY UNDERWAY

1 PINT/DAY IN PORT/ANCHOR.
1 QUART/DAY FOR ALL
OPERATING CONDITIONS
1 PINT/DAY IN PORT /ANCHOR.
1 GAL/DAY FOR ALL
OPERATING CONDITIONS.
N.A.

1 PINT/DAY IN PORT/ANCHOR. 1
QUART/DAY FOR ALL
OPERATING CONDITIONS

'REMARKS " f
. ~ - ' .
RUDDER POST HAS NEW
JOHN CRANE SPLIT SEAL
INSTALLED DURING YARD
PERIOD

NO DATA AVAILABLE
NO DATA AVAILABLE

THIS CLASS HAS "ZEE"
DRIVES. THERE ARE NO
RUDDERS.
NO DATA AVAILABLE

NO DATA AVAILABLE
NO DATA AVAILABLE
The blank spaces in the table indicate that information is not available.
Rudder Bearing Lubrication
17
-------
1 "r ,i!!":iii|i'>'ii!"i"!j 'iinniii, • i"if|i, if,, I"
Table 5. Comparison of Environmental Concentration with Relevant Water Quality
Criteria (mg/L)
Constituent
oil and grease
Concentration
1.3 x Iff4 (at sea)
2.1 (in port)
Federal Discharge
Standard
visible sheena/15b
Most Stringent State Water
Quality Criteria
5.0 (FL)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)

NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
33 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
Data Source
Reported

UNDS Database

X
X

Sampling

Estimated

X
X
X
Equipment Expert
X
X
X
X

X
X

X
Rudder Bearing Lubrication
18
-------
NATURE OF DISCHARGE REPORT
<~ 'Seonvater Cooling Overboard Discharge
1.0 INTRODUCTION

2.1 Equipment Description and Operation
ii

Seawater cooling systems on surface ships and submarines provide cooling water for heat
exchangers, removing heat from the propulsion plant and mechanical auxiliary systems. Heat
exchangers are provided for steam, diesel, and gas turbine propulsion plants and electric
generating plants; air-conditioning (A/C) plants; air compressors; and electronic equipment.
Seawater is provided to steam propulsion plants for the purpose of condensing exhausted steam
from propulsion or electric generator turbines before the condensate is cycled back to boilers or
steam generators.

Seawater cooling systems draw seawater either directly from hull connections (sea
chests), or indirectly from the firemain that is supplied directly from a hull connection. The
seawater is pumped through heat exchangers where it absorbs heat and is then discharged
overboard at a higher temperature. At sea, the demands for seawater cooling are higher than
piefSide or at anchor because systems requiring seawater cooling tend to be in use and at a higher
power output level while underway. Even while pierside, however, the demands for cooling of
auxiliary systems may be significant. Conventional steam vessels were estimated to have a 24-
hour start-up and securing cycle and nuclear vessels a 48-hour start-up and securing cycle.1

Typically, the demand for cooling water is continuous. The residence time of seawater in
seawater cooling systems is relatively short, perhaps a minute or two for most portions of the
cooling system. Some branch piping, however, may have relatively long residence times due to
inactivity of equipment.2
! 'i '•' . I
Seawater cooling systems are designed to minimize flow-induced erosion of the piping
system. The piping systems, where possible, have geometry (e.g., increase turn or elbow radii) or
sizing to minimize turbulent flow. The materials of construction (e.g., copper, nickel, and
titanium) are selected because of their resistance to seawater corrosion. Sea chests, heat
exchangers, and other components could also contain sacrificial material such as waster pieces or
zinc anodes to protect the system from corrosion.

Many boats and craft such as utility landing craft and rigid inflatable boats use keel
coolers or stern flushing tubes.1 Keel coolers use ship's motion to pass water over exposed heat
transfer coils ig a recessed area of the boat keel. Stern flushing tubes are simple cooling systems
in which engine cooling water is drawn from a hull connection and is discharged from the
vessel's stem, normally above the water line.
Seawater Cooling Overboard Discharge
2
-------
Sea chests and hull connections are equipped with sea strainer plates to prevent debris
from entering the seawater cooling system (especially when in port or in coastal waters) and
causing failures due to clogging.3 The openings hi these strainer plates vary in diameter from 1/4
inch to 1-1/2 niches and require periodic blowdowns to prevent clogging. This is accomplished
by blowing low-pressure air or steam out through the plates.3

Some vessels add biofouling prevention chemicals to the seawater.1'4 The contribution of
anti-fouling additives to seawater cooling overboard discharge is addressed hi the Seawater
Piping Biofouling Prevention NOD report and will not be considered in this report.

hi addition to seawater cooling while pierside, Navy vessels with non-conventional steam
propulsion also fill their main steam condenser heat exchangers with fresh water if the vessel is
going to be in port for an extended period. When vessels are in port for an extended period of
tune, they often deactivate their propulsion plants. During these periods, the main condenser is
filled with fresh water because fresh water inhibits biofouling.1 Freshwater layups for non-
conventional main steam condenser heat exchangers are discussed in the Freshwater Layup NOD
report.

2.2 Releases to the Environment

The releases to the environment consist of the seawater discharged overboard from the
seawater cooling system with entrained or dissolved materials from the components of the
seawater cooling system and bottom sediments that are brought onboard through the sea chest.
The components of the seawater cooling system include: the sea chest, pumps, heat exchangers,
pipes, fittings, and valves. The sea chests are constructed of steel and are painted with high
durable epoxy paints, and they also contain steel or zinc sacrificial material.1 The pumps are
constructed of titanium, stainless steel, nickel alloys, bronze, and non-metallic composites.1 Heat
exchangers are copper-nickel alloys or titanium.1 The pipes and fittings in seawater systems are
primarily copper-nickel alloys, but fittings may also be bronze with silver-brazed joints.1 Valves
are constructed of bronze, nickel alloys, or aluminum alloys.1 Some traces of hydraulic oil or
other lubricants may enter the seawater from remotely operated valves or pumps. The metals that
may enter the seawater include copper, nickel, lead, aluminum, tin, silver, iron, titanium,
chromium, and zinc.

hi addition, the discharge constitutes a thermal load. The maximum discharge
temperature is 140 degrees Fahrenheit (°F) to prevent formation of soft scale (calcium carbonate)
inside the pipes and heat exchangers.1 The difference in temperature from influent to effluent is
usually between 10 °F to 15 °F, but the range can be as much as 5 °F to 25 °F.5

Sea strainer plate blowdown consists of air or steam, and any solids blown off the strainer
plate. Air bubbles rise to the surface and dissipate, while the solids fall to the bottom. Solids can
include anything that has been held against the plate by the cooling water suction (e.g., debris and
mud) plus biota that has grown on the plate over time (e.g., sea grass and slime).

2.3 Vessels Producing the Discharge
Seawater Cooling Overboard Discharge
3
-------
Ships, boats, and craft in the Navy, Military Sealift Command (MSC), U.S. Coast Guard
(USCG), Army, and Air Force with the exception of some non-self propelled service craft such
as barges, use seawater for cooling. Of the over 6,000 ships, boats, and craft in the Armed
Forces, the vast majority of these vessels (over 5,000) consists of boats and craft. The majority
of the seawater cooling overboard discharge, however, is generated by larger ships and vessels
that have large, continuous seawater cooling demands. There are 673 such surface ships and
submarines. The boats and craft in service use either intermittent cooling water or have keel
coolers where there is no flow through the vessel. Table 1 lists the vessels that contribute to this
discharge and the estimates for the number of transits, number of days in port, and number of
days operating within 12 nautical miles (n.m.) by each ship class each year.
characterizes the
harbors and near-
ihe constituents in
in the discharge.
3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that
discharge. Section 3.1 describes where the discharge occurs with respect to
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists
the discharge, and Section 3.4 gives the concentrations of the constituents i

3.1 Locality

This discharge occurs both within and beyond 12 n.m. of shore.

3.2 Rate

Seawater cooling flow rates can vary from several gallons per minute (gpm) for smaller,
diesel-powered ships to flows of greater than 170,000 gpm for aircraft carriers during full-power
steaming. While transiting, vessels tend to operate at levels sufficient to maintain steering
control and do not require the maximum amount of seawater cooling. While anchored or
pierside, seawater cooling flow rates are at their lowest because only certain auxiliary equipment
is required. Table 2 lists examples of typical pierside and transit steaming flow rates for vessel
classes.6
I,
Tables 3a, 3b, and 3c provide estimates of discharge flow rates for various ship classes
within 12 n.m. of shore based on available data. The number of transits were used to estimate
the number of light-off and securing cycles for steam-powered vessels. The calculations use a
typical transit time of 4 hours between 0 to 12 n.m.7 For USCG vessels, operation within 12 n.m.
of shore includes seawater cooling flow rates at pierside rates for 16 hours each day with the
remaining 8 hours at typical underway flow rates. An example for the estimated annual flow of
the WAGE 399 Class for operation within 12 n.m. of shore is calculated by the equation:
Seawater Cooling Overboard Discharge
4
-------
Estimated Annual Flows (gal), Operating Within 12 n.m. ,
:iQty)(6peratingfime)(60) [(16Y24)(]PiersideFlow) + (8/24)(Operating Flow)]

WAGE 399 Annual Flow (gal), Operating Within 12 num. ,
=~(2)(2400 hrs)(60 min/hr) [(16?24)(800 gal/rain)^ (8/24)(4000)] . ,,
:\ ' : "" < -537,600,000gal - *
Based on these estimates, the total annual flow of seawater cooling overboard discharge
from Navy, MSC, Army, and USCG vessels is estimated as 390 billion gallons. Flow rates for
Air Force vessels are not estimated.

3.3 Constituents

Seawater cooling overboard discharge is primarily seawater that contains trace materials
from seawater cooling system pipes, fittings, valves, seachests, pumps, and heat exchangers. The
expected constituents of seawater cooling discharge include copper, iron, aluminum, zinc, nickel,
tin, titanium, arsenic, manganese, chromium, lead, and possibly oil and grease from valves and
pumps. Of the constituents expected to be present in this discharge, arsenic, chromium, copper,
lead, nickel, and zinc are priority pollutants. None of the expected constituents is a
bioaccumulator.

The constituents from strainer plate blowdown include the material ejected from the
strainer plate, such as biota, mud, or debris, trapped from the sea or harbor waters.

3.4 Concentrations

Influent and effluent samples were collected from the seawater cooling systems of five
ships.8 A summary of the analytical results are presented in Table 4. This table shows the
constituents, the log-normal mean, the frequency of detection for each constituent, the minimum
and maximum concentrations, and the mass loadings of each constituent. For the purposes of
calculating the log-normal mean, a value of one-half the detection limit was used for non-
detected results.

The analytical data for a Coast Guard vessel were not used to calculate the log-normal
mean concentrations hi Table 4 because the data indicated a large average net decrease in effluent
concentrations for total copper, nickel, tin, and zinc. For example, data for this vessel varied
widely for total copper with an average influent concentration of 1,450 ug/L and an average
effluent concentration of 419 ug/L, a net decrease of 1,031 ug/L. These concentrations are one to
two orders of magnitude higher than data from the other ships. The Coast Guard vessel data
were considered an anomaly and were excluded from log-normal mean concentration
calculations to avoid biasing the data with large, negative net concentrations.

Variability is expected within this discharge as a result of several factors including
material erosion and corrosion, residence times, passive films, and influent water variability.
Pipe erosion is caused by high fluid velocity, or by abrasive particles entrained in the seawater
Seawater Cooling Overboard Discharge
5
-------
I II I ll
flowing at any velocity. In most cases of pipe erosion, the problematic high fluid velocity is a
local phenomenon, such as would be caused by eddy turbulence at joints, bends, reducers,
attached mollusks, or tortuous flow paths in valves. Passive films inhibit metal loss due to
erosion. Corrosion is influenced by the residence time of seawater in the system, temperature,
biofouling, constituents in the influent, and the presence or absence of certain films on the pipe
surface. All of these influences on metallic concentrations are variable within a given ship over
time, and between ships.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria.
Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of non-
indigenous species is discussed.

4.1 Mass Loadings

Based on the discharge volume estimates developed in Tables 3a, 3b and 3c and the log-
normal mean discharge concentrations and mass loadings are presented in Table 4. Table 5 is
present in order to highlight constituents with log-normal mean concentrations that exceed water
quality criteria (WQC). A sample calculation of the estimated annual mass loading for copper is
shown here:
Mass Loading for Copper (Total)
Mass toacling=(Net Positive Log-normal Mean Concentration)(Flow Rate)
(34.49 |ig/LX3.785L/galX390,000,000,000 gal/yr)(2.202 lbs/kg)(10'9 kg4tg) & 112,100 Ibs/yr
4.2 Environmental Concentrations
a • ' • h
The log-normal mean discharge concentrations are compared to the Federal and most
stringent state WQC in Table 6. Copper exceeds the Federal and most stringent state WQC.
This can be attributed to two factors: 1) the copper concentrations of many harbors exceed the
standard, and 2) other copper sources (e.g. copper hull coatings) of the vessel are located near the
influent sea qhest. Between 1 and 90 ng/L of copper naturally occurs in seawater.9 Nickel and
silver concentrations also exceed the Federal and most stringent state WQC. Nitrogen (as
ammonia, nitrate/nitrite, and total kjeldahl nitrogen) exceeds the most stringent state WQC.

4.3 Thermal Effects

The potential for seawater cooling overboard discharge to cause thermal environmental
effects was evaluated by modeling the thermal plume generated under conditions tending to
produce the greatest temperature rise and then compared to state plume thermal discharge
i
Seawater Cooling Overboard Discharge
6
-------
requirements. Thermal effects of seawater cooling water overboard discharge were modeled
using the Cornell Mixing Zone Expert System (CORMTX) to estimate the plume size and
temperature gradients in the receiving water body. Thermal modeling was performed for three
ships in three harbors (Mayport, FL; Norfolk, VA; and Bremerton, WA) to assess the potential
thermal impact. The discharge was also assumed to occur during winter when the ambient water
temperatures are lowest. Based on these models, Navy aircraft carriers are predicted to generate
thermal plumes that, under conditions of low harbor flushing, low wind velocities, and maximum
cooling water flow rates, would exceed the regulatory limits of Washington.5 Thermal plumes
from models of smaller ships (destroyers) do not exceed regulatory limits.5 Of the five states
having a substantial presence of Armed Forces' vessels, only Virginia and Washington have
established thermal mixing zone dimensions.

4.4 Potential for Introducing Non-Indigenous Species

The seawater cooling water system has a minimal potential for transporting non-
indigenous species, because the residence times for most portions of the system are short. Some
portions of the seawater system lie stagnant where marine organisms may reside. However, these
areas tend to develop anaerobic conditions quickly, except at the junctions with the active
portions of the system, where oxygenated water continuously flows by and through the ship. The
seawater is not a system where large volumes of water, under aerobic conditions, are transported
over distances.

A small potential exists for transport of non-indigenous species because the blowdown
procedure for the strainer plates may dislodge biota that has grown on the plate over time.
5.0 CONCLUSION

Seawater cooling overboard discharge has a potential to cause an adverse environmental
effect because:

1) Nitrogen, copper, nickel, and silver concentrations in the discharge exceed Federal
and the most stringent state water quality criteria, and the mass loadings of nitrogen,
copper, nickel, and silver are significant; and

2) Some vessels could exceed some states' thermal mixing zone requirements while in
port.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. System
engineering information was used to estimate the rate of discharge. Table 7 shows the sources of
data used to develop this NOD report.
Seawater Cooling Overboard Discharge
7
-------
Specific References
"!"l,, • "•• " •• I
1. UNDS Equipment Expert Meeting Minutes. Seawater Cooling Water Overboard. 27
August 1996.

-------
Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13, 1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. 23 March 1995.

UNDS Ship Database, August 1,1997.
Seawater Cooling Overboard Discharge
9
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Table 2. Seawater Cooling Flow Rates, Examples (Naval Vessels)
Vessel Class
Aircraft carriers (CVN 68)
Cruisers (CG 47)
Destroyers (DDG 51)
Frigates (FFG 7)
Amphibious assault ships (LHD 1)
Submarines
Pierside (gpm)
4,100
1,650
1,500
1,750
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2,000
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>170,000
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6,840
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up to 40,500
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13
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1 Total Suspend
Solids
'ea'

v^
p
N
O
m
c
>e
r^
o
a
o

—
2
Volatile Resid

-5
'~'

t
"Sb
i

ij
i

,-^
e
c

"i
g
r>
s

>
vd
s
VO
TT
£
O
s
VO
_1
a
DO
g
"n
CM
O
O

4-Chloro-3-
1 Methylphenol
5>g S
S -s
8 «
e OT
o «
i-t 1-1
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.§ 3 "2
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-------
Table 5. Estimated Annual Mass Loadings of Constituents
Constituent*
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen^
Copper
Dissolved
Total
Nickel
Dissolved
Total
Silver
Total
Log-normal Mean
Influent (ng/L)
100
60
580

9.86
14.88

~
~

• ~
Log-normal Mean
Effluent (HR/L)
120
80
680

40.6
49.37

15.4
19.6

2.77
Log-normal Mean
Concentration (ng/L)
20
20
100

30.7
34.49

15.4
19.6

2.77
Estimated Annual
Mass Loading (Ibs/yr)
65,010
65,010
325,048
390,058

99,700
112,100

50,100
63,700

9,000
' Mass loadings are presented for constituents that exceed ambient WQC and for bioaccumulators only. See Table 4
for a complete listing of mass loadings.
A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Seawater Cooling Overboard Discharge
21
-------
ti " •••',' III1'.
Table 6. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituents
Classicals (ug/L)
Ammonia as
Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen®
Metals (ug/L)
Copper
Dissolved
Total
Nickel
Dissolved
Total
Silver
Total
Log-normal
Mean
Effluent

20
80
680
760

40.55
49.37

15.4
19.6

2.77
Minimum
Concentration
Effluent

BDL
BDL
340

11.90
7.55

BDL
BDL

BDL
Maximum
Concentration
Effluent

240
1710
1300

1040.00
1135.00

96.4
95.0

5.90
Federal
Chronic WQC

None
None
None
None

2.4
2.9

8.2
8.3

0.92
Most Stringent State
Chronic WQC

6(HI)A
8 (HI)A
—
200 (HI)A

2.4 (CT, MS)
2.9 (FL, GA)

8.2 (CA, CT)
7.9 (WA)

1.2 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.

CA ^ California
CT « Connecticut
FL = Florida
GAs Georgia
Hi13 Hawaii
MS ** Mississippi
WA s Washington
Seawater Cooling Overboard Discharge
22
;:,„[;,
-------
Table?. Data Sources
i t /
NOD Section
2.1 Equipment Description and -*
Operation / / "'
2.2 Releases to the Environment
23 Vessels Producing the Discharge
S.I Locality
3.2 Rate' /< "
3,3 Constituents
3.4 Concentrations
4,1 Mass Loadings
4.2 Environmental Concentrations " *
4,3TnennalEfifect$
4.4 Potential for Introducing Noo-
Indigenous Species . -'
' ~ ' - Data Source
Reported

UNDS Database

Sampling .

X
X
X

Estimated

Equipment Expert
X
X
X
X
X
X

X
Seawater Cooling Overboard Discharge
23
_
-------
-------
NATURE OF DISCHARGE REPORT
Seawater Piping Biofouling Prevention
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed in three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)~either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

2.1 Equipment Description and Operation

The detrimental effects of marine biofouling on vessel performance have long been
recognized by the Navy. The effects from biofouling are fouled surfaces of shipboard piping,
heat exchangers and other related equipment used to distribute seawater aboard vessels resulting
m flow restrictions and loss of heat transfer efficiency. Seawater cooling systems on vessels are
used to provide cooling water for propulsion plant and auxiliary system heat exchangers. Heat
exchangers remove heat directly from the main propulsion machinery, the electrical generating
plants, air conditioning plants, and directly or indirectly from all other equipment requiring
cooling. Seawater cooling systems draw seawater either directly, via a hull connection (sea
chest), or indirectly, via a seawater header or the firemain that is supplied directly from a hull
connection. The seawater is pumped through heat exchangers where the seawater absorbs heat
and is then discharged overboard.

Preventing biofouling in seawater cooling system heat exchanger tubes is essential for
maintaining peak heat exchanger operation and optimum propulsion plant performance. Marine
biofouling prevention is accomplished on certain vessels with on-board chlorinators that inject
low concentrations of sodium hypochlorite, a chlorine solution, at or near seawater cooling
system intakes. See Figure 1 for a schematic diagram of a typical shipboard chlorinator
treatment system. Chlorinators convert some chloride in seawater into a sodium hypochlorite
solution in an electrolytic cell. The hypochlorite solution from the cell is then piped to the
seawater intake or to junction piping at or near the seawater intake, where it is metered into the
seachest This provides treatment of the seawater prior to passing through the cooling system
piping and components. The chlorine solution inhibits the growth of biofouling organisms or
prevents them from attaching to the interior surfaces of seawater cooling system piping and
components. A sampling connection at the outlet of the heat exchangers allows chlorine
concentration levels to be monitored, and the injection rate to be modified as necessary.
i

In addition to chlorination, Military Sealift Command (MSC) vessels use two other
methods to control biofouling; chemical dosing using an ethyl alcohol based chemical seawater
dispersant, and anodic biofouling control systems.1
i1
Chemical dosing as a means of biofouling control involves the periodic injection of a
proportioned amount of an ethyl alcohol based chemical dispersant into the seawater cooling
system at or near the point of seawater intake, usually a seachest, and is currently used on one
MSC oiler. See Figure 2 for a schematic diagram of a typical shipboard chemical dosing
Seawater Piping Biofouling Prevention
2
-------
treatment system. The means of injection may include a gravity head tank and flowmeter, an
eductor dosing system, or a pump and tank system directed to a seachest. The chemical is
flushed through the system and then discharged with the seawater.

Anodic biofouling control systems are designed for continuous operation. See Figure 3
for a schematic diagram of a typical shipboard anodic biofouling control system. Several
systems are currently in use. Each anodic system works on the same principle: an impressed
current applied to copper anodes accelerates the dissolution of copper ions. The anodes are
usually mounted in the sea chest of the vessel. Copper ions inhibit the propagation of marine life
and prevent biofouling.

2.2 Releases to the Environment

The purpose of chlorinating seawater is to protect the cooling system against biofouling
caused by the attachment of living organisms. A chlorination system generates "free chlorine" in
the form of a solution of sodium hypochlorite. This free chlorine reacts with various materials in
seawater, including living tissue, as described in Section 3.3. Seawater discharged from cooling
systems that are protected from biofouling with chlorine systems can contain residual free
chlorine as well various reaction products resulting from the reaction of the free chlorine with
organic material, ammonia, and bromide ion (see Section 3.3). In seawater, free chlorine and
resulting reaction products are collectively called "chlorine produced oxidants" or CPO.

It is expected that the cooling water discharged from the MSC vessel that chemically
doses its seawater cooling systems will contain the ethyl alcohol based dispersant. For those
MSC vessels with anodic treatment systems, constituents from the copper anodes used are
expected in the discharge.

2.3 Vessels Producing the Discharge

Refer to Table 1 for Navy and MSC vessel discharges. All other Armed Force vessels do
not use seawater piping biofouling control methods or equipment.2'3'4
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Seawater biofouling treatment systems continuously discharge both within and beyond 12
nautical miles (n.m.) of shore as long as seawater cooling systems are in operation.
Seawater Piping Biofouling Prevention
3
-------
3.2 Rate
Table 1 presents estimated flow rates by ship class for pierside and underway
conditions.3'4'5
L i, ; , • ' i
Seawater cooling water flows vary with propulsion plant operating conditions and the
system cooling requirements. There is a greater demand for cooling water when a vessel is
underway because me propulsion plant is operating. However, the time spent underway while
transiting within 12 n.m. is small compared to the time a vessel spends pierside and beyond 12
n.m. While pierside, the demand for seawater cooling is primarily from auxiliary equipment
such as electrical generators, and air conditioning and refrigeration plants.

Anodic bipfouling control systems are manually controlled systems normally pre-set for a
current output of 0.2 amps,6 which results in the generation of approximately 0.237 g copper/hr
based on the following Faraday's Law calculation:
{(0.2 amps) (63.54 g copper/mole) (1 coulomb/amp-sec) (3,600 sec/hr)} /
{(2 equivalents/mole) (96\484 coulomb/equivalent)}
1 t > •* f -4, L '
i ' t i \ * ^
» 0.237 g copper/hr ,^___m__
3.3 Constituents
..' , ; j
Seawater dosed with sodium hypochlorite contains free chlorine in the form of
hypochlorous acid (HOCl) and hypochlorite ion (OC1"). Free chlorine undergoes four important
types of reactions in natural waters: (1) oxidation of reduced materials and subsequent
conversion to chloride ion; (2) reaction with ammonia and organic amines to form chloramines,
collectively called combined chlorine; (3) reaction with bromide to form hypobromous acid
(HOBr) and hypobromite (OBr~), called "free bromine;" and (4) reaction with organics to form
chloro-organics. Free bromine reacts in a manner similar to free chlorine, oxidizing reduced
material or forming bromamines (combined bromine) or bromo-organics. Most common
analytical methods for quantifying chlorine in water measure the sum of all free and combined
chlorine and bromine in solution, but do not measure the chloro- and bromo-organics. The
results of such measurements in seawater are reported as CPO. The Navy injects enough free
chlorine to meet the chlorine demand, and ensure that there is sufficient excess CPO throughout
the system to protect against biofouling.

Seawater treated with the chemical seawater dispersant contains primarily ethyl alcohol
and ammonium chloride. Other constituents of this dispersant are unknown.1

For those MSC vessels with installed anodic biofouling control systems, components of
copper ions are expected hi the discharge.

Copper is the only priority pollutant hi this discharge. There are no known
bioaccumulators in this discharge.

Seawater Piping Biofouling Prevention
4
.ill!
-------
3.4 Concentrations

On submarines, sodium hypochlorite solution containing hypochlorous acid and
hypochlorite ion is injected continuously into seawater piping systems to maintain a CPO
concentration of 100 ng/L at a sampling point within the system (i.e. before the point of
discharge from the submarine). The actual CPO concentration at the point of discharge from the
submarine is not measured. However, based on monitoring during initial system setup and
system design data, the CPO concentration in seawater cooling overboard discharge is lower than
the 100 ug/L concentration at the sample point. The concentrations of CPO discharged from
MSC vessels are assumed to be similar to the concentrations discharged from submarines (i.e.,
100 fig/L) because there are no available chlorine discharge data for MSC vessels.

Every three days, over the course of one hour, twelve liters of the chemical dosing
seawater dispersant is metered into a 9,200 gallons per minute (gpm) cooling water system
aboard one MSC oiler.1 Assuming all of the chemical added is also discharged, based on this
ratio, a concentration of approximately 6 mg/L in the discharge would result. The ethyl alcohol
based dispersant is expected to degrade rapidly and to be less than 6 mg/L after mixing with the
receiving waters.

Copper ion emission concentrations resulting from the use of anodic biofouling control
systems is dependent on the current (amperage) output and the seawater flow rate. The current
output is manually set (0.2 amps typically) and is not adjusted when seawater pumps are put on
or taken offline which changes the seawater flow rate. For a flow rate of 1,000 gal/min and
current output of 0.2 amps, the resultant concentration will be 1.04 |ag/L based on the unit
conversion calculation below:

Concentration = (masscopper)/(volumewater) , - "". l s
mass copper = 0,237 g/hr *" , ;>
volume water - 1,000 gal/min (3.785 L/gal) (60 rrun/hr) = 2.27 x 10s L/hr'
concentration = (0.237 g/hr) / (2.27 x IQ^L/hr) fa 1.04 x W~*'g/t = 1 MusTL_ ' ^

A flow rate of 1,000 gal/min, was used for this sample calculation only. 1,000 gal/min is a round
number and close to the flow rate of many fire pumps. Similar calculations can be performed for
other flow rates, with the resultant concentrations presented in Table 1.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality standards. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.
Seawater Piping Biofouling Prevention
5
-------
"II
4.1 Mass Loadings

Mass loadings were calculated in Table 2 based on ship movement data and the flow rates of
seawater estimated from Table 1.7 Calculations in Table 2 assumed that a chlorine concentration
of 100 yg/L is continuously present in the seawater discharge. Most common analytical methods
for quantifying chlorine in water measure the sum of all free and combined chlorine and bromine
in solution. The results of such measurements in seawater are reported as CPO. The Navy
injects enough "free chlorine" to meet the chlorine demand, and ensure that there is sufficient
excess CPO throughout the system to protect against biofouling. The total estimated mass
loadings for chlorine as CPO in Table 2 were calculated to be 2,538 pounds per year. The
following is a sample calculation for the SSN 688 at pierside:
C12 Mass Loading
=(0.1 mg/L)(1.41xl08 gal/yr)(3.7854 L/gal)(2.2 lb/kg)(l kg/lxIO6 mg)
=117tb/yr
concentration
Flow; .rate
Conversion gals to liters
Conversion kg to Ib
Conversion mg to kg
C12 Mass Loading
=0.1 mg/L (Mean concentration)
=2.21b/kg
=lkg/lxl06mg
=1171b/yr
i . i
The dispersant dosing treatment system injects 12 liters of dispersant 26 times per year.1
At a weight of 8.23 pounds per gallon (Ib/gal), a total of 678 pounds (82 gallons) of the
dispersant are added to over 1.033 billion gallons of seawater cooling water while in port. It was
assumed that with only 48 hours of transit time annually (with an average of 4 hours per transit),
dispersant dosing evolutions would not take place during transit.
Dispersant Mass Loading =
Injections per year
Amount Injected
Conversion gals to Ib
Conversion liters to gal
Dispersant Mass Loading
(26 mj/yr)(12 L)(8.23 lb/gal&2642 gal/liters)
678 Ib/yr
•' • • f
(78 days in port^/O&iject every 3 days) = 26 mj/yr
12 liters per injection
8.231b/gal
.2642 gal/liters
6781b/yr
For the 19 MSC vessels with anodic biofouling control systems, using the copper
discharge rate of 0.237 g copper/hr and the estimated annual seawater discharge flow rates from
these vessels (Table 1 and 2), yields a total copper mass loading of 25.0 pounds per year.
4.2 Environmental Concentrations
Table 3 compares the constituent concentrations from Section 3.4 with
most stringent state water quality criteria for CPO and copper. The estimated

Seawater Piping Biofouling Prevention
6
the Federal and
concentrations of

-------
CPO exceed the most stringent state water quality criteria.

Based on monitoring and system design data, CPO levels are estimated to be less than
100 |j,g/L for seawater discharges on submarines. There are no Federal water quality criteria for
chlorine. The most stringent state water quality criteria is 7.5 jag/L. The concentration value of
100 jj,g/L is measured as CPO which is primarily chlorine but can also include a small amount of
bromine.

A computer, model was used that plotted chlorine plumes (using existing and planned
chlorine discharge levels) from various vessels in Mayport, Florida. Mayport is the smallest of
the five major naval ports. Plume dimensions at critical concentrations (7.5,10, and 13 |ag/L)
were compared with mixing zone limitations enforced by the states of Virginia and Washington.
Virginia and Washington are used because they are the only states with clearly defined mixing
zones. Only the chlorine plume from the MSC vessels did not meet the mixing requirements of
the selected states. This plume spread out during the later stages of mixing and exceeded certain
mixing zone width requirements.8 The computer model did not assume expected decay of CPO,
which would result in smaller mixing zones.

4.3 Potential for Introducing Non-indigenous Species

Biofouling prevention systems do not present an opportunity for transport of non-
indigenous species. The anti-biofouling systems are designed to prevent organisms from
attaching to any part of seawater systems so they are discharged directly overboard in the same
geographical area in which they are pulled into the system.
5.0 CONCLUSION

Seawater piping biofouling control discharge has the potential to cause an adverse
environmental effect. For chlorinator biofouling prevention systems, chlorine is discharged in
significant amounts at concentrations expected to exceed ambient state water quality criteria.
The use of anodic biofouling control systems results in the discharge of copper overboard. The
copper concentration being significantly lower than water quality criteria, and the annual mass
loading being very low, the discharges from anodic biofouling control have a low potential for
causing adverse environmental effects.
6.0 DATA SOURCES AND REFERENCES

Table 4 lists the data source of the information presented in each section of this NOD
report.

Specific References

1. Weersing, P., MSC Central Technical Activity, Code N72PC1. Point Paper,

Seawater Piping Biofouling Prevention
7
-------
"Supplemental Information About Chlorinators and Other Anti-Fouling Systems for
Seawater Systems On MSC Ships," December 20,1996.

2. Aivalotis, J., USCG, Personal communication with David Eaton, M. Rosenblatt & Son.
April 25,1997.
i
3. Kurz, Richard J., SEA 92T251. Equipment Expert Meeting Structured Questions,
"Seawater System Chlorination with Dechlorination," September 5,1996.

4. UNDS Equipment Expert Meeting (October 2,1996) Minutes.
Chlorinator/Dechlorinator. October 11,1996.
.". ' . !|
5. UNDS Round Two Equipment Expert Meeting Minutes, Seawater Piping Biofouling
Control Discharge, April 4,1997.

6. Cathelco Limited Information Packet, December 24,1997.

7. Pentagon Ship Movement Data for Years 1991 - 1995, Dated March 4,1997.

8. Malcolm Pimie Inc., "Environmental Effects Analysis: Chlorination of Seawater Cooling
Systems for Biofouling Prevention," September 1997.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.
."I . ' 1:
Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302, Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau

Seawater Piping Biofouling Prevention
8
;„ till, lib,;,:!;, : ; .si :> liJilLr •'•! iJIi ::
i; i I,,,:; Hall ml
„ .llilli.li!, Illli 'I I „ ' ,i ,!l,i!l.,ll
!' JdillV il;l|i!!liiliiliili . .ft,.,
-------
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23, 1995.
Seawater Piping Biofouling Prevention
9
-------
o
Figure 1. Chlormation Systems Schematic
Seawater Piping Biofouling Prevention
10
-------
To Head
Exchangers,
Oil Coolers,
Evaporators,
Fire Pumps and
Ancillary
System
Main
Seawater
Cooling Line
Inlet Grid
Seachest
Figure 2. Typical Installation of Chemical Dosing System
Seawater Piping Biofouling Prevention
11
-------
To Heat
Exchangers,
Oil Coolers.
Evaporators,
Fire Pumps and
Anaciliary
Systems
LTTIH
\[ ^ Power In
• .^"^"**
Main Sea Valve
Seawater
Cooling Line
In let Grid
C2000
Electrodes
Seachest
Figure 3. Typical Installation of Anodic Biofouling Control System
Seawater Piping Biofouling Prevention
12
-------

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00
0
o
•
o
o
oj.
oT
o
C5
O

g"
0
cT
o
o
cT
-S
•
0
ts
VO"
o
CO
oo
O

O
o^
vo
oo
vo"
0
o
"o
VO
924,000,000
I
c\

O S

%$
VO
G
VO

^^ o
P
i! -
S3 -a § §
p s
-------
Table 3. Environmental Concentrations and Water Quality Criteria
Constituent
CPO
Copper
_/ Concentration „
* : (vz/L)
100
0.52 - 0.69
'- Federal Chronic *
WQC(^L)
- •
2.4
Most Stringent State
Chronic WQCOig/L)
7.5 (CT, HI, MS, NJ, VA,
WA)
2.4 (CT, MS)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec.
22, 1992 and 60 FR 22230; May 4, 1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.

CT = Connecticut
HI = Hawaii
MS = Mississippi
NJ = New Jersey
VA = Virginia
WA = Washington
Table 4. Data Sources

NOB Section
24 Equipment Description and ,
Operation . " •
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
5.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
"* .- ' Data Source -
Reported

HMDS Database

X
X

Sampling

- Estimated

X
X
X
X
X
X
Equipment Expert
X
X
X
X
X
X

X
Seawater Piping Biofouling Prevention
15
-------
-------
NATURE OF DISCHARGE REPORT
Small Boat Engine Wet Exhaust
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed hi three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipments or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

2.1 Equipment Description and Operation

Small boat engines commonly use seawater to both cool and quiet their exhaust. Seawater
passes through the heat exchanger, gear oil cooler, and aftercooler (if equipped), and is then
injected into the exhaust. When injected, some of the gaseous and solid components of the
exhaust transfer into the cooling water. The cooling water then discharges into the receiving
water. Any cooling water that is not injected into the exhaust is directed overboard.1 For
purposes of this analysis, it was assumed that all cooling water cycled through the engine is
injected into the air exhaust.

Small boats are powered by either inboard or outboard engines. Inboard engines usually
develop greater power than outboards. In addition, inboard engines are generally diesel fueled
while outboard engines typically use gasoline. Inboard and outboard engines can be either two-
or four-stroke. The majority of small boat outboard engines are two-stroke gasoline engines.
The moving parts of gasoline-powered, two-stroke outboard engines are lubricated with oil that
is pre-mixed with gasoline. Thus, the oil is continuously burned with the gasoline. In four-
stroke engines, lubricating oil is circulated and not intentionally introduced into the combustion
chamber.2

A diagram of a typical two-stroke diesel engine air system is included as Figure 1. A
diagram of a typical inboard wet-exhaust system is included as Figure 2. Although engine design
may vary based on boat class, general process flow will be similar for all water-cooled, small
boat engines.
i •
2.2 Releases to the Environment
i
This discharge consists of water injected as a cooling stream into the exhaust system of
small boat engines. Exhaust constituents generated during the operation of the engines can be
transferred to the engines' water cooling streams and discharged as wet exhaust. Inboard engines
usually discharge wet exhaust above the water line. Outboard engines generally discharge their
wet exhaust underwater through the propeller hub.
.' • ' i
23 Vessels Producing the Discharge
i-
There are approximately 3,300 Navy, 1,560 U.S. Coast Guard (USCG), 209 Army, and
1,454 Marine Corps small boats currently using seawater for cooling engine exhaust. Of the total
number of small boats in the military fleet, 3,822 have inboard engines and 2,701 have outboard
Small Boat Engine Wet Exhaust
2
.11, iul'j I !ii.»i!ii •.
JIB;,; ! :,,; L
[I l,liv, tli ,i .111, J,,; ' I
-------
engines.3 Air Force and Military Sealift Command (MSC) small boats have not been included in
this analysis; however, their inclusion does not significantly affect this reports conclusion.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Based on their limited range, all small boats are expected to operate within 12 nautical
miles (n-m.).1

3.2 Rate

Approximately one-third of the small boat fleet is equipped with outboard engines.
Based on engine specifications, outboard engines can discharge up to 20 gallons per minute
(gpm).4 This rate was used as the fleet-wide average for outboard-driven small boats.

Inboard diesel engines generally have a higher discharge rate than outboard engines, and
can discharge up to 100 gpm.5 This estimate assumes that all cooling water flows through the
engine and is discharged into the exhaust. Many small Armed Forces boats have twin engines,
yielding a total flow rate up to 200 gpm per vessel. However, to take into account vessels with
single engine installations, and for vessels with engines discharging less than 100 gpm per
engine, a flow rate of 150 gpm per vessel was used as the average fleet-wide flow rate for boats
with inboard engines.

Table 1 summarizes the estimated annual small boat engine wet exhaust flow rate by
service. Flow rates were calculated for each service based on a monthly average operating time
of 25 hours, and each vessel discharging 150 gpm of wet exhaust for inboards and 20 gpm for
outboards.4'5'6 The total fleet-wide discharge is approximately 11 billion gallons per year.

3.3 Constituents

The main constituents from all engines are oxides of nitrogen (NOX), organic compounds
(including hydrocarbons (HCs)), carbon monoxide (CO), and particulates. The HC constituents
are primarily the result of incomplete combustion. Since diesel fuels have a different
composition than regular gasoline, the distribution of constituents in the exhaust differ between
the two engine types. In general, diesel engines produce higher particulate emissions and lower
organic emissions than gasoline-powered engines.7

3.3.1 Outboard Engines
Small Boat Engine Wet Exhaust
3
-------
As mentioned in Section 2.1, almost all outboard engines are two-stroke gasoline
powered engines. Some limited studies have been done on the impact of engine exhaust on
water quality. A 1995 study measured the rate of introduction of volatile organic compounds
(VOCs) into water during the operation of gasoline powered two-stroke and four-stroke outboard
engines. In this study, a 10-horsepower (hp) outboard engine of each type was operated in an
enclosed tank, and the increase in VOCs such as benzene was measured. The results were given
in terms of miUigram (mg) of compound per 10 minutes (min) of operation (e.g. 2800 mg
benzene/10 min). Therefore, the number was a bulk measurement of the rate of accumulation of
the compound in the water.8

The study reported that the VOC compounds found hi water for both two-stroke and four-
stroke engines were almost exclusively aromatic hydrocarbons. In most cases, other types of
HCs were not found. The amount of VOCs found in the water on a power basis (grams per
horsepower-hour (g/hp-hr) was equivalent to approximately 10% of the total HCs emitted in the
exhaust The VOC compounds measured in the 1995 study and the rate of accumulation are
shown in Table 2.8 Of the compounds listed in Table 2, benzene, toluene, ethylbenzene, and
naphthalene are priority pollutants. No bioaccumulators are suspected to be present in this
discharge.

3.3.2 Inboard Engines
i
1 li ,
To support the air quality management planning process, EPA has published emission
factors for various industrial sources, including stationary diesel engines up to 600 hp. These
emissions factors relate quantities of released materials to fuel input, as nanogram per joule
(ng/J) fuel input, or power output, as hi g/hp-hr. Although intended for stationary diesel engines,
these emission factors may be used to approximate diesel engine emissions for small boats and
craft for the following reasons:

• For diesel engine families with 1994 emissions certification, more than 90 percent
have HC emissions of 0.5 g/hp-hr or less.9 According to the manufacturer's
specification sheet, the HC emissions rate for a typical diesel engine hi use by the
Armed Forces is 0.45 g/hp-hr.5 This demonstrates that the emissions from the
typical diesel engine used by the Armed Forces is similar to industry standard
diesel engines.

• The EPA emission factor for total organic carbon (TOC) emitted by diesel engines
is approximately 1.1 g/hp-hr.7 Because HCs are a subset of TOC, these emissions
rates appear to be appropriate for an order of magnitude estimate.
'; • • ' ! '
il
Table 3 lists the emission factors for constituents present in the air exhaust of diesel
engines.7 Through contact with the cooling water, many of these constituents have the potential
to be introduced into the water. Of the compounds shown hi Table 3, benzene, toluene, acrolein,
naphthalene, acenaphthylene, acenaphthene, fluorene, phenanthrene, anthracene, fluoranthene,
pyrene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene,

Small Boat Engine Wet Exhaust
4
-------
benzo(a)pyrene, indeno(l,2,3-cd)pyrene, dibenzo(a,h)anthracene, and benzo(g,h,i)perylene are
priority pollutants. None of the constituents listed in Table 3 are bioaccumulators.

3.4 Concentrations

3.4.1 Outboard Engines

The 1995 study measured the VOC accumulation in water from the exhaust of 10-hp (7.3
kilowatt (kW)) two-stroke engines. Because the typical two-stroke outboard engine used by the
Armed Forces is a 100 hp (74.6 kW) engine, the results from the 10-hp engine are not directly
transferable. However, one pertinent observation was reported in the 1995 study which permits
the results of the smaller engine to be "scaled" up for a larger engine. This observation was that
the concentration of VOC in the water was related primarily to the level of HC emissions in the
exhaust. The higher the level of HC emissions in the engine air exhaust, the higher the level of
VOC found in the water.8 This indicates that if the level of total HC emissions for a larger
engine can be estimated, the VOC concentrations for the compounds given in the 1995 study can
reasonably be estimated by comparing the total HC emission rates.

In 1996, EPA published a rule regulating the emissions of gasoline-powered marine
engines. The rule gives an equation for HC output which describes the current emission rates of
two-stroke engines for the power output range from 2 hp to 300 hp. This equation is given as:
: HC = [151-K557/P0'9)], or 300 g/kW-hr, whichever is lower.
In this expression, P is the power in kW, and HC is the hydrocarbon emissions rate in
g/kW-hr.10 The relationship between power and emissions is different for 4-stroke and 2-stroke
engines. However, in the absence of a similar equation for 4-stroke engines, it was assumed that
4-stroke engine emissions follow the same trend in emissions output on a normalized basis
(power basis) as two-stroke engines.

Using the typical two-stroke outboard engine size of 100 hp and the EPA equation, the
normalized output for HC is 162.5 g/kW-hr. Therefore, the total emissions rate is approximately
12,122 g/hr. Using the 7.3 kW engine power and the 267 g/kW-hr HC emissions rate reported in
the 1995 study for the two-stroke engine, the total HC emissions rate is 1,949 g/hr. The ratio of
HC emissions for these two engine sizes can be calculated as shown below:
Estimate the hydrocarbon emissions ratio for a 100 hp (74.6 kW) engine
Total emissions rate (7.3 kW engine): = (HC)(P) = (267 g/kW-hr) (7.3 kW) - 1,949 g/hr
Projected'emissions rate (74.6 kW engine): - (HC)(P) = (162.5 g/kW-hr)(74.6 kW) = 12,122 g/hr
Emissions ratio = 12,122/1,949 = 6.2
If it is assumed that there is a direct relationship between the HC emissions rate and the
VOC introduction rate, the rates of VOC introduction measured in the 1995 study can be
multiplied by the HC emissions ratio. Using this approach, Table 4 provides the estimated VOC

Small Boat Engine Wet Exhaust
5
-------
introduction rates for two-stroke outboard engine wet exhaust. An example calculation for
benzene is provided below:
Benzene introduction rate for a 7.3 kW engine is 2800 mg/10 ran (from 1995 study)
Hydrocarbon emissions ratio for a 74.6 kW engine equals 6.2 (from above calculation)
Benzene introduction rate equals (6.2)(2800 mg/10 min) = 17,360 mg/10 min
, " " !,
A similar procedure can be followed to estimate the VOC introduction rate for four-
stroke engines! For these engines, a typical engine size is 90 hp. Again, using the EPA equation,
the normalized output for HC in a 90 hp (67.1 kW) engine is 163.6 g/kW-hr. Therefore, the total
emissions rate is approximately 10,961 g/hr. Using the 7.3 kW engine power and the 267 g/kW-
hr HC emissions rate reported in the 1995 study for the two-stroke engine, the total HC
emissions rate for the two-stroke engine in the 1995 study is 1,949 g/hr. For a 90 hp engine, the
hydrocarbon emissions ratio therefore is 10,961/1,949 or 5.62. Using this ratio, Table 4 shows
the estimated VOC introduction rate for four-stroke outboard engines. A sample calculation for
the introduction rate of benzene is given below:
Benzene introduction rate for a 7.3 kW engine is 110 mg/10 min (from 1995 study)
Hydrocarbon emissions ratio for a 67.1 kW engine equals 5.62 (froiin abovl takulatidn)
Benzene introduction rate equals (5.62)(110 mg/10 min) = 618.2 mgVIO min
To estimate the concentration of the constituents in the wet exhaust, the flow rate must be
used. From Section 3.2, the approximate wet exhaust flow rate for outboard engines is 20 gpm. .
The constituent concentration can be estimated by assuming all the VOCs introduced into the
exhaust enters the water. Table 4 shows the estimated concentrations for the constituents in both
two-stroke and four-stroke outboard engines. A sample calculation is presented below:
Wet Exhaust Flow rate: 20 gpm
Benzene introduction rate: 17,360 mg/10 min
Concentration = (17,360 mg/10 min)(l min/20 gal)(l gal/3.7854 L) = 22.9 mg/L
3.4.2 Inboard Engines
i '.':•• . . |l
The constituent concentrations for the discharge of inboard engines were determined
through a multi-step calculation. Using emission factors for mid-size stationary diesel engines
given hi Table 3 and diesel engine output specifications, the concentrations hi air exhaust were
estimated. The transfer of air exhaust constituents into the water was estimated using Henry's
Law, which relates the partial pressure of a gas hi the atmosphere to the concentration of the gas
hi water. Table 5 provides the estimated constituent concentrations in the inboard engine wet
exhaust. A sample calculation for the concentration of benzene is presented in the calculation
sheet at the end of the report.
4.0 NATURE OF DISCHARGE ANALYSIS
Small Boat Engine Wet Exhaust
6
-------
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality standards. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The estimated mass loadings shown in Table 6 and Table 7 were based on the total
number of small boats in the Navy, USCG, Army, and Marine Corps; on a monthly average
operating time of 25 hours; and each boat discharging 150 gpm of wet exhaust for inboards and
20 gpm for outboards.4'5'6 The concentration data for two-stroke engines were used because the
majority of Armed Forces outboard engines are two-stroke. This approach is conservative
because constituent concentrations hi two-stroke engine wet exhaust are higher than
concentrations in four-stroke engine exhaust.

Mass loading sample calculations:

Table 6? Outboard Engine for benzene is:
(22.93 mg/L)(0.97 billion gallons/yf)(3.785 liters/gallon)(t kg/106 mg)= 84,186 kg/yr
Table 7, Inboard Engine for benzo(a)pyrene is;
(7.69 x IP'5 mg/L)(10>3l billion gallons/vf)(3.785 Uters/gaUon)(I kg/106 mg) = 3.0 kg/yr
4.2 Environmental Concentrations

The concentrations and mass loading estimates described above are likely an overestimate
because of non-equilibrium effects. The method used to estimate the concentrations of the diesel
exhaust components in wet exhaust using Henry's Law assumed sufficient residence time inside
the engine for the aerosols in the exhaust to reach equilibrium with the cooling water. However,
due to the short residence time of both air and water in the exhaust system, equilibrium
conditions are unlikely. Residence tune hi the exhaust system is expected to be less than one
second. Because equilibrium conditions are unlikely, less constituents will dissolve in the
cooling water.

Based on cited research, chemical constituents hi the wet exhaust from small boat engines
can be present at concentrations that exceed water quality criteria (WQC). Table 8 summarizes
estimated discharge concentrations and WQC for constituents of this discharge. Benzene,
toluene, ethylbenzene, and naphthalene in two stroke outboard engines exceed the most stringent
state WQC. Benzene and ethylbenzene in four-stroke outboard engine wet exhaust, and total
PAHs in inboard engine wet exhaust each exceed the most stringent state WQC.

4.3 Non-Indigenous Species
Small Boat Engine Wet Exhaust
7
-------
II •'
The residence time of cooling water in small boat engines is very short; therefore, the wet
exhaust is discharged within yards of where the cooling water was taken aboard. Because
seawater is nqt transported during small boat operations, it is unlikely that the operation of small
boat engines could transport or introduce non-indigenous species.
5.0 CONCLUSIONS
Constituents found in small boat engine wet exhaust discharge are
discharged in significant amounts that exceed water quality criteria. Therefore.
the potential to cause adverse environmental effects.
estimated to be
;, this discharge has
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information, equipment specifications, average annual use, and fleet-wide inventories were
Considered in estimating the rate of discharge. Estimated constituent concentrations were
calculated using solubility principles and published emissions data. Additional constituent
concentrations were obtained from previously completed research. Table 9 shows the sources of
data used to develop this NOD report.
i .
ii
Specific References
,, „ i j
1. UNDS Equipment Expert Meeting Minutes - Small Boat Engine Wet Exhaust. 3
September 1996, M. Rosenblatt and Son, Inc. (MR&S)

2. Davis^ Kip, NSWC. Small Boat Equipment Description and Operation, 10 March 1998,
Doug Hamm, Malcolm Pirnie, Inc.
,; j!
3. UNDS Round 2 Equipment Expert Meeting Minutes - Small Boat Wet Exhaust. 8 April
1997.
• . ' • • I'
4. Outboard Marine Corporation. Water Pump Flow Data - V4/V6/V8. February 5,1997.

5. Marine Specification Sheet, Model 7082-7000 Diesel Engine, Detroit Diesel Corporation,
1993.

6. Kip Davis (NSWC). Boat Numbers and Flow Rates, 18 March 1997, Doug Hamm
(MPI).
i
7. United States Environmental Protection Agency, Office of Air Quality Planning and
Standards. Compilation of Air Pollution Emission Factors. AP-42, Fifth Addition,
January 1995.
Small Boat Engine Wet Exhaust
8
-------
8. Juttner, et. al, "Emissions of Two- and Four-stroke Outboard Engines-1. Quantification
of Gases and VOC." Water Resources, Vol. 29 (November 1995): 1976-1982.

9. Environmental Protection Agency. Final Regulatory Impact Analysis: Control of
Emissions of Air Pollution from Highway Heavy Duty Engines, 16 September 1997.

10. Environmental Protection Agency, "Final Rule for New Gasoline Spark-Ignition Marine
Engines", Federal Register, Vol. 61, No. 194 (4 October 1996): 52091.

11. UNDS Database. 593.9117, Volume 2, Part 1. Small Boat Wet Exhaust. "Air Systems
of a 2-stroke cycle engine (GM71)." 19 November 1996.

12. Oregon Iron Works. "Boat Information Book for 65'Explosive Ordnance
Disposal Support Craft (EODSC) MK2, FY91-S9007-CL-BIB-010". 15 December
1993. Pg3-12.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
Small Boat Engine Wet Exhaust
9
-------
Mississippi. Water Quality Criteria for Ihtrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
" • •• . !
Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
, ' , , j '
•. • ; ' • • . . >:•.. I:
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

LT Joyce Aivalotis, USCG. Average Operating Times for USCG Small Boats. 11 April 1997.
I
William Boudreaux (NSWC) & Kip Davis (NSWC). Ship Numbers and Flow Rates, 12 May
1997, Doug Hamm (MPI).
il !
Staskiel, Mike, PMS324G16. List of Small Boats by Engine Type. 3 October 1996.
• . 1
MARCORSYSCOM. Totals for Marine Small Boat/Watercraft. 14 February 1997.
„ i < i
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. 23 March 1995.
Small Boat Engine Wet Exhaust
10
-------
SEA WATER INLET
WATER
JACKET
EXHAUST
MANIFOLD

AIR INTAKE
PORTS
EXHAUST
NLET PIPE
FLEXIBLE
PIPE
EXHAUST
SILENCER
EXHAUST
ROCKER
WATER
JACKET
EXHAUST
VALVE
BLOWER
EXHAUST AND
SEA WATER
OUTLET

WATER LINE

OVERBOARD
DISCHARGE
CAMSHAFT
AIR BOX
INTAKE
SILENCER
AIR SCREEN
Figure 1. Air Systems of a Two-Stroke Cycle Engine (GM71)11
Small Boat Engine Wet Exhaust
11
_
-------
EXHAUST
TUBING
TO
MUFFLER
COMMON
HEADER
LEGEND

EXHAUST GAS
SEA WATER
*" ^m MAIN
FLANGE ENGINE
EXHAUST MANIFOLD R/H
SEA WATER SUPPLY
Figure 2. Typical Water Jacketed Elevated Loop
12
Small Boat Engine Wet Exhaust
12
-------
Table 1. Estimated Annual Small Boat Wet Exhaust Discharge Flow Rates3'4*5'6
^Service (fleet)
Navy (inboard)
Navy (outboard)
USCG (inboard)
USCG (outboard)
Army (inboard)
Army (outboard)
Marine Corps (outboard)
Marine Corps (inboard)
Totals (inboard)
Totals (outboard)
Totals (combined)
Number of Small
r '""" Boats v
2,500
800
620
940
152
57
904
550
3,822
2,701
6,523
/ Estimated Annual Discharge* ,
17 (billions of gallons)
6.75
0.29
1.67
0.34
0.41
0.02
0.32
1.48
10.31
0.97
11.28
* Based on 150 gpm for vessels with inboard engines, 20 gpm for vessels with outboard engines, and an average
operating time of 25 hours/month.

Table 2. Wet Exhaust Constituents Emitted from Two and Four-Stroke 10 Horsepower
Gasoline Outboard Engines8
Constituent
Benzene
Toluene
Ethylbenzene
p/m-Xylene
o-Xylene
3 4-Ethyltoluene
Mesitylene
2-Ethyltoluene
Pseudocumene
Hemellitene
Indane
Indene
Naphthalene
2-Methylnaphthalene
1 -Methylnaphthalene
Formaldehyde
Amount in Wet Exhaust from
Two-Stroke Outboard Engines
(mg/lOmin)*
2800
8500
2000
6900
3600
3400
1200
870
4500
1200
840
270
1400
930
350
970
Amount in Wet Exhaust from
Four-Stroke Outboard Engines
(mg/lOmin)
110
260
22
71
37
26
10
8.7
40
13
4.7
6.5
13
5.5
2.7
100
*Note: Majority of small boat outboard engines in the Armed Forces are two-stroke engines
Small Boat Engine Wet Exhaust
13
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Table 3. Organic Compound Emission Factors for Diesel Engines7
Constituent

Benzene
Toluene
Xylenes
?ormaldehyde
Acetaldehyde
Acrolein
Nox
CO
CO2
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd) pyrene
Dibenz(a,h) anthracene
Benzo(g,h,i) perylene
Emission Factor
(lb/MMBtu)*
0.000933
0.000409
0.000285
0.00118
0.000767
0.0000925
4.41
0.95
164
0.0000848
0.00000506
0.00000142
0.0000292
0.0000294
0.00000187
0.00000761
0.00000478
0.00000168
0.000000353
9.91E-08
0.000000155
0.000000188
0.000000375
0.000000583
0.000000489
(ttg/J)
0.40119
0.17587
0.12255
0.5074
0.32981
0.039775
1896.3
408.5
70520
0.036464
0.0021758
0.0006106
0.012556
0.012642
0.0008041
0.0032723
0.0020554
0.0007224
0.00015179
0.000042613
0.00006665
0.00008084
0.00016125
0.00025069
0.00021027
' Ib/MMBtu = pounds per million British thermal units
Small Boat Engine Wet Exhaust
14
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Table 4. Estimated Concentrations of Wet Exhaust Constituents from Two- and Four-
Stroke Gasoline Outboard Engines
Constituent
Benzene
Toluene
Ethylbenzene
p/m-Xylene
o-Xylene
3 4-Ethyltoluene
Mesitylene
2-Ethyltoluene
Pseudocumene
Hemellitene
Indane
Indene
Naphthalene
2-Methyhiaphthalene
1 -Methylnaphthalene
Formaldehyde
Introduction Rate
Two-Stroke Engines
(nag /ID rain)*
17360
52700
12400
42780
22320
21080
7440
5394
27900
7440
5208
1674
8680
5766
2170
6014
Introduction Rate
Four-Stroke Engines
_ (mg/10,min)*
•* •*
618.2
1461.2
123.64
399.02
207.94
146.12
56.2
48.89
224.8
73.06
26.41
36.53
73.06
30.91
15.17
562
Estimated Concentrations in
Engine Wet Exhaust (mg/L)
**- "" *.
Two-Stroke
22.93
69.62
16.38
56.51
29.48
27.85
9.83
7.13
36.86
9.83
6.88
2.21
11.47
7.62
2.87
7.94
Four-Stroke
0.82
1.93
0.16
0.53
0.27
0.19
0.07
0.06
0.3
0.1
0.035
0.048
0.1
0.04
0.02
0.74
*Note: The majority of small boat outboard engines in the Armed Forces are two-stroke engines.
Small Boat Engine Wet Exhaust
15
-------
Table 5. Estimated Concentrations of Wet Exhaust Constituents from
Diesel Inboard Engines
Constituent
Benzene
Toluene
Xylenes
Formaldehyde
Acetaldehyde
Acrolein
Nox
CO
CO2
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Ihdeno{l,2,3-cd) pyrene
Dibenzo(a,h) anthracene
Benzo(g,h,i) perylene
Concentration in Air Exhaust
(moles/ft3)
3.21E-08
1.19E-08
7.22E-09
1.06E-07
4.68E-08
4.44E-09
3.95E-04
9.11E-05
l.OOE-02
1.78E-09
8.93E-11
2.47E-11
4.72E-10
4.43E-10
2.82E-11
1.01E-10
6.35E-11
1.98E-11
4.15E-12
1.05E-12
1.65E-12
2.00E-12
3.65E-12
5.63E-12
4.75E-12
Concentration in Discharge
(mgflL)
1.87E-04
6.78E-05
4.91E-05
7.58E-01
4.83E-02
6.15E-04
1.82E-02
1.97E-03
1.11E+01
2.19E-04
2.16E-06
6.58E-06
3.81E-04
8.17E-04
3.46E-05
3.84E-06
4.43E-04
9.18E-04
2.13E-04
5.28E-06
2.49E-06
7.69E-05
3.45E-03
5.05E-03
5.80E-03
Small Boat Engine Wet Exhaust
16
-------
Table 6. Estimated Annual Fleet-Wide Mass Loading of Wet Exhaust Constituents
from Outboard Engines
Constituent -
f * ~~ ~r* *
Benzene
Toluene
Ethylbenzene
p/m-Xylene
o-Xylene
Naphthalene
2-Methylnaphthalene
*-„ , Concentrations ,
(mg/L)
22.93
69.62
16.38
56.51
29.48
11.47
7.62
Estimated Mass Loading ,
,l(kg/yr)
84,196
255,595
60,140
207,483
108,252
42,098
27,965
/ (lbs/yr) ,
185,600
562,500
132,600
456,400
238,700
92,800
61,700
* These values were based on an annual flow rate of 0.97 billion gallons/year (see Section 4.1). Mass
loadings are based on estimated emissions from a 100 HP, two-stroke engine.
Table 7. Estimated Annual Fleet-Wide Mass Loading of Wet Exhaust Constituents from
Diesel Inboard Engines
Constituent
* Concentration in -
>:, Discharge
^(rag/L>
, Annual Mass
Loading
(Kilograms)
Annual Mass
Loading ,
(Pounds)-
Polyaromatic
Hydrocarbons (PAHs)
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd) pyrene
Dibenzo(a,h) anthracene
Benzo(g,h,i) perylene
2.19E-04
2.16E-06
6.58E-06
3.81E-04
8.17E-04
3.46E-05
3.84E-06
4.43E-04
9.18E-04
2.13E-04
5.28E-06
2.49E-06
7.69E-05
3.45E-03
5.05E-03
5.80E-03
8.56E+00
8.44E-02
2.57E-01
1.49E+01
3.19E+01
1.35E+00
1.50E-01
1.73E+01
3.58E+01
8.32E+00
2.06E-01
9.72E-02
3.00E+00
1.35E+02
1.97E+02
2.26E+02
18.9
0.186
0.566
32.8
70.3
2.98
0.330
38.1
79.0
18.3
0.454
0.214
6.61
297
434
499
c These values were based on an annual flow rate of 10.31 billion gallons/year (see Section 4.1)
Small Boat Engine Wet Exhaust
17
-------
Table 8. Comparison of Estimated Concentrations of Wet Exhaust Constituents and
Water Quality Criteria (jxg/L)
Constituent
Outboard Engines
Two-Stroke
Benzene
Toluene
Ethylbenzene
Naphthalene

Four-Stroke
Benzene
Ethylbenzene
Inboard Engines
Acenaphthylene
Phenanthrene
Chrysene
Benzo(a)pyrene
Benzo(a)anthracene
Bcnzo(b)fluoranthene
Benzo(k)fluoranthene
Indeno{l,23-cd) pyrene
Dibenzo(a,h) anthracene
Benzo(g,h,i) perylene
TOTAL PAHs (Inboard
Engines)
Estimated Discharge
Concentration

22,930
69,620
16,380
11,470

820
160

2.16E-03
8.17E-01
2.13E-01
7.69E-02
9.18E-01
5.28E-03
2.49E-03
3.45
5.05
5.80
16.3 l
Federal Acute
woe

None
None
None
None

None
None

None
None
None
None
-
-
-
-
-
-

Most Stringent State Acute
-;.,;,/ -w<*c - • .- -

71.28 (FL)
2,100 (HI)
140 (HI)
780 (HI)

71.28 (FL)
140 (HI)

0.031 (FL)1
0.031 (FL)1
0.031 (FL)1
0.031 (FL)1
0.031 (FL)1
0.031 (FL)1
0.031 (FL)1
0.031 (FL)1
0.031 (FL)1
0.031 (FL)1
0.031 (FL)1
36 (57 PR 60848; Dec.

were compared to the most
N^tes:
Refer to federal criteria promulgated by EPA hi its National Toxics Rule, 40 CFR 131.
22, 1992 and 60 FR 22230; May 4, 1995)
Where historical data were not reported as dissolved or total, the metals concentrations
stringent (dissolved or total) state water quality criteria.

Ft - Florida \
HL = Hawaii

1: Florida criteria for total PAHs is for the total of the following individual PAH compounds: acenaphthylene,
benzo-^ajanthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene,
chrysene, dibenzo(a,h)anthracene, indeno(l,2,3-cd)pyrene, and phenanthrene. Estimated discharge
concentrations for total PAHs represent a sum of these chemicals.
Small Boat Engine Wet Exhaust
18
-------
Table 9. Data Sources
*t
. NODSection
2.1 Equipment Description and
Operation. ,-.''"
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality ,
3.2 Rate
3.3 Constituents
3.4'Concentrations
4.1 Mass Loadings <- - „
4.2 Environmental Goncentrations
4.3 Potential for Introducing Non-
Indigenous Species '••
>~ Data Source^
~ Reported
X
X
UNDS Database
X
X
X
X

Sampling

Estimated

X
X
X
X
X
X
Equipment Expert
X
X
X
X
X
X

Small Boat Engine Wet Exhaust
19
-------
Calculation Sheet
Benzene

Background:
Henry's Law was used to estimate the concentration of components in wet exhaust from small boat inboard
diesel engines. This calculation sheet shows the calculation for the concentration of benzene in the wet
exhaust Calculations for the other exhaust components were similar.
, , i!
••! f ' !!:
A heat balance was used to determine the approximate wet exhaust equilibrium temperature. The
temperature was determined using an air exhaust flow rate of 2,190 dm at 870 °F, and a water injection rate
of 100 gpm at 60 °F. 60 °F is believed to be an appropriate average because most large military ports are
located in areas with similar average water temperatures. For this calculation, we assume the exhaust gas to
have thermal properties similar to air.

AH: Change in enthalpy, m: mass of air or water, Cp: Specific heat capacity of air or water
AHcxhaustgas=mCp (200 °F - T)
= (2,190 ftVmin) (0.0601 Ib^ft3) (0.24 Btu/lbm°F) (870 °F - T)

- 31.59 Btu/°Fmin. (870 °F-T) (1)
AHwalCT = mCp (T - 60 °F) = (100 gal/min) (8.345 lbm /gal) (1 Btu/ lbm °F) (T - 60 °F)

-= 834.5 Btu/°Fmin(T- 60 °F) (2)

Setting (1) = (2) we obtain the following:
i

31.59 Btu/°F (870 °F - T) = 834.5 Btu/°F( T - 60 °F)
31.59 (T) + 834.5 (T) = 870 °F (31.59) + 834.5 (60 °F)

T =89.5 °F = (9/5) °C +32 = 32 °C

This temperature was then used to determine the appropriate values for Henry's Law
constants, which vary with temperature.
At dilute concentrations, the concentration of benzene dissolved in water can be found from Henry's Law:
Xcxhaust= (tla) (Xwater) / \"t)
Where:
Xexhiujt: Mole Fraction of Benzene in Exhaust
H,: Henry's Law Constant (Adjusted Reference 7)
X^: Mole Fraction of Benzene in Water
Pt: Total Exhaust Pressure (atm)
•: • • • I
Rearranging, Henry's Law can be rewritten as:

Xwater = (Xexhaust) (Pt) / Ha

The mole fraction of benzene in exhaust can then be converted into a concentration of benzene in the wet
exhaust in mg/L using the molecular weight of benzene.
Given Conditions and Assumptions:
Small Boat Engine Wet Exhaust
20
-------
55.56 moles H2O in 1 liter, [ (1000 g/liter) (mole H2O / 18 g ) = 55.56 moles H2O / liter ]
Exhaust temperature of 870 °F
2,190 crm air exhaust flow rate for 228 kW diesel engine
0.401 ng/J generation rate of benzene
Backpressure (Pt) on engine is approximately 1.147 atm
Molecular weight of benzene is 78.11 grams per mole (78,110 mg/mole)
Based on a water temperature of 32 °C (305.15 K), Henry's Law constants (in atm) for the constituents are
the following: v
Constituent Ha (atm)
Benzene
Toluene
Xylenes
Formaldehyde
Acetaldehyde
Acrolein
Nox
CO
C02
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd) pyrene
Dibenzo(a,h) anthracene
Benzo(g,h,i) perylene
6.52E+02
7.94E+02
7.64E+02
2.05E-01
2.09E+00
1.98E+01
6.81E+04
1.37E+05
3.85E+03
5.09E+01
3.08E+02
2.84E+01
1.01E+01
4.74E+00
7.11E+00
2.61E+02
1.42E+00
2.41E-01
2.18E-01
2.47E+00
8.19E+00
3.22E-01
1.43E-02
1.52E-02
1.11E-02
The conversion of Henry's Law constants into common units is presented at the end of the calculation sheet.

Solution:
1) Total number of moles per cubic foot in the air exhaust, including constituents and circulated air, n

The number of moles per cubic foot can be determined using the ideal gas law; PV = n,RT

Where:
P: Pressure within the exhaust piping, 1.147 atm
V: Volume of space occupied by gas (assume 1 ft3)
R: Gas constant, 0.08206 L-atm/ K-mol
T: Temperature, 305.15 K

Rearranging the ideal gas law equation and solving for nt/V:
n,/V =P/RT

nt/V = (1.147atm) / (( 0.08206 L-atm/ K-mol) ( 1 ft3/28.32 L) (305.15 K))
= 1.30 moles/ft3
Small Boat Engine Wet Exhaust
21
-------
2) Concentration of benzene in air exhaust, Ab

Ab^ (6.401 ng/J) (228 kW) (3.6 x 106 J/kW-hr) (10'9g/ng) (1000 mg/g) (min./2190 f°) (hr/60 min)
^ 2.50 xW3 rag/ft3
= (2.50 x 10'3 mg/ft3) (mole benzene/78,1 10 mg) = 3.2 x 10'8 moles benzene/fl3 exhaust

3) Mole fraction of gas in exhaust, P»
Pa = Ab / total molar concentration
Pa = (3.2 x 10* moles benzene/ ft3 exhaust) / (1.30 total moles/ ft3 exhaust)
Pa = 2.46 x 10"8 moles benzene/ mole exhaust

4) Mole fraction of gas in water, Xwater
= (Xexhaust) (Pt) / Ha
= (2.46 x 10-8) (1.147 atm) / (652 atm)
= 4.33 x 10"11 moles benzene/ mole water
5) Concentration of gas in water:
Per 1 liter of water;
Moles benzene = (4.33 x 10'11 moles benzene/mole H2O)(55.56 moles H2O/ 1 liter) = 5.19 x 10'9 moles/L
= (2.4 x 10"9 moles/L) (78,110 mg benzene/mole) = 1.87 x Iff4 mg/L benzene
Small Boat Engine Wet Exhaust
22
I IJsIl ', ...hiliili ,,M 31,,!; j
/,,,, lA,,'';: J,i !!l,i, jj|,l
-------
Determination of Henry's Constants

Henry's constants for the constituents were available, but units and temperature for the constants varied between the
references used. Henry's constants with the following units were available:

1) HI, atm
2) H2, atm-m3/mol

For purposes of clarity, the same calculation was used for each constituent. It was therefore necessary to
convert all of Henry's constants to atm units, (1).

1) Conversion H2 (atm-m3/mol) to HI (atm):

HI = (H2 atm-m3/mol) (55.6 mol water / L) ( L / 10"3 m3 water) = (H2) (55,600)

Henry's constants with the following temperatures in degrees Celsius were available:
(1) 20 °C
(2) 24 °C
(3) 25 °C
(4) 40 °C
(5) 32 °C

Henry's constants increase on average about threefold for every 10 °C rise in temperature for most volatile
hydrocarbons.3 Therefore, with an increase in temperature the constants increase by a factor of AH = 3. All of
the constants were converted to 32 °C constants using the following conversions.

For Henry's constant at 32 °C and converting from Henry's constants at 20 °C, 24 °C, 25 °C, and 40 °C respectively:

H32 = (H2o)(3.74),

H32 = (H24)(2.41),

H32 = (H2S) (2.16), and

H32 = (H4o)/(2.41)

Example - Henry's Constant Calculation

For Acrolein, Henry's constant was available in atm-m3/mol for 20°c (Ha = 9.54 x 10"s)
Ha (atm) = (9.54 x 10'5 atm-m3/mol) (55,600 mol/m3) (3.74)
Ha = 19.8 atm

Using these methods, the constants were converted to atm units as shown in the table on the following page.
Small Boat Engine Wet Exhaust
23
-------
Table of Henry's Constants
Degrees
Source
Units
Benzene
Toluene
Xylenes
Formaldehyde
Acetaldehyde
Acroleirt
Nox
CO
C02
Naphthalene
Acenapfathylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benz(a)anthracene
Chrysene
Benzo(b)fluoranthene
Bcnzo{k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd) pyrene
Dibcnz(a,h) anthracene
Benzo(g,h,i) perylene
32 degrees
Cooper
atm

3.18E+04
635E+04
1.95E+03

20 degrees
USEPA
(atar^miVmol)

9.87E-07

9.54E-05

1.15E-03
1.48E-03
9.20E-05
6.42E-05
1.59E-05
1.02E-03
6.46E-06
5.04E-06
1.16E-06
1.05E-06
1.19E-05
3.94E-05
1.55E-06
6.86E-08
7.33E-08
5J4E-08
25 degrees
Mackay
(atm*m3/rnoi)

4.24E-04

2.37E-04
839E-05
3.95E-05
5.92E-05
2.17E-03
1.18E-05

25 degrees
Mackay
KpamVmol
5.50E-01
6.70E-01
6.45E-01

4.30E-02

2.40E-02
8.50E-03
4.00E-03
6.00E-03
2.20E-01
1.20E-03

, 40 degrees
CH2MHifit
(atm*m?/mol)

9.05E-05

32 degrees
Henry's Constants
•; aim- '•"':.•
6.52E+02
7.94E+02
7.64E+02
2.05E-01
2.09E+00
1.98E+01
3.18E+04
6.35E+04
1.95E+03
5.09E+01
3.08E+02
2.84E+01
1.01E+01
4.74E+00
7.11E+00
2.61E+02
1.42E+00
2.41E-01
2.18E-01
2.47E+00
8.19E+00
3.22E-01
1.43E-02
1.52E-02
1.11E-02
Bold: Original Referenced Number
Sources:
a. Kavanaugh, M. C. and R. Rhodes Trussell, "Design of Aeration Towers to Strip Volatile
Contaminants from Drinking Water" Journal of the American Water Works Association. December. 1980.
i
ii
b. Cooper, D. and F. Alley, Air Pollution Control. A Design Approach. Waveland Press, Inc., 1986.
1 ' !
c. United States Environmental Protection Agency, Office of Air Quality Planning and Standards.
Ground-Water and Leachate Treatment Systems Manual. R-94, January 1995.
! '
d. Mackay, D. and W. Y. Shiu, "A Critical Review of Henry's Law Constants for Chemicals of
Environmental Interest*'. Journal of Phvs. Chem. Ref. Data. Vol. 10. No. 4. pp. 1175-1199.1981.
;' •" i •;,. i
e. CH2M Hill Inc., Bay Area Sewage Toxic Emissions Model. Version 3, 1992.
Small Boat Engine Wet Exhaust
24
-------
SMALL BOAT ENGINE WET EXHAUST
MARINE POLLUTION CONTROL DEVICE (MPCD) ANALYSIS
Several alternatives were investigated to determine if any reasonable and practicable
MPCDs exist or could be developed for controlling discharges from small boat engine wet
exhaust. An MPCD is defined as any equipment or management practice, for installation or use
onboard a vessel, designed to receive, retain, treat, control, or eliminate a discharge incidental to
the normal operation of a vessel. Phase I of UNDS requires several factors to be considered
when determining which discharges should be controlled by MPCDs. These include the
practicability, operational impact, and cost of an MPCD. During Phase I of UNDS, an MPCD
option was deemed reasonable and practicable even if the analysis showed it was reasonable and
practicable only for a limited number of vessels or vessel classes, or only on new construction
vessels. Therefore, every possible MPCD alternative was not evaluated. A more detailed
evaluation of MPCD alternatives will be conducted during Phase n of UNDS when determining
the performance requirements for MPCDs. This Phase n analysis will not be limited to the
MPCDs described below and may consider additional MPCD options.

MPCD Options

Small boats of the armed forces are equipped with either two- or four-stroke compression
ignition diesel or two-stroke spark ignition gasoline engines. During the operation of small boat
engines, seawater is used to cool and quiet engine exhaust. As seawater is introduced into the
engine exhaust, combustion by-products are captured by the seawater stream, and are discharged
into the receiving water.

Three potential MPCD options were investigated. The purpose of these MPCDs would
be to reduce or eliminate the release of hydrocarbons, oil and grease, volatile organic compounds,
and semi-volatile organic compounds into the marine environment. The MPCD options were
selected based on initial screenings of alternate materials and equipment, pollution prevention
options, and management practices. They are listed below with brief descriptions of each:

Option 1: Employ dry exhaust systems on new boats and craft with inboard engines
-This option would require that new small boats and craft to be equipped with inboard
engines to be outfitted with dry exhaust systems wherever practicable.

Option 2: Convert small boats and craft with inboard engines to a dry exhaust
system - This option would involve converting small boats and craft that are currently
discharging wet exhaust at or below the waterline to dry exhaust systems.
Small Boat Engine Wet Exhaust MPCD Analysis
1
-------
Option 3: Procure new outboard engines with reduced emissions to meet new
emissions requirements being imposed in 1999 - This option would involve replacing
existing outboard engines with new "low emission" outboard engines either all at once or
through attrition. These new outboards would meet EPA emission requirements which
will be taking effect in 1999.

MPCD Analysis Results

Table 1 shows the results of the MPCD analysis. It contains information on the elements
of practicability, effect on operational and warfighting capabilities, cost, environmental
effectiveness, and a final determination for each option. Based on these findings, Option 1 —
building small boats and craft with inboard engines and dry exhaust systems, and Option 3 —
procure new dutboard engines with reduced emissions to meet new emissions requirements, offer
the best combination of these elements and are both considered to represent a reasonable and
practicable MPCD.
Small Boat Engine Wet Exhaust MPCD Analysis
2
-------
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>,
horsepower ranges currentl
available, may require two

Navy would cost an
estimated $9.0M.

outboards where one was
sufficient before.

Implementing this option
through attrition would

impose a considerably lower

| annual cost of $34,000.

8
S

1
•6
S
•a
PQ
CO
I JniM I, i!i,i i.iirll
,< ,;,:, Ui!1,]!'! !i, Ill
-------
REFERENCES

1 NSWC Comments on NOD Report Review, March 18,1997.

2 USEPA, Amendment to Emissions Requirements Applicable to New Gasoline Spark-Ignition
Marine Engines, EPA Title 40 CFR Part 91, Effective April 2,1997.
Small Boat Engine Wet Exhaust MPCD Analysis
5
-------
-------
NATURE OF DISCHARGE REPORT
Sonar Dome Discharge
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed hi three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that has
been identified as a candidate for regulation under UNDS. The NOD reports were developed
based on information obtained from the technical community within the Navy and other branches
of the Armed Forces with vessels potentially subject to UNDS, from information available hi
existing technical reports and documentation, and, when required, from data obtained from
discharge samples that were collected under the UNDS program.

2.1 Equipment Description and Operation

Sonar domes are located on the hulls of submarines and surface ships. Their purpose is to
house electronic equipment used for detection, navigation, and ranging. Figures 1 through 4
show typical hull-mounted submarine and surface ship sonar domes.
i',
Sonar domes on Navy surface ships are made of rubber. On submarines, they are made of
steel or glass-reinforced plastic (GRP) with a 1/2-inch rubber boot covering the exterior.
Military Sealift Command (MSC) T-AGS Class ships have sonar domes made of GRP. Zinc
anodes are fastened to the exterior of steel sonar domes, and are contained within all the sonar
domes, for cathodlc protection. Figure 5 shows a Navy surface ship rubber dome, prior to
installation.
" ji
Sonar domes can be filled with fresh and/or seawater to maintain their shape and design
pressure. Most surface ship sonar domes are initially filled with freshwater, and any water that is
lost underway is replenished with seawater from the firemain system. Sonar domes on FFG 7
Class frigates and some MSC ships are filled with seawater. Submarine sonar domes are
connected to the sea through a small tube to equalize pressure, but water inside the dome has
limited exchange with seawater.1
i
Table 1 summarizes sonar dome types, applications, and characteristics. The larger
AN/SQS-53 and AN/SQS-26 sonar domes on cruisers and destroyers are located at the bow, and
the smaller AN/SQS-56 domes on frigates are mounted on the keel. Submarine sonar domes are
located at the bow- MSC T-AGS Class ships have several small sonar domes at various locations
on the hull. The T-AGS Class sonar domes listed as free flood in Table 1, have ports which are
open to the sea.

Table 2 shows materials that compose sonar domes, and components and materials inside
sonar domes. Components and materials interior to sonar domes can include piping, sacrificial
anodes, paint and the interior material surface of the sonar dome itself. Materials on the exterior
surface of the sonar dome consist of the exterior material surface of the dome itself, any paints or
coatings applied to the dome, and in some cases, sacrificial anodes.

There have been changes in the composition of the rubber material in Navy surface ship
sonar domes. Prior to 1985, all sonar domes contained tributyltin (TBT) antifoulant on the
interior and exterior, to prevent or minimize marine growth. The TBT was impregnated into the
outermost 1/4-inch layers (both exterior and interior) of the rubber. Figure 6 shows the plys or
layers of a surface ship rubber sonar dome. Since 1985 rubber sonar domes have been
manufactured with TBT only on the exterior surface. This type of sonar dome has been
Sonar Dome Discharge
2
-------
backfitted on older ships when they require sonar dome replacement, and has been installed on
all new ships since 1990. Submarine sonar domes do not contain TBT. Instead, the exterior
rubber boots are coated with a copper-based antifouling paint.2 Table 3 lists the surface ships
that have no TBT in the interior of their sonar domes.

Sonar domes are emptied for sonar dome maintenance or replacement, and are always
emptied when a vessel is in drydock. Some maintenance can be performed pierside. Sonar
domes are emptied by first pressurizing them with air, to force as much water as possible through
the installed eductor piping. Once this step is complete, eductors are used to remove all
remaining water in the dome. The total volume of water discharged exceeds the sonar dome
volume because the seawater used to operate the eductors is discharged along with water from
the sonar dome.

The water emptied from the sonar dome interior is: 1) discharged overboard, if the vessel
is waterbome, or 2) collected for proper management ashore, if the vessel is in drydock.

2.2 Releases to the Environment

There are two sonar dome discharges, discharges of the water from the interior of sonar
domes and external discharges. Discharges of water from the interior of the sonar dome result
from maintenance evolutions that require the sonar dome to be emptied. External discharges
result from continuous leaching of TBT or other anti-fouling compounds from the sonar dome
exterior.

2.3 Vessels Producing the Discharge

Only Navy and MSC vessels are equipped with sonar domes; the other Armed Forces
ships are not. Sonar domes are equipped on the following types and classes of Navy and MSC
ships:

• cruisers (CG and CGN Classes);
• destroyers (DD and DDG Classes);
• frigates (FFG Class);
• submarines (all SSN and SSBN Classes); and
• MSC T-AGS Class ships.

Tables 1 and 4 list the classes and populations of sonar dome-equipped vessels. Eighty-
three of the Navy surface ships have the larger AN/SQS-26 or SQS-53 sonar domes, and 43 have
the smaller SQS-56 domes. Seventy-two active submarines have the smaller BQQ-5, BQR-7 or
BSY-1 sonar domes, and the 17 others have much larger BQQ-6 sonar domes.
3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

Sonar Dome Discharge
3
-------
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and near-
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
, i
3.1 Locality

Discharges from the interior of sonar domes only occur while vessels are pierside.
Discharges from the external surface of sonar domes occur both within and beyond 12 nautical
miles (n.m.) of shore, as materials leach continuously from the exterior of the dome. Discharges
from the external surface of sonar domes were studied by the Naval Command, Control and
Ocean Surveillance Center to characterize the environmental effects in San Diego harbor.3

3.2 Discharge Rate

Discharge from the ulterior of sonar domes is intermittent, depending on when the dome
is emptied for maintenance. The average volume of water discharged for maintenance or repair
activities is estimated based on input from naval shipyards. Sonar dome discharge volume varies
with the dome type (size) and the method used to empty the dome. Norfolk and Pearl Harbor
Naval Shipyards report that between 23,000 and 38,000 gallons is typically emptied from
AN/SQS-53 sonar domes.4"5 Table 4 contains the estimated annual discharge for sonar done-
equipped vessels, based on the vessel class populations, sonar dome water capacity, and number
of sonar domes expected to be emptied per year. On average, sonar domes on surface ships are
emptied two times per year. Submarine sonar domes are normally emptied once per year.2 Table
4 indicates a total annual discharge estimate of about 9.3 million gallons of interior sonar dome
effluent, with just under 4.0 million of that being from sonar domes with internal TBT coatings.
ji .
Discharge from the external surface of a sonar dome is not a liquid discharge; rather, it is
the leaching of anti-fouling agents into the surrounding water, and cannot be characterized by a
Volumetric flow rate. A Navy study was conducted hi San Diego Bay in 1996 to determine TBT
release rates from rubber sonar domes. Release rates from the external surfaces were determined
by attaching a closed capture system to the sonar domes exteriors of three ships. The sampled
sonar domes ranged in age, at 3,10 and 20 years since installation. Table 5 shows that the
average release rate for TBT from the external surfaces of the sonar domes was 0.36 jj,g/cm2/day
(micrograms per square centimeter per day), which results in an average release of 0.27 grams of
TBT per day per ship.3

33 Constituents
••'• !! • • . . i '• : [l ' •
Table 2 shows the components and materials in sonar domes that can contribute
constituents to the sonar dome discharge. The specific constituents depend on vessel class, the
age of the dome, and the source of water that fills the dome. Discharges from the ulterior of
sonar domes can include copper, nickel, tin and zinc which corrodes, erodes, or leaches from
piping, sacrificial anodes, paint, or other material inside the dome. If the interior of the dome is
impregnated with TBT, discharges will also include that constituent. The potable water and/or
seawater that fills the sonar dome is also a source of constituents in discharges from the interior.
Sonar Dome Discharge
4
-------
In addition to these constituents, the interior effluent can contain compounds that are produced
by degradation of the materials or reaction of material with the water. For instance, TBT, which
might be found on both the interior and exterior of surface ship rubber sonar domes, degrades to
dibutyltin (DBT) and monobutyltin (MBT).

External discharge constituents will include the TBT impregnated into the exterior of
rubber sonar domes, or copper from copper based antifoulant coating on GRP and steel domes.
Discharge from copper based and other antifoulant coatings are addressed separately, by the Hull
Coating Leachate NOD Report.

Sampling of the water within the interior of sonar domes was conducted to identify and
measure constituents, and was done according to procedures specified by the Navy. Samples
from the interior of sonar domes were manually collected from the sonar dome piping systems of
Navy surface ships and submarines, prior to discharge. The three sampling activities, Norfolk
and Pearl Harbor Naval Shipyards and the Naval Command, Control and Ocean Surveillance
Center did not all sample for the same constituents, as shown in Table 6. The tests that were
performed on the samples included gas chromatography, hydride derivization and atomic
absorption for TBT, and Toxicity Characteristic Leaching Procedure (TCLP) for metals. Tests
done on sonar domes have indicated that the constituents of discharges from the interior of sonar
domes are copper, nickel, tin, zinc, TBT (also known as tetra-normal-tributyltin), DBT and MBT.
External sonar dome discharge constituents are TBT, DBT, MBT, copper, and zinc.3'4'5'6

Of the discharge constituents listed above, copper, nickel, and zinc are priority pollutants.
None of the discharge constituents are bioaccumulators.

3.4 Concentrations

A summary of results of sampling discharges from the interior of sonar domes is
contained in Table 6. Altogether, previous Navy studies have analyzed the water from the
interior of sonar domes on 31 surface ships and submarines, with some vessels sampled multiple
times. In addition to the metals and compounds listed in Section 3.3, four samples from the USS
South Carolina were analyzed for Chemical Oxygen Demand (COD) and four samples from the
USS Conolly were analyzed for both Total Suspended Solids (TSS) and Total Organic Carbon
(TOC). The results of the sampling are summarized below:3'4'5

The average concentrations of the metal constituents are listed in Table 6.

Among the classical pollutants, COD levels ranged from 20 to 180 milligrams per liter
(mg/L), with an average of 123 mg/L. Total organic carbon levels ranged between 4 and 6 mg/L.
Total suspended solids were all below 4 mg/L.

TBT concentrations ranged from 1 to 470 micrograms per liter (pg /L), with an average of
74 |j,g/L. Only one sample has been taken for concentrations of MBT and DBT. The results
were 5 and 33 |ig/L, respectively.
Sonar Dome Discharge
5
-------
The firemam system is normally used to replenish sonar dome water lost on surface ships
while underway and to educt the final water remaining when a sonar dome is emptied. However,
the seawater from the firemain has a negligible effect on the constituent concentrations in this
report. The salinity of the samples was low, indicating that little make-up seawater was added to
the sonar domes during operations. The sonar dome sampling procedure requires samples to be
taken from the dome, not from the emptied water, so firemain water that powers the eductors will
not dilute or contribute constituents to the samples.
i;
The above analytical results only address discharges from the ulterior of the sonar domes,
and do not account for the discharge from the external surfaces. The external surface TBT
release rates and estimated mass loadings are included in Sections 3.2 and 4.1, respectively.
4.0 NATURE OF DISCHARGE ANALYSIS
; • , ; !
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality standards. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings
!
The amount of water discharged fleet-wide from the interior of sonar domes was
estimated using:
1) the amount of water generated from each type of sonar dome when that sonar dome is
emptied;
2) the frequency of maintenance requiring sonar domes to be emptied;
3) the number of vessels with each type of sonar dome; and
4) the average concentrations of each of the constituents.

The estimated fleet-wide mass loadings for copper, nickel, tin, and zinc were calculated
by the following formula:
(avg.
concentrations
in
Mass Loading (Ibs/yr) =
ug/L) (discharge in gal/yr) (3.7854 L/gal) (2.2
]b/kg)(10"9 kg/jig)
For example, copper:
MassLoading=
(303 jig/L) (9,278,800 gal/yr) (3.7854 L/gal) (2.2 lb/kg)(lO"9 kg/ng) = 23.4 Ibs/yr
This calculation of mass loadings from sonar domes overestimates the actual mass
loadings because:
I! '
Sonar Dome Discharge
6
-------
1) All discharges are assumed to occur pierside, but some of the discharges actually
occur in drydock, where they are managed under shipyard discharge permits.
2) All discharges are assumed to occur within U.S. territorial waters, but some of the
discharges actually occur outside U.S. territorial waters.
3) Results of discharge sample measurements which were below detection levels were
assumed to be at the detection level.

The average constituent concentrations from Table 6, and a total estimated annual
discharge volume of 9.3 million gallons per year for all vessels, taken from Table 4, were used to
calculate the mass loadings. Based upon this information and the above formula, the annual
mass loadings for metals were calculated to be 23 pounds for copper, 11 pounds for nickel, 15
pounds for tin, and 122 pounds for zinc.

The estimated fleet-wide mass loading for TBT, DBT and MBT generated from sonar
dome interiors was calculated by the same formula (above), using a 3.96 million gallon discharge
volume per year for those vessels in Table 4 that could have TBT inside the sonar dome. Using
the average TBT concentration of 74 p,g/L, the annual mass loading estimate for TBT is 2.4
pounds per year due to discharges of water from the interior of the sonar dome. Although not
representative of all vessels, the one sample in which DBT and MBT were measured is used to
calculate fleet-wide mass loading for those constituents, using the same 3.96 million gallon
discharge volume, since DBT and MBT are degradation products of TBT. Based on the single
sample concentrations of 33 and 5 fig/L for DBT and MBT, respectively, the estimated mass
loadings are 1.1 and 0.2 pounds per year, respectively.

The calculation for TBT mass loading from the exteriors of surface ship rubber sonar
domes was performed using the following formula:
Sonar Dome External Discharge TBT Mass Loading (Ibs/yr) = \ • ~ ,-v/
(avg. release rate,ra g/day) (0;00205 Ibs/g) (no. of ships with rubber domes) [avg, days/yr in port
+ ((no. transits/vr)(4nre/fransit)^24hrs/day)],>

(0.27 g/day) (0.00205 Ibs/g) (1267ships) (158 days/yr in port + ((12 transits/yr)(4 hrs/transit)* 24,
hrs/day)) -12.6 Ibs/yr - ; ,?' -----
This formula uses the release rate from Table 5, which is based on sampling the discharge
from the external surface of rubber sonar domes on three Navy surface ships, two of which had
older sonar domes, and the newer DDG 51 Class USS John Paul Jones.3 The formula also uses
158 days/yr as the estimated annual in-port tune for each ship. The result is a TBT annual mass
loading of 12.6 pounds due to discharges from the external surface of the sonar dome.

Therefore, the estimated maximum TBT mass loading within 12 n.m. for surface ships
equipped with rubber sonar domes is 15.0 Ibs/yr. This is the sum of 2.4 Ibs/yr from discharges
from the interior of the sonar domes and 12.6 Ibs/yr from discharges from the external surface.

The estimated mass loadings generated from sonar dome interior and exterior discharges
Sonar Dome Discharge
7
-------
are presented in Table 7.

4.2 Environmental Concentrations
!!
Table 8 compares the concentrations of constituents in sonar dome discharge with the
niost stringent water quality criteria (WQC) for that constituent. For sonar dome discharge, the
constituents known to be present are TBT, DBT, MET, copper, nickel, tin, and zinc. As a result
of the comparison, the mean concentrations of TBT, copper, nickel, and zinc each exceed their
respective Federal and most stringent state acute WQC. The interior concentrations can be
compared to acute values and the exterior concentrations compared to chronic values. Neither
DBT, MET, nor tin has a relevant WQC.

4.3 Potential for Introduction of Non-Indigenous Species

Most sonar domes do not have the potential for the transfer of non-indigenous species in
discharge of water from the interior of the sonar dome, or for transfer from the external surface.
Non-indigenous species transfer would occur primarily during the emptying and replenishment of
water in the interior of the sonar dome, and that is normally performed at a vessel's homeport or a
shipyard. TBT on the ulterior surface of older rubber sonar domes and the exterior of all rubber
sonar domes prevents attachment of marine organisms and could inhibit their growth.
1 : •(! , .',,.. i
Sonar domes filled with freshwater have little potential to be a mechanism for transfer of
non-indigenous species in the water that fills the dome. There is minimal exchange with
seawater. Only a small volume of water from the ship's potable water or surrounding seawater is
added to the existing potable water in the dome between emptying and replenishment events to
make up for any loss of sonar dome water during operations. Therefore, the opportunity to
introduce non-native organisms into the surrounding water is limited.

Non-free-flood sonar domes filled with seawater have the potential for transfer of non-
indigenous species. These types of sonar domes are found on FFG 7 Class Navy frigates.
However, the non-indigenous species transfer potential is considered very low for the following
reasons: 1) the maintenance requiring sonar dome emptying and replenishment is normally
performed at the ship's home port, so water taken on will be discharged in the same locality; 2)
most of the sonar domes have TBT on the interior surface because the ships were built prior to
1990; and 3) the residence time inside these sonar domes is long (on the order of 6 months),
making the probability of survival of non-indigenous species more remote.1
5.0 CONCLUSIONS

Discharges from sonar domes has a low potential for causing adverse environmental
effect. Although concentrations of organotins (MBT, DBT, and TBT), copper, nickel, and zinc
discharged from sonar dome interiors exceed water quality criteria mass loadings of these
substances are small (3.7,23,11, and 122 pounds per year, respectively). Exterior releases of
TBT are also expected to be small (12.6 pounds annually).
Sonar Dome Discharge
8
-------
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 9
lists data sources for this report.

Specific References

1. UNDS Equipment Expert Meeting Minutes. Sonar Dome. September 10,1996.

2. UNDS MPCD Practicability Meeting. Sonar Dome. June 26,1997.

3. U.S. Navy. Marine Environmental Support Office, Naval Command, Control and Ocean
Surveillance Center RDT&E Division (NRaD). Sonar Dome Discharge Evaluation. San
Diego, California, February, 1997.

4. U.S. Navy. Pearl Harbor Naval Shipyard. Uniform National Discharge Standards
Information. Pearl Harbor, Hawaii. Memorandum, September 1996.

5. Norfolk Naval Shipyard. Uniform National Discharge Standards Information.
Portsmouth, Virginia. UNDS Questionnaire and Attachments, September 1996.

6. U.S. Navy. Naval Sea Systems Command (SEA 03VB). Tributvl Tin Contaminated
Sonar Dome Water. Arlington, Virginia. Memorandum to SEA 91W4 and SEA 03M, 29
April 1994.

7. Sharpe, Richard. Jane's Fighting Ships. Jane's Information Group, Ltd., 1996-97

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance — Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water

Sonar Dome Discharge
9
-------
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.
i
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Latrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
; • i1 . • ; • ji
Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
1 i " 1 •
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register,?. 15366. March23,1995.
Sonar Dome Discharge
10
-------
Figure 1. SQS-26 Sonar Dome in the Cruiser Belknap (CG 26)
Sonar Dome Discharge
11
-------
Figure 2. SQS-26 Sonar Dome on the Frigate Knox.
Sonar Dome Discharge
12
-------
•• f r i i c
Figure 3. SQS-53 Transducer Housing on a Spruance-Class Destroyer.
Sonar Dome Discharge
13
-------

^^
SfiarVj
.1*Jr"-a. • W „
Figure 4. Spherical, Bow-Mounted Array Housing for the BSY-2 Combat System.
Sonar Dome Discharge
14
-------
Figure 5. Surface Ship Rubber Sonar Dome Prior to Installation.
Sonar Dome Discharge
15
-------
SONAR DOME RUBBER WINDOW
INSIDE COVER
(NO FOUL)
3 - LONGITUDINAL,
PUES
BEAD
ASSEMBLY
FAIRING NUT PLATE
3 - RADIAL PLIES
FAIRING FILL
OUTSIDE COVER
Figure 6. Surface Ship Rubber Sonar Dome Layers.
Sonar Dome Discharge
16
-------
Table 1. Types and Characteristics of Sonar Domes1'2'7
Sonar Type ,
AN/SQS-53
AN/SQS-26
AN/SQS-56
AN/BQQ-5
AN/BQQ-6
AN/BQR-7
AN/BSY-I
EM100
EM1000
EM121A
SEABEAM
TC-12NB
TR-109
Ship Class /.
CG47,DDG51,DD
963, DDG 993
CGN 36, 38
FFG7
SSN 688 (through
750), SSN 637, SSN
671
SSBN 726
SSN 640
SSN 688 (from 751)
MSCT-AGS51
MSC T-AGS 60 (62 &
63)
MSC T-AGS 60
MSC T-AGS 26
MSC T-AGS 60
MSC T-AGS 60
No; of
"Vessels
80
3
43
47
17
2
23
2
2
4
2
4
4
DOH»;<;
' Material
Rubber/TBT
Rubber/TBT
Rubber/TBT
GRP or steel
GRP or steel
GRP or steel
GRP or steel
GRP
GRP
GRP
GRP
GRP
GRP
Dome Water Volume
(gal, appro*.)
24,000
24,000
5,000 *
35,000
74,000
35,000
35,000
N/A*
N/A*
300
511
25
75
Discharge Volume
•per Event (es't,>
30,000
30,000
6,000
35,000
74,000
35,000
35,000
N/A (free flood)
N/A (free flood)
300**
300**
300**
300**
* Filled with seawater
** 300 gallons is representative of the two larger sonar dome types on MSC ships
Table 2. Sonar Dome Materials1'2
&' :,iSj;--;<^mp61i^<^Eonipouo«i'

Tributyltin
Copper-nickel piping
Tin (other than TBT, DBT, MET)
Zinc anodes
Glass-reinforced plastic
Steel components
Epoxy-based paints
Rubber
Antifbuling paint (Cu & other based)
- External to dome
Surface Ships
X

X
X

X
X
Submarines

X
X
X
X
X
Internal to dome
Surface Ships
X
X
X
X
X
X
X
X

Submarines

X
X
X
X
X
X
X

Note: Not all surface ships have TBT internal or external to the sonar dome(s).
Sonar Dome Discharge
17
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Table 3. Ships With TBT-Free Sonar Dome Interiors^
Class
CG 47 Class
DD 963 Class
DDG 51 Class
DDG 993 Class
T-AGS 26, 51, 60 Classes
SSNs&SSBNs
Vessels in Class
CG51,CG73
DD 972, 979, 987
DDG 54, 56-67, 69, 71,74
DDG 993
All
All
Number in Class
2 of 27 ships
3 of 31 ships
16 of 18 ships
1 of 4 ships
8 of 8 ships
89 of 89 vessels
Based on equipment experts and sampling analysis results.
Table 4. Annual Sonar Dome Interior Discharge by Ship Class
1,2,4,5,6
Ship Class
CG47
CGN36
CGN38
DDG 51
DD 963
DDG 993
FFG7
TAGS
SSN637
SSN640
SSN 671
SSN 688
SSBN 726
TOTAL:
Total
Ships
27
2
1
18
31
4
43
8
13
2
1
56
17
223
Ships with
Internal
TBT
25
2
1
3
28
3
20
0
0
0
0
0
0
82
Gallons per
Drainage
Event (est.)
30,000
30,000
30,000
30,000
30,000
30,000
6,000
300
35,000
35,000
35,000
35,000
74,000
N/A
Drainage
Events per
Year
2
2
2
2
2
2
2
2
1
1
1
1
1
N/A
Gallons per Year
(ships with internal
'"TBT*} :-'-'••- :
1,500,000
120,000
60,000
180,000
1,680,000
180,000
240,000
0
0
0
0
0
0
3,960,000
Gallons per
"''••"•' Year
(all vessels)
1,620,000
120,000
60,000
1,080,000
1,860,000
240,000
516,000
4,800
455,000
70,000
35,000
1,960,000
1,258,000
9,278,800
* Could have TBT inside sonar dome, based on Table 6.
N/A « not applicable
Table 5. Tributyltin Release Rates from Exterior of Sonar Domes3
Sampled Vessel
DDG 53 USS John Paul Jones
CG 59 USS Princeton
DD 976 USS Merrill
Average:
Sample Date
12-96
12-96
12-96

Tributyi tie (TBT)
Release Rate
Hg/cm2/day grams/day
0.89
0.06
0.14
036
0.62
0.09
0.10
0.27
Sonar Dome Discharge
18
-------
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Table 7. Estimated Sonar Dome Mass Loadings
Constituent
'^ s
Copper
Nickel
Tin
Zinc
TBT
TBT
DBT
MET
Loading (Ibs/yr)

23.4
11.2
15.0
121.9
2.4
12.6
1.1
0.2
Discharge Origin
External

' Internal
X
X
X
X
X

X
X
Table 8. Comparison of Measured Values in Sonar Dome Interior Discharge
with Water Quality Criteria
Constituent
TBT
Copper
Nickel
Zinc
Mean / Max
Reported
Concentration
74 / 470
303 / 1,630
145 / 660
1,577 / 8,300
Federal
Acute WQC
0.37a
2.4
74
90
^Federal
Chronic WQC
0.01a
2.4
8.2
81
Most Stringent
State Acute WQC
0.001 (VA)
2.4 (CT, MS)
8.3 (FL, GA)
84.6 (WA)
Most Stringent
"State Chronic
: *-WQC '
0.001 (VA)
2.4 (CT, MS)
7.9 (WA)
76.6 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.

CT = Connecticut
FL = Florida
GA = Georgia
MS = Mississippi
VA = Virginia
WA = Washington

a Proposed water quality criteria, August 7, 1997
Sonar Dome Discharge
21
-------
Table 9. Data Sources
NOD Report Section
2. 1 Equipment Description and
Operation
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
32 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
43 Potential for Introducing Non-
Indigenous Species
Data Source
Reported
NavySMMRC*
NavySMMRC*
UNDS Database

Design
Documentation
Naval Shipyards
NRaD San Diego
NRaD San Diego
X

Sampling

Estimated

X
X

Equipment Expert
X
X
X
X
X
X

X
* MRC: Maintenance Requirement Card
Sonar Dome Discharge
22
-------
NATURE OF DISCHARGE REPORT
Steam Condensate
1.0 INTRODUCTION

This section describes steam cqndensate discharge and includes information
equipment that is used and its operation (Section 2.1), general description of the
the discharge (Section 2.2), and the vessels that produce this discharge (Section

2.1 Equipment Description and Operation
on: the
constituents of
2.3).
Many surface ships in the Navy and Military Sealift Command (MSC) use steam from
shore facilities when in port to operate auxiliary systems, such as laundry facilities, heating
systems, and other hotel services.1 Shore steam is piped above ground from land based boiler
plants at pressures between 100 and 150 pounds per square inch (psi) to connections on the pier.
The steam is routed via hoses from pier connections to topside connections on the ships.1 Within
the ship, the steam is routed through the ship's auxiliary steam lines to the equipment. The heat
exchangers and shipboard piping are usually fabricated of copper/nickel alloy and carbon steel,
but can also contain titanium, copper, or nickel. Steam distribution systems on all naval ships
use comparable designs and consistent standards for system materials; therefore, there is little
variation in steam distribution and condensate collection system design between ships. In the
i.;1! ! ••' 'f If ."'i'!"! " • •' '. " • " ' • i '-' r
process of supplying heat to the ship systems, the steam cools and most condenses into water.
This condensed water is referred to as condensate.
.'•'; •!• ' • -• : I
'. ' i ' . • , . I :
The condensate passes through a series of traps and orifices and collects in insulated drain
collection tanks in the lowest points of the machinery spaces. The tanks are usually made of
carbon steel or galvanized carbon steel. When a ship is making its own steam, the condensate in
these drains is recycled as boiler feedwater. When taking on shore steam, this condensate is
discharged overboard because shore facilities do not have infrastructure to receive returned
condensate from ships. The condensate normally is pumped to a topside riser connection for
discharge overboard. The overboard discharge pump is controlled automatically, by means of a
float switch or similar device in the collection tank. In limited cases, the condensate is combined
'-'l*! , , "' i! »'"' 'IEl • ,'i ' :1 ,' ' • ' !"' ,, !'"','!, , ' !• ' • !l i
with non-oily machinery wastewater in the non-oily machinery wastewater drain tank for
discharge overboard below the waterline. Discharge of steam condensate as a component of non-
oily machinery wastewater is discussed in the non-oily machinery wastewater NOD report.

The naval facilities that provide shore steam to ships are designed and operated in
accordance with Navy standards.2 These facilities are required to sample and test shore steam
and provide certification to ships that the steam meets the following requirements:3
pH
conductivity
dissolved silica
hardness
i h ,1;:
total suspended solids
8.0 to 9.5
25 |amho/cm2 max. (micromhos per square centimeter)
0.2 ppm max. (parts per million)
0.10 epm max. (equivalents per million)
0.10 ppm max.
Steam Condensate
2
-------
2.2 Releases to the Environment

Steam condensate discharge can contain metals or treatment chemicals entrained in or
eroded from the shore facilities and ships' steam systems. Steam condensate is discharged at
elevated temperatures relative to the receiving waters. The discharge can be periodic or
continuous based on the condensate flow rate, size of the condensate collection tank, and design
of the collection tank's pumping control system. The discharge occurs 5 to 10 feet above the
waterline. A portion of the condensate flashes into steam when discharged at ambient air
pressure.

2.3 Vessels Producing the Discharge

Currently 179 Armed Forces surface ships discharge steam condensate. The classes and
numbers of Navy and MSC ships that discharge shore-supplied steam condensate overboard are
listed in Table 1. Submarines do not take on shore steam and do not discharge steam condensate
because the design of their steam systems do not provide shore steam connections. The U.S.
Coast Guard (USCG) does not discharge steam condensate because USCG vessels run their
auxiliary boilers on a continuous basis. Also, most USCG homeports do not have readily
available shore steam.1 Army, Air Force, and Marine Corps vessels do not discharge steam
condensate in port.
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Steam condensate is discharged only in port when shore steam is supplied to ships. There
are 179 ships that produce steam condensate discharge located in 10 ports along the coastal U.S.
The larger ships producing this discharge are located in the ports of Norfolk, VA, Mayport, FL,
San Diego, CA, Pearl Harbor, HI, and Everett and Bremerton, WA. In some ports, the ships are
at several locations within the port instead of being centered at one set of piers.

3.2 Rate

The discharge rate of steam condensate is directly related to the amount of shore steam
provided per hour to a ship. Table 2 provides the total estimated heating load for each ship class.
These loads were obtained from a handbook on dockside utilities and reflect the sum of the
constant (year round, such as, galley, laundry, hot water) and intermittent (seasonal) heating
loads for the ship.2 This handbook contains estimated steam load requirements for various ship
classes at 10, 30, 50 and 70 degrees Fahrenheit (°F). For estimating purposes, the condensate

Steam Condensate
3
-------
1 .,1
discharge volumes were based on an average outside air temperature of 50 °F (Table 2). A
survey of meteorological data indicates that the 50 °F data is estimated to represent the average
outside air temperature of most naval ports. Column (b) in Table 2 shows the equivalent number
of gallons per year of condensate discharged at 180 °F that was obtained by applying the
appropriate conversion factors to the figures in Column (a) and multiplying it by the number of
days in port as listed in Table 1 (taken from the Ship Movement Data4) as shown below.
Condensate Drain, gal/yr = (Loads. lbs/hr)(0.12 gal/lb)(24 hr/day)(No. of days in port per year)
Column (c) is obtained by multiplying the figures in Column (b) by the number of ships
in the class. Condensate flow rates for ships where steam requirement data was unavailable were
interpolated based on the ship's size and similarities to other ship classes. Based upon the
calculations presented in Table 2 for an average air temperature of 50 °F, the average steam
cbndensate flow rate for all ship classes is 4,500 gallons per day per ship. As mentioned in
Section 2.2, a small portion of the condensate will flash to steam as it is discharged; however, no
data are available to determine the exact amount of the discharge that is steam. Therefore, to
provide an upper bound on the flow that will enter the water, it is assumed that all of the
discharge will be water.

33 Constituents

Steam condensate is primarily water that contains materials from the shore steam piping,
ship piping, and heat exchangers and boiler water chemicals. This discharge was sampled for
constituents that had a potential for being in the discharge. Based on the steam condensate
process, system designs, and analytical data available, analytes in the metals, organics, and
classicals classes were tested.1*5 Sampling was conducted on the LHD 1, CG 68, LSD 51, and T-
AO 198 in accordance with the Rationale for Discharge Sampling Report.5 The results of the
sampling are provided in reference 6. Table 3 provides a list of all constituents and then-
concentrations that were detected in the discharge. Discharges of steam condensate are expected
to be warmer Sian ambient water temperatures with a maximum overboard discharge temperature
of 180 °F because mis is the maximum operational temperature that condensate discharge pumps
can withstand.

Antimony, arsenic, cadmium, copper, lead, nickel, selenium, thallium, zinc, benzidine
and bis(2-ethylexyl) phthalate are priority pollutants that were detected in this discharge. There
Were no bioaccumulators detected in this discharge.

3.4 Concentrations

The concentrations of detected constituents are presented in Table 3. This table shows
the constituents, the log-normal mean, the frequency of detection for each constituent, the
maximum and minimum concentrations, and the mass loadings for each constituent. For the
purposes of calculating the log-normal mean, a value of one-half the detection limit was used for
npndetected results-
Steam Condensate
4
-------
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. hi Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria.
Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of non-
indigenous species is discussed.

4.1 Mass Loadings

Based on the discharge volume estimates developed in Table 2, mass loadings are
presented in Table 3. Table 4 is present in order to highlight constituents with log-normal mean
concentrations that exceed water quality criteria. A sample calculation of the estimated annual
mass loading for copper is shown here:
Mass Lpading for Copper (Dissolved) ,,?- ,„, ^ *
Mass Loading = (Net Positive Log-normal Mean Concentration)(Flow Rate)
(13^44 Eig/L)(3.7851^31X296,000,000 gal/yr)(g/l,0()0,dOO p.gKHy/453.593 g) & 33 Ibs/yr
4.2 Environmental Concentrations

The constituent concentrations in the steam condensate discharge and their corresponding
Federal and the most stringent state water quality criteria (WQC) are listed in Table 5. The
copper and nickel concentrations exceed the Federal and the most stringent state WQC.
Ammonia, nitrogen (as nitrate/nitrite and total kjeldahl nitrogen), and phosphorous exceeds the
Hawaii WQC. Benzidine and bis(2-ethylhexyl) phthalate exceed the Georgia WQC.

4.3 Thermal Effects

The potential for steam condensate to cause thermal environmental effects was evaluated
by modeling the thermal plume generated by the discharge and then comparing the model results
to state thermal discharge water quality criteria. Thermal plumes from steam condensate
discharge were modeled primarily using the Cornell Mixing Zone Expert System (CORMDC)
model. Additional modeling of discharge plume characteristics was conducted using CH3D, a
three-dimensional hydrodynamic and transport model. The models were used to estimate the
plume size and temperature gradients in receiving water bodies.7'8 Modeling was performed for
discharges from an aircraft carrier (CVN - 68 Class) and an underway replenishment vessel
(AOE-1 Class).

The discharge plumes were modeled for the Navy ports in Norfolk, VA and Bremerton,
WA. Virginia and Washington State are the only states that have established thermal mixing
zone criteria in the form of allowable plume dimensions and ambient temperature increases in the
receiving water body. Other coastal states require thermal mixing zones be established on a case-
Steam Condensate
5
-------
by-case basis during the discharge permitting process, taking into account site- and discharge-
specific information. Typically, criteria are developed to restrict the increase in the ambient
water temperature and the extent of the plume in the water body to limit the duration of exposure
fo^ organisms passing through the plume, to prevent mortalities of bottom-dwelling organisms,
and to prevent long-term effects such as migratory or community changes. State criteria for
Virginia and Washington are summarized in Table 6.
' •:,: ,,'!!'
The Virginia thermal regulations state that the discharge shall not cause the receiving
ambient water temperature to increase by more than 3 °C at the edge of an allowable mixing
zone. Virginia's allowable mixing zone for a thermal plume permits the plume to extend over no
mpre than one-half the width of the receiving watercourse. In addition, the plume shall not
extend downstream a distance greater than five times the width of the receiving watercourse at
the point of discharge.7

The Washington thermal criteria vary depending upon the waterbody classification
established by the State. The water in the vicinity of the Navy port at Bremerton has been
classified by Washington as a Class A waterbody. The State thermal criteria for a Class A
waterbody requires that discharges shall not result in the receiving water temperature exceeding
16 °C at the edge of an allowable mixing zone. If the water temperature exceeds 16 °C due to
natural conditions, no discharge shall raise the receiving water temperature by greater than 0.3 °C
at the edge of an allowable mixing zone. If the water temperature does not exceed 16 °C due to
natural conditions, the Washington criteria provide a formula to determine the allowable
incremental temperature increase at the mixing zone boundary. Washington has established the
mixing zone to permit the plume to extend over a horizontal distance no greater than 200 feet
plus the depth of the water over the discharge point, and no greater than 25% of the width of the
water body.7

The aircraft carrier and amphibious vessel were modeled for Norfolk in winter conditions
because these situations result in the greatest steam condensate discharge. Modeling for
Bremerton was performed for all months of the year because, while cold (i.e., winter) conditions
result in the greatest flow rate, the warm (i.e., summer) conditions result in the lowest allowable
temperature increase.

Based on the CORMIX modeling, steam condensate discharges do not exceed Virginia
thermal mixing zone criteria. CORMIX model predictions do indicate that steam condensate
discharge from an aircraft carrier into the inlet in Bremerton can exceed Washington's thermal
mixing zone criteria. The model predictions indicate that the discharge from AOE-1 Class
vessels are not expected to exceed criteria. The AOE-1 Class is the next largest generator of
steam condensate typically found in Bremerton.
!'.-' ' j
There are several real-world considerations applicable to this discharge that CORMIX is
not designed to simulate. These limitations result in over-conservative predictions. Such
considerations include the effect of tidal action and turbulent mixing beyond the plunge zone (i.e.
area of initial mixing from a discharge above the waterline) on the discharge plume. The
additional mixing from tidal action and turbulence would be expected to reduce plume size. In
Steam Condensate
6
-------
addition, when applied to steam condensate discharge, CORMIX underestimates the initial
mixing that occurs when the discharge enters the water. Since the version of CORMIX used for
this exercise is designed for submerged release, the modeling effort was performed assuming the
discharge hose touches the water surface. The fact that the discharge is known to occur 5-10 feet
above the surface could not be simulated. The result is that the entry velocity assigned by
CORMIX, based on flow rate and discharge pipe diameter, does not reflect accurately the true
entry velocity, which is expected to be greater due to the acceleration from gravity. With higher
entry velocities, the initial mixing would be greater and the plume size would be smaller. To
illustrate, the CORMIX prediction for Bremerton Harbor estimates a plume depth of only 4 cm
based on an initial discharge velocity of 1.67 meters per second (m/s). If the acceleration due to
gravity from a 5-10 foot drop were considered, the entry velocity would increase significantly, to
5.7 m/s. The resulting plume depth would be considerably deeper and would result is more
mixing with receiving water. Another occurrence that the CORMIX model can not simulate is
the loss of heat to the atmosphere, especially during free-fall.

Because of the CORMIX model limitations for this discharge, the Navy and EPA
modeled the steam condensate thermal plume from an aircraft carrier in Bremerton Harbor using
the hydrodynamic and transport model CH3D. CH3D is expected to predict more accurately the
plume dimensions than CORMIX because CH3D simulates the mixing of the buoyant plume
with ambient flows by ways of advection and turbulent mixing both horizontally and vertically in
the water column. CH3D is still expected to provide an overestimate of the plume size because
this model does not account for the full extent of initial mixing hi the plunge zone. CH3D
estimates that the thermal plume for an aircraft carrier moored at the pier at Bremerton would
extend a distance of 80 m from the discharge port along the vessel hull, not extending past the
end of the hull. The plume would also extend outward no more than a distance of 30 m from the
vessel hull at any point along the hull. CH3D predicts that, during the first 24 hours after
discharge, the plume would cover only 5% of the width, 2% of the length, and 0.07% of the total
surface of Sinclair Inlet.

Although the modeling described above indicates that the thermal plume from steam
condensate released from an aircraft carrier may exceed Washington criteria in a small, localized
area, the EPA and Navy do not consider that the plume results hi a significant environmental
impact. Such a localized plume would have a low potential for interfering with the passage of
aquatic organisms in the water body and would have a limited impact on the organisms that
reside in the upper water layer (sea surface boundary layer). In addition, because the discharge is
freshwater (no salinity) and warmer than the receiving water, the plume floats hi the surficial
layer of the water body and has no impact on bottom-dwelling organisms. Therefore, EPA and
DOD do not consider that the thermal loads from steam condensate discharge have the potential
to cause an adverse environmental impact.
Steam Condensate
7
-------
i, M !, WP1 "111I:'.:

' ' ! :.''7i I
4.4 Potential for Introducing Non-Indigenous Species

This discharge does not present the potential for the transport of non-indigenous species
because: the source of the steam is potable water from the same geographic area; it is discharged
in the same vicinity; and it enters the ship as steam above 212 °F.
5.0 CONCLUSIONS
i

Steam cpndensate discharge has a low potential to cause an adverse environmental
impact. This conclusion is based on the following two findings:
,• • • , i
i
1) Although concentrations of copper, nickel, benzidine, bis(2-ethylhexyl) phthalate,
phosphorous, and nitrogen exceed the most stringent water quality criteria, the
mass loadings for these constituents are small. The distribution of the ships
among several ports and within the ports themselves disperses the discharge
(multiple discharge points) into a variety of receiving waters.
2) There are only two states that have established thermal mixing zone criteria in the
form of codified plume dimensions (Washington and Virginia). The thermal
criteria of other coastal states require thermal mixing zones be established on a
case-by-case basis during the permitting process. The discharge is predicted to
meet Virginia and Washington State thermal criteria with the exception of an
aircraft carrier in the port at Bremerton, Washington.. However, conservative
modeling of discharge from an aircraft carrier at Bremerton predicts thermal
plumes that would cover only 5% of the width, 2% of the length, and 0.07% of
the total surface of Sinclair Inlet. Since the plume is restricted to such a localized
area, the EPA and DoD do not consider that the plume results in an adverse
environmental impact and no further analyses are required.
" ,. •' / , "> ' i
6.0 DATA SOURCES AND REFERENCES
-Sl .,!< :. ' . ' • . ... i!
To characterize this discharge, information from various sources was obtained.
Information from a military handbook on dockside services was used to calculate the rate of
discharge. Sampling data from four surface ships provided concentrations, and mass loadings
were calculated from the rate and the concentrations. Table 7 shows the sources of data used to
develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Steam Condensate Drain, September 12,
1996.

2. Military Handbook - 1025/2, Dockside Utilities for Ship Service, 1 May 1988.
Steam Condensate
8

;,,.,,„,: ,::i 11 , i,.,.1. n, Jin i a: I i!.!,i!
*1 ^ •...; ant.! ~i:';i' & ' 11:1.. It n i •..•••: • .'!' .:.
-------
3. Naval Ship's Technical Manual (NSTM), Chapter 220, Vol. 2, Revision 7, Boiler
Water/Feed Water Test & Treatment, pp 22-6, 22-7, and 22-50. December 1995.

4. Pentagon Ship Movement Data for Years 1991-1995, March 4,1997.

5. UNDS Rationale for Discharge Sampling, Undated.

6. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

7. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed
Services. Versar, Inc. July 3,1997.
8. NAVSEA. Supplemental Thermal Effects Analysis. March 1999.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.
Steam Condensate
9
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New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
.; :i •» '• • ..• I!'
Texas. Texas Surface Water Quah'ty Standards, Sections 307.2-307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
j., i!1"! ,i' ! ' • ,;,,••" i. "
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260,
i „ • . i , '" , j i
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
, . . , . • f.
Baumeister, Theodore; Avallone, Eugene; Baumeister JJJ, Theodore; Marks' Standard Handbook
for Mechanical Engineers, Eighth Edition. McGraw-Hill Book Company, 1978..
;; | .'II • • | ",ij I
Rawson, K.J.; and E.G. Tupper. Basic Ship Theory 2, Second Edition, Longman Group London
and New York. 1978.
;•; , • ' |"
Jane's Information Group, Jane's Fighting Ships. Capt. Richard Sharpe, Ed. Sentinel House:
Surrey, United Kingdom, 1996.

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the .
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. 23 March 1995.

Summary of Meteorological Data to Determine Air and Water Temperatures, October 1997.

UNDS Ship Database, August 1,1997.
Steam Condensate
10
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Table 1. Vessel Classes Generating Steam Condensate Discharge
VESSEL -
r CLASS
CVN68
CV63
CVN65
CV59
CG47
CGN38
CGN36
DDG 993
DD963
AGF11
AGF3
LCC19
LHD1
LHA1
LPH2
LPD4
LSD 49
LSD 41
LSD 36
MCM1
T-AE26
T-AFS1
AO177
T-AO 187
AOE1
AOE6
T-AG 194
T-AGM 22
T-ARC7
ARS50
T-AH19
AS 33
AS 39
-r VESSEL DESCRIPTION -%
*. /ji
Nimitz Class Aircraft Carriers
Kitty Hawk Class Aircraft Carriers
Enterprise Class Aircraft Carriers
Forrestal Class Aircraft Carriers
Ticonderoga Class Guided Missile Cruisers
Virginia Class Guided Missile Cruiser
California Class Guided Missile Cruisers
Kidd Class Guided Missile Destroyers
Spruance Class Destroyers
Austin Class Miscellaneous Command Ship
Raleigh Class Miscellaneous Command Ship
Blue Ridge Class Amphibious Command Ship
Wasp Class Amphibious Assault Ship
Tarawa Class Amphibious Assault Ship
Iwo Jima Class Amphibious Assault Ship
Austin Class Amphibious Transport Docks
Harpers Ferry Class Dock Landing Ships
Whidbey Island Class Dock Landing Ships
Anchorage Class Dock Landing Ships
Avenger Class Mine Countermeasures Vessels
Kilauea Class Ammunition Ships
Mars Class Combat Stores Ships
Jumboised Cimarron Class Oilers
Henry J. Kaiser Class Oilers
Sacramento Class Fast Combat Support Ships
Supply Class Fast Combat Support Ships
Mission Class Navigation Research Ships
Compass Island Class Missile Range Instrumentation Ships
Zeus Class Cable Repairing Ships
Safeguard Class Salvage Ships
Mercy Class Hospital Ships
Simon Lake Class Submarine Tenders
Emory S Land Class Submarine Tenders
QUANTITY OF
VESSELS PER
_ CLASS
7
3
1
1
27
1
2
4
31
1
1
2
4
5
2
3
3
8
5
14
8
8
5
12
4
3
2
1
1
4
2
1
3
NUMBER OF>
DAYS m PORT
PER YEAR
147
137
76
143
166
161
143
175
178
183
183
179
185
173
186
178
170
170
215
232
26
148
188
78
183
114
151
133
8
208
184
229
293
Notes:
Number of days inport per year for each ship class taken from the Ship Movement Database.
Vessel classes receiving shore steam are identified in Military Handbook 1025/2, Dockside Utilities for Ship
Service.
Steam Condensate
11
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Table 2. Steam Condensate Discharge By Vessel Class At Outdoor Temperatures of 50 Degrees F
VESSEL CLASS
CVN68
CV63
CVN65
CV59
CO 47
CGN38
CON 36
DDG993
DD963
AGF11
AGF3
LCC19
LHD1
LHA1
LPH2
LPD4
LSD 49
LSD 41
LSD 36
MCM1
T-AE26
T-AFS1
AO177
T-AO 187
AOE1
AOE6
T-AG 194
T-AGM 22
T-ARC7
ARS50
T-AH19
AS 33
AS 39
ACTIVE
7
3
1
1
27
1
2
4
31
1
1
2
4
5
2
3
3
8
5
14
8
8
5
12
4
3
2
1
1
4
2
1
3
(a)
Total Heating Load in
Ibs/hr per vessel
15,000
13,000
15,000
13,000
1,100
3,400
3,400
1,800
1,800
2,650
2,650
7,700
6,300
6,300
5,800
4,400
3,600
3,600
3,600
1,000
2,300
3,350
3,350
3,350
5,600
5,600
1,500
2,700
2,700
500
500
6,500
6,500
o»
Condensate Drain in
galfons/yr per vessel
6,582,090
5,316,418
3,402,985
5,549,254
545,075
1,634,030
1,451,343
940,299
956,418
1,447,612
1,447,612
4,114,328
3,479,104
3,253,433
3,220,299
2,337,910
1,826,866
1,826,866
2,310,448
692,537
178,507
1,480,000
1,880,000
780,000
3,059,104
1,905,672
676,119
1,071,940
64,478
310,448
274,627
4,443,284
5,685,075
.: •
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Table 3. Summary of Detected Analytes
Constituent
*>•
CLASSICALS,
Alkalinity
Ammonia as Nitrogen
Biochemical Oxygen Demand
Chemical Oxygen Demand
(COD)
Chloride
Nitrate/Nitrite
Sulfate
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (TOC)
Total Phosphorous
Total Recoverable Oil and
Grease
Total Sulfide (lodometric)
Volatile Residue
MEli&S -
Antimony
Total
Arsenic
Total
Barium
Dissolved
Total
Cadmium
Total
Calcium
Dissolved
Total
Copper
Dissolved
Total
Iron
Dissolved
Total
Lead
Dissolved
Total
Magnesium
Dissolved
Total
JLog Normal,
Mean> ;
'• -.

3
2

243
359

33
49

49
56

9
11

192
190
Steam Condensate
13
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Constituent
METALS
Manganese
Dissolved
Total
Molybenum
Dissolved
Nickel
Dissolved
Total
Selenium
Total
Sodium
Dissolved
Total
Thallium
Dissolved
Titanium
Total
Vanadium
Dissolved
Zinc
Dissolved
Total
ORGANICS
4-Chloro-3-Methylphenol
Benzidine
Bis(2-Ethylhexyl) Phthalate
Log Normal
Mean
(Hg/L)

1.17
2.57

1.72

10.3
11.6

2.87

482
432

1.18

2.73

5.25

13.94
11.35
(ug/L)
6.84
32.8
19.4
Frequency of
Detection

2 of 4
4 of 4

Iof4

Iof4
Iof4

Iof4

3 of 4
2 of 4

2 of 4

Iof4

4 of 4
3 of 4

Iof4
Iof4
2 of 4
Minimum
Concentration
(wg/L)

BDL
1.85

BDL

BDL
BDL

BDL

BDL
BDL

BDL

7.15
BDL
(Ug/L)
BDL
BDL
BDL
Maximum
Concentration
(ug/L)

6
5.1

3.7

22
34.7

3.5

8220
8280

13.3

6.4

10.5

21.9
23.0
(Ug/D
30
73.5
112
Mass
Loading
(Ibs/yr)

3
6

25
28

1,188
1,065

34
28
(Ibs/yr)
17
81
48
BDL s Below Detection Limit
Log-nonnal means were calculated using measured analyte concentrations. When a sample set contained one or
more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations
equivalent to one-half of the detection levels were also used to calculate the log-normal mean. For example, if a
"non-detect" sample was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log-
normal mean calculation.
Steam Condensate
14
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Table 4. Estimated Annual Mass Loadings of Constituents
Constituent* < \
CLASSICALS
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen^
Total Phosphorous
0RGAMCS
Benzidine
Bis(2-Ethylhexyl) Phthalate
METALS~
Copper
Dissolved
Total
Nickel
Dissolved
Total
Log Normal
n Mean
- Cmg/L)
0.18
0.44
0.80
1.24
0.09
(MS/L)
32.8
19.4
(W5/L).

13.4
20.1

10.3 .
11.6
; Frequency of"
„ Detection

4 of 4
4 of 4
4 of 4

3 of 4
-
Iof4
2 of 4

2 of 4
3 of 4

Iof4
Iof4
Minimum
Concentration
(mg/Ll '
0.12
0.3
0.24

BDL
^(Pg/t)
BDL
BDL
< (MS/L) .

BDL
BDL

BDL
BDL
Maximum
Concentration
- ' (mg/L) s
0.37
0.81
2

0.27
(^g^L)
73.5
112
' (»e/L)'

49.0
91.0

22
34.7
. Mass
Loading
.Qbsfy& ;
444
1085
1972
3057
222
(Mim^-
81
48
, (Ibs/yr)

33
49

25
28
* Mass loadings are presented for constituents that exceed WQC. See Table 3 for a complete listing of mass
loadings.
A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Steam Condensate
15
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Table 5. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituent
Ammonia as
Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen8
Total Phosphorous
Benzidine
Bis(2-Ethylhexyl)
Phthalate
Copper
Dissolved
Total
Nickel
Dissolved
Total
Log-normal
Mean
(ug/L)
180
440
800
1240
90
32.8
19.4

13.4
20.1

10.3
11.6
Minimum
Concentration
(ug/L)
120
300
24

BDL
BDL
BDL

BDL
BDL

BDL
BDL
Maximum
Concentration
(Mg/L)
370
810
2000

270
73.5
112

49.0
91.0

22
34.7
Federal
Chronic WQC
(HS/L)
None
None
None
None
None
None
None

2.4
2.9

8.2
8.3
Most Stringent State
Chronic WQC
(U8/L)
6(HI)A
8(HI)A
-
200 (ffl)A
25 (HI)A
0.000535 (GA)
5.92 (GA)

2.4 (CT, MS)
2.9 (GA, FL)

8.2 (CA, CT)
7.9 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR131.36 (57 FR 60848; Dec. 22,
1992 and 60 FIl 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
j j|
CA =» California
CT = Connecticut
FL» Florida
GA s Georgia
HI - Hawaii
MS = Mississippi
WA - Washington
BDL = Below Detection Limit
Steam Condensate
16
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Table 6. Summary of Thermal Effects of Steam Condensate Discharge
Ships
Modeled
Discharge
Temp
(°F>-
Average
Air Temp
('FT;.
Discharge
'flow
(gallons per
• hour)
Aimbient
Winter'
Water
Temp TO'
Predicted
Plume Length
v (*»)
Allowable
-Plume x
'Length (m).
Predicted
Plume~^ v
Width (mf
Allowable
Plume Width
* ,>)
v Washington State (1.5°C AT) - -
CVN*
AOE
180
180
50
50
1,866
672
-*" „ „ -5 Vir
CVN
LCC
212
212
40
40
2,207
1,007
50
50
80
2.3
73
73
30
10**
400
400
pma(3,0°CAT) ' \ , „ : ;
40
40
689
180
32,000
32,000
203
70.1
3,200
3,200
Note: Flow rates for Virginia were calculated based on a linear interpolation of the data available
in reference 2 for 30°F and 50°F air temperature.
*Indicates CH3D model predictions after the first 24 hours after discharge. All other
predictions are based on CORMIX model results.
**CORMIX output displays the plume width to the point where AT s 0°C.
Table?. Data Sources
,
NOD Section
2.1 Equipment Description and
Operation - " _
•2.2 Releases to the Environment" -
2.3' Vessels Producing the Discharge
3.1 Locality
3.2 Rate ^
3.3 Constituents
'3.4 Concentrations •*•'-.
4.1 Mass Loadings - -
4.2 Environmental Concentrations
4.3 Thermal Effects
4.4 Potential for Introducing Non-
Indigenous Species
, Data Sources'. ?v - •
Reported,'

UNDS Database

Sampling

X
X

Estimated

. Equipment Expert
X
X
X
X
X

X
X
Steam Condensate
17
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NATURE OF DISCHARGE REPORT
Stern Tube Seals & Underwater Bearing Lubrication ^ / >,./
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed hi three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

This section describes the stem tube seals and underwater bearing lubrication discharge
arid includes information on: the equipment that is used and its operation (Section 2.1), general
description of the constituents of the discharge (Section 2.2), and the vessels that produce this
discharge (Section 2.3).

2.1 Equipment Description and Operation
, ! , , . • , . . . • . I, I ,
Vessels of the Armed Forces have one or two propeller shafts, except for aircraft carriers,
which have four sSafts. Stern tube seals, stem tube bearings, and intermediate and mam strut
bearings are components associated with the propeller shaft. Figure 1 shows the location of these
components. The stem tube seals prevent seawater entry into the vessel at the inboard end of the
stem tube bearing. Stern tube bearings support the weight of the propeller shaft where the shaft
exits the vessel. Intermediate and main strut bearings are outboard bearings that support the
weight of the propeller and shafting outboard of the vessel. Submarines do not have strut
bearings. Instead, submarines have a self-aligning bearing aft of the stern tube that supports the
weight of the propeller. Both stern tube and strut bearings are constructed with a bronze backing,
and lined with rubber strips (called staves), or babbitt metal. Babbitt is an alloy of tin and lead
and is commonly used as a bearing material. However, babbitted bearings are oil lubricated and
the lube oil is circulated in a closed system with no discharge to the environment. Babbitt wear
material is collected in the oil filter of stern tube oil lubricated systems. Depending on the vessel
type, lubrication for the stern tube seals, stern tube, and strut bearings is accomplished by
seawater, freshwater, or oil.1

Some small boats and crafts use surrounding seawater for cooling and a greased bearing
for lubrication. As such, the surrounding seawater is at a greater pressure than the greased
bearing on small boats, and if there is any leakage, seawater will leak into the bilge of the small
boat instead of the grease being discharged to the surrounding seawater. Any grease released into
the bilge of small boats and crafts is discussed in the Surface Vessel Bilgewater/OWS Discharge
NOD report.

2.1.1 Seawater Lubrication

Seawater lubrication is used hi all Navy and U.S. Coast Guard (USCG) vessels. Seawater
iS supplied from either the firemain or auxiliary machinery cooling water system on surface ships
and is supplied from the auxiliary seawater system on submarines. Submarines flood their trim
tanks with seawater and use this water to cool and lubricate the stern tube seals while in port.
For all surface ships and submarines, seawater enters a seal cavity, where some of it is used to
lubricate the seal faces. The remainder passes aft through channels between staves in the stern
tube bearing, cooling and lubricating the bearing, and finally exiting to the sea at the aft end of
the bearing. Seawater flow through the stem tube bearing is maintained at all times, except when
conducting maintenance or disassembly, regardless of whether the vessel is in port or underway.
The residence time of the seawater flow is short. For example, the residence time of water in the
stem tube of a'DDG 51 Class ship is approximately 13 seconds.2 Similar short residence times
Stern Tube Seals & Underwater Bearing Lubrication
2
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for stern tube lubricating water on other vessel classes is expected. Strut bearings are not
provided with forced cooling or lubrication. Instead, strut bearings use the surrounding seawater
flow for lubrication and cooling when the vessel is underway.

On surface vessels, copper-nickel alloy (70% copper/30% nickel) piping is normally used
for the stern tube seal lubrication system. On submarines, nickel/chromium piping is used. The
lubricating seawater also comes into contact with the propeller shaft, bearing surfaces, zinc
anodes, bearing staves, the seals, and bearing bushings.

Shafts are made of forged steel. Bearing surfaces are sleeved with copper-nickel (80%
copper / 20% nickel) or fiberglass. Zinc anodes provide corrosion protection hi the bearing
housings. Stern tube and strut bearing staves are made of bonded synthetic rubber (typically
Buna-N (nitrile)). The estimated life of the staves is 5 to 7 years. Although the staves surround
the shaft on all sides, the bottom staves (approximately 40% of the staves) support the shaft
weight and are susceptible to maximum wear. In submarines, the wear rate of the rubber is
approximately 10 to 20 mils (one mil equals 0.001 inch) per year. In surface vessels with
controllable pitch propellers, the wear rate is 40 mils per year, and in surface vessels with fixed
pitch propellers, the wear rate is 20 to 30 mils per year.3

The rotating seat of a typical stern tube seal on a surface vessel is made of phosphor
bronze (an alloy of bronze and phosphorous). The stationary face insert was originally made of
Teflon-impregnated asbestos. However, a majority of the asbestos components have been
replaced with a phenolic material.1 Seals used in submarines are comprised of silicon carbide
and carbon graphite because they are exposed to more severe operating conditions. The life of
stern tube seals is approximately 5 years and they have a very small area exposed to wear,
compared to the bearings. Therefore, wear products from seal components constitute a very
small percentage of this discharge.

The lubricated components of a propeller shaft are shown in Figure 1. A cross-section
diagram of a typical seal is provided as Figure 2.

2.1.2 Freshwater Lubrication

On very rare occasions in port, freshwater may be used for lubricating me shaft seal on
submarines. This occurs on approximately four submarines per year, for one week each.4
Normally, while a submarine is in port, shaft seal lubrication is provided from seawater stored in
the submarine's trim system. After an extended in port period, this supply of seawater will
eventually become depleted. At that time, freshwater is used to fill the trim system to provide
shaft seal lubrication. On these occasions, a potable water fill hose from the pier is connected to
the trim tank. This freshwater is typically mixed with the residual seawater in the tank (estimated
at a 50% mixture of seawater and freshwater), and is used for lubricating the shaft seals. The
cooling water is discharged to the sea in the manner described in Section 2.1.1.
Stern Tube Seals & Underwater Bearing Lubrication
3
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2.1.3 Ambient Water Lubrication

All Army watercraft use ambient water for lubrication of stern tube seals and underwater
bearings. Ambient water, either freshwater or saltwater, is used in all operational locations,
depending upon where the vessel is located (i.e., in fresh or saltwater). Army watercraft do not
use potable water for lubrication while hi port and do not use pressurized water to force feed
underwater bearings.

2.1.4 Oil Lubrication
I
A number of Military Sealift Command (MSC) vessels are fitted with oil-lubricated stern
tube and strut bearings, which do not produce any of the discharge described in this report. Oil-
lubricated seals exist in a variety of configurations. All have anti-pollution design features, that
prevent oil from leaking to the sea under normal operating conditions.5 On the T-AO 187 Class
ships, each of the two shaft systems contains 2,300 gallons of oil. Some common system design
features to prevent oil releases are:1
I:!' : « •• ' ' ' . i, (i
• Use of 'multiple sealing rings at both the inboard and outboard ends of the stern tube.
• Methods to maintain pressure in the stern tube cavity lower than the sea water pressure
outside. This ensures that, in the event that the outboard seal leaks, water will leak into
the cavity rather than oil leaking out. Any water which accumulates as a result of a leak
into the cavity is managed as Surface Vessel Bilgewater/OWS Discharge.
• Positive methods for determining seal leakage.

2.2 Releases to the Environment

For surface vessels, this discharge consists of seawater from the firemain system or
auxiliary machinery water cooling water system with the additional constituents described in
Section 2.1 that are entrained as the seawater flows through the system. The lubricating water is
released to the environment through the after end of the stern tube bearing. In the case of
submarines, the discharge will occasionally consist of freshwater with chlorine.

2.3 Vessels Producing the Discharge
. : , 1 . . ;l . • i i
r
Almost all classes of surface vessels and submarines of the Armed Forces have shaft seals
and bearings that require lubrication. The exceptions are a few vessel classes such as the MHC
51 Class, mat use unconventional means of propulsion such as cycloidal propellers.1 Army
\Vatercraft use packing rings to seal hull penetrations of the shaft and do not use mechanical seals
for this purpose.
Stern Tube Seals & Underwater Bearing Lubrication
4
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3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

Flow of water through the shaft seals and stern tube bearings is maintained at all times.
Therefore, this discharge occurs both within and beyond 12 nautical miles (n.m.).

3.2 Rate

3.2.1 Seawater Lubrication

For surface ships, flow rates of seawater through the stern tube bearing are approximately
2 gallons per minute (gpm) per foot of bearing length and 3 gpm for seal lubrication. The
seawater flow rate through submarine shaft seals while underway is 16 gpm for SSN 688 Class
and 18 gpm for SSBN 726 Class submarines. A discharge of 10 to 20 gpm per shaft is typical for
most vessels.1 For purposes of this report, a flow rate of 20 gpm has been used. It was assumed
that there are 274 surface ships, each with two shafts and 89 submarines, each with one shaft.
Based on operational knowledge, 5% of the vessels' underway time is spent within 12 n.m. and
50% of the vessels' time is spent pierside.6 These are conservative estimates, because most
vessels have flow rates that are lower than 20 gpm and though there are 24 four-shaft vessels in
the Navy, there are 65 single-shaft vessels that were considered to be two-shaft vessels. Thus,
this analysis overestimates the number of shafts producing this discharge by 17. When surface
ships are idle in port, full water flow is maintained through the stern tube bearing and seals. The
total annual fleetwide discharge volume was calculated as follows:
Total fleetwide annual discharge (gallons/year) = (20 gallo^ -!
hr/day) (365 days/year) [(274 surface ships) (2 shafts/ship) -fc (89 submarines) (1 shaft per
submarine)] (0.55 (5% ojf vessel's underway time is within I2jpum. and 50% of vessels' time is in
port)) = 3,682,879,200 gal/year - . , \ . ,->
3.2.2 Freshwater Lubrication

When submarines are idle in port, flow is maintained at 4 gpm for attack submarines (e.g.
SSN 688 Class) and 9 gpm for Missile Submarines (e.g. SSBN 726 Class).3'7 Approximately
81% of active submarines are attack submarines (SSNs) and 19% are ballistic missile submarines
(SSBNs). Hence, the weighted freshwater flow rate per submarine is approximately (0.81)(4
gpm) + (0.19)(9 gpm) « 5 gpm.
Stern Tube Seals & Underwater Bearing Lubrication
5
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Tptal'.fleetwide annual discharge (gallons/year) = (5 gallons/minute flow rate) (60 min/hr) (24
hr/day)''(?' days)year) (1 week per year) [(4 submarines) (1 shaft per submarine)] =201,600
3.3 Constituents
i; -j , • , • • \
3.3.1 Seawater Lubrication
„ "' 'j.i • •, , ,. I i
Seawater for lubrication of stern tube bearings is supplied either from the firemain or the
auxiliary seawater cooling main, depending on the vessel class. Additional information on
firemain systems and the seawater cooling system can be found hi their respective NOD reports.

When the shaft is turning, the most likely constituent to be present in the discharge is
rubber. Metals, if any, can be present hi the discharge and include copper and nickel, the
materials of construction of the stem tube. The priority pollutants in this discharge include
copper and nickel. None of the potential constituents in this discharge are bioaccumulators.

33.2 Freshwater Lubrication

Because the shaft is not turning under idle conditions, there is no wearing of the bearing
materials. The freshwater from the port facility is typically chlorinated for disinfection.
Therefore, the discharge could contain small amounts of chlorine plus the same priority
pollutants listed in" Section 3.3.1. None of the potential constituents are bioaccumulators.

3.4 Concentrations

Firemain and freshwater are used to lubricate stem tube seals and bearings. The
lubricating water briefly contacts the bearings and seals when compared to the rest of the
firemain; the firemain piping system is much longer than the length of the stern tubes (5.5 feet
each) and hence the residence tune of seawater hi the firemain system is much greater than the 13
second residence tune hi the stern tube seal and bearing lubrication system of a typical surface
vessel. Freshwater data were also used.

3.4.1 Seawater Lubrication
ii
The concentrations of the constituents, as shown hi Table 2, were estimated using
corrosion rates for the materials of construction, the surface area of the materials exposed to
seawater, and the rate of seawater lubricating the stern tube.2
' ' '' , , ' ' ' ' I :
3.4.2 Freshwater Lubrication

Water treatment plants typically add sufficient chlorine or monochloramine so that the
finished water leaving the plant has a total residual chlorine (TRC) level of approximately 2.0
mg/L.8 As water flows through the distribution system, TRC is depleted through its bactericidal
action and due to reactions with other chemicals hi the water and on piping and other surfaces.
• , • ••. i, •• i
Stern Tube Seals & Underwater Bearing Lubrication
-------
By the time the water reaches the tap, TRC levels have been reduced to approximately 1.0 mg/L.
After water is taken aboard a submarine into the trim tank and before its discharge after being
used as a stem tube seal lubricant, several factors cause the TRC level to continue to decline. For
example, the TRC-containing freshwater is mixed with the seawater that remains in the trim tank
and as a result, is diluted by about 50% based on the fact that trim tanks are about 50% full of
seawater while pierside. This results in an immediate reduction of the TRC concentration to
approximately 0.5 mg/L. In addition, organic matter in the residual seawater in the trim tank will
cause further rapid depletion of TRC levels. Although not measured specifically, the amount of
TRC in the trim tank water used to lubricate the shaft seal is likely to be at least as low as the
levels measured in the freshwater used to layup condensers in submarines. TRC levels in such
systems were reduced from 1.2 mg/L to 0.028 mg/L in two hours. Please refer to the Freshwater
Layup NOD report for additional information. Using the average flow rate from the trim tank, it
requires approximately 17 hours to drain the trim tank.

The estimated contributions of the freshwater lubrication process to the discharge are
unknown but thought to be minor. This is because the shaft is not turning while pierside so there
is no bearing wear. In addition, the lubricating water only contacts the lubrication system
components for a short period of time because of the constant flow of water from the trim tank,
through the bearing, and then to the sea. For a typical surface ship (DDG 51 Class) the residence
time of water in the stem tube is approximately 13 seconds2 and similar residence times for stem
tubes on other vessel classes is expected. With residence times of this order, there is little time to
accumulate erosion or corrosion products from the bearing lubrication system materials of
construction.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

4.1.1 Seawater Lubrication

An estimate of the rubber discharge was made based on data for DDG 51 Class vessels.
The DDG 51 Class was chosen because it is a mid-size vessel with a significant population in the
fleet. The available data includes:
Bearing Length
Number of Staves
Stave Width
Stern Tube
66 inches
26
3.18 inches
Strut
96 inches
26
3.18 inches
Stern Tube Seals & Underwater Bearing Lubrication
7
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Using this data, the total length of rubber material exposed to wear was calculated to be 351 feet
per shaft by the equation:
((66 inches + 96 inches) bearing length per shaft) (26 staves per shaft)/(12 inches per foot)
= 351 feet of bearing material per shaft -
DDG 51 Class ships have two shafts; therefore, the total length of bearing material per
ship is 702 feet. Because DDG 51 Class ships have controllable pitch propellers, a wear rate of
40 mils (0.04 inch) on each stave occurs per year. Approximately 40% of the staves carry the
weight of the shafting and thus are subjected to this wear rate. The total volume of rubber that is
worn annually from the staves per ship was calculated as follows:
Volume of Rubber Per Ship = (702 feet of rubber) (3.18 inches/(12 inches/foot) width of staves)
(0.04 inch/(12 inches/foot) wear depth) (0.4 percentage of staves subject to wear) = 0.25 cubic
feet ' " '"•"'•; :" '.*'' '"*'" "".V;''*':.;-r: :" :".'•*-'"
The density of Buna-N (nitrile) rubber is 61.8 pounds per cubic feet (lbs/ft3). Therefore,
15.4 pounds [(61.8 lbs/ft3) (0.25 ft3)] of rubber are contained in the discharge from each ship
annually. Based upon the assumptions described in Section 3.2.1, ships spend approximately 5%
of their underway time within 12 n.m.6 Thus, 0.76 pound of rubber is discharged by each vessel
within 12 n.ml Bearing wear does not occur while the vessel is alongside the pier or at anchor
because the shafts are not turning.
•I' , ' i , , if '
Using 0.76 pound of rubber as an average for each surface ship and 0.38 pound for each
submarine (due to the single shaft configuration of submarines), the total annual mass loading for
274 ships (excluding boats and crafts) and 89 submarines was calculated by the equation:
Total Annual Mass Loading of Rubber = (0.76 pound/ship) (274 ships) H- (0.38
fKJirnd/submanne) (89 submarines) = 242 pounds •'"•''"' ' ; ' •
'i T i • II ' " ' II I '
A total of 242 pounds of rubber is discharged annually for all vessels. This is a
conservative estimate because many vessels have a wear rate of less than 40 mils per year and
many surface vessels do not have two shafts.

Concentrations of rubber were then calculated as follows:
Concentration of rubber hi mg/liter = (242 pounds per year) (453,600 rag/pound) / [(334,807,200
gallons per year) (3.785 liters/gallon)] = 0.09 mg/liter
The total annual mass loadings for the metal constituents of seawater lubrication was
calculated based on materials of construction in the stern tube, corrosion rates for those materials,
and the surface area of the material exposed to seawater for a DDG 51 Class ship. The material
Stern Tube Seals & Underwater Bearing Lubrication
8
-------
of construction is a copper-nickel alloy (80% copper and 20% nickel). The available data
includes2:

Surface area exposed to seawater = 7,254 square inches (in2)
Corrosion rate of copper nickel = 7.0 micrometers per year (um/yr)
Density of copper nickel = 8.9 x 106 grams per meter cubed (g/m3)
Total Annual Mass Loading of Copper and Nickel = (corrdsion rate) (density) (area) (percent of
time within 12 n>m.) -160.4 grams per year - * ' - ~-
Based on these analyses, one DDG 51 stern tube has the potential to discharge 128.3 grams or
0.28 pound of copper and 32.1 grams or 0.07 pound of nickel annually within 12 n.m. of shore.
Applying this estimate to all vessels of the Armed Forces results in a total annual mass loading of
180 pounds of copper and 45 pounds of nickel.

4.1.2 Freshwater Lubrication

The weighted average of the freshwater flow rate to the stern tube bearings on a
submarine is approximately 5 gallons per minute (19 liters per minute) when the submarine is
idle hi port. Assuming a 1.0 mg/L TRC concentration in the freshwater (see Section 3.4.2) and
that the freshwater will be diluted by an equal amount of seawater remaining in the trim tank
when the freshwater is added, the TRC mass loading per submarine per day was calculated by the
equation:
TRC Mass Loading = (Freshwater flow rate) (TRC concentration) ^Dilution factor) = (19, L/min)
(OJ)01grams/L)(50%)(60ffiin/to^ "<
-13.7grams TRC per day'per submarine ,. - -
Because submarines rarely use freshwater to lubricate the shaft seal, it is assumed that
there are four submarines that use this method annually for shaft seal lubrication and each for a
total of one week. Based on the assumptions in Section 2.1.2, the total annual TRC mass loading
for submarines was calculated by the equation:
Annual TRC Mass Loading = (13.7 grams TRC/day/sub),(7 days/year) (4 subs) = 383 grams
TRC/year = 0.383 kg TRC/yr = 0.84 pounds TRC/yr 7
The estimated mass loadings for this discharge are provided in Table 1.

4.2 Environmental Concentrations

Table 2 shows the concentration of the priority pollutants that are present in the discharge
from seawater-lubricated bearings compared to acute water quality criteria (WQC). Only copper
exceeds water quality criteria. — The concentration of copper is derived from corrosion rates for
copper, the surface area of the material exposed to seawater, and the rate of seawater lubricating
the stern tube.
Stern Tube Seals & Underwater Bearing Lubrication
9
-------
i : .; . i '.'•'. , „'-,:, 11 ; • •
The freshwater lubrication discharge from submarines consists of freshwater that could
have low concentrations of TRC. Although not measured specifically, the amount of TRC in the
trim tank water used to lubricate the shaft seal is likely to be at least as low as the levels
nlieasured in the freshwater used to lay up boilers and condensers in submarines. TRC levels in
such systems were reduced from 1.2 mg/L to 0.028 mg/L in two hours.
i!"
The rubber staves are abraded during the shaft rotation into small particles that do not
dissolve, are relatively inert, and hence are largely not bioavailable.

4.3 Potential for Introducing Non-Indigenous Species
! . . .' j]
The transport of non-indigenous species is not a concern for this discharge because the
flow through the shaft seals is continuous, the residence time of seawater is 13 seconds for a
DbG 51 Class ship, and the seawater is not held on board for this purpose; therefore, there is
little opportunity to transfer non-indigenous species. Similar residence times are expected for all
other vessel classes.
5.0 CONCLUSIONS
I
The constituents in stern tube seal and underwater bearing lubrication have a low
potential to cause an adverse environmental effect because:
1 I- ' ..'• I!
1) Oil lubricated stem tube seals and bearings cannot release oil to the environment under
normal ship operations.

2) For seawater lubricated stem tube seals and bearings, there is very little contribution of
constituents to the seawater lubrication fluid from the stern tube seal system, other than
rubber, copper, and nickel because of the very short time that the fluid is in contact with
the stem tube seal system. Rubber is released to the environment because the rubber
bearing staves wear. Copper and nickel are introduced because they are materials of
construction of the stern tube. While copper concentrations can exceed chronic WQC,
the mass loadings are not considered sufficient to pose an adverse environmental effect.

3) Freshwater lubricated stern tube seals and bearings are used only on submarines and only
rarely (estimated to be four submarines, each for one week per year) when the seawater in
the trim tanks normally used for lubrication is exhausted. The freshwater lubrication
discharge TRC concentration is expected to be as least as low as the levels measured in
the freshwater used to lay up condensers hi submarines.
6.0 DATA SOURCES AND REFERENCES
"' ' i
To characterize this discharge, information from various sources was obtained. Table 3
shows the sources of data used to develop this NOD report.
;i, |i •
Stem Tube Seals & Underwater Bearing Lubrication
10
liiiitlii J Bill ' ].
-------
Specific References

1. HMDS Equipment Expert Meeting Minutes - Shaft Seal Lube/Stern Tube
Seals/Underwater Bearing Lubrication. September 10,1996.

2. Personal Communication Between Miles Kikuta (MR&S) and David Kopack (SEA GOT)
and Gordon Smith (SEA 03L). December 11,1998.

3. Personal Communication Between George Stewart (MR&S) and Sanjay Chandra
(Versar). April 25,1997.

4. Personal Communication between Bruce Miller (MR&S) and LCDR Warren Jederberg,
Submarine Force, Pacific Environmental Officer of 15 October, 1997.

5. Personal Communication Between George Stewart (MR&S) and Sanjay Chandra
(Versar). March 14,1997.

6. UNDS Ship Database, August 1,1997.

7. Commander Submarine Force, U.S. Atlantic Fleet Letter 5090 Serial N451A/4270 of 13
December 1996 in Response to UNDS Data Call.
8. American Water Works Association. Optimizing Chloramine Treatment. AWWA
Research Foundation, 1993.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. 62, Number 150. August 5,1997.
Stern Tube Seals & Underwater Bearing Lubrication
11
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Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Qualify Standards Effective April 8,1997.
,1 ,i . I. i
Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.
V ,;:| ' , !;_ I, :
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii, Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.
j
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).
I
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, pg 15366. March 23,1995.
•„!'! 'i 'I! „ ' ' „! . ' j| '
Committee Print Number 95-30 of the Committee of Public Works and Transportation of the
House of Representatives, Table 1.
Stern Tube Seals & Underwater Bearing Lubrication
12
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Figure 1. Port and Starboard Shaft Lines
Stern Tube Seals & Underwater Bearing Lubrication
13
-------
ADAPTER RING
MECHANICAL
SEAL ELEMENT ___._.,_
0 -jejOl ROTATING
COMPONENTS
FACE SEALING
STRI
MOUNTING RING ASSEMBLY

MOUNTING CLAMP RINGS (2)

BELLOWS ASSEMBLY

EMERGENCY PACKING
GLAND

SPLASH GUARD

SHAFT SEAT

DRIVE BOLTS
DRIVE CLAMP
RING
CENTERLINE SPLIT
Figure 2. Type MX9 Inboard Water Lubricated Fully Split Seal
Stern Tube Seals & Underwater Bearing Lubrication
14
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Table 1. Estimated Fleet-Wide Mass Loadings for Stern Tube Seals and Underwater
Bearing Lubrication
- /_ '• — ' Constitueiirt^;vl;^ji-,S^v;i'.;|
TRC
Rubber
Copper
Nickel
^Ife'Esi^^ •;
0.84
242
180
45
Table 2. Comparison of Calculated Data with Water Quality Criteria (jig/L)
Constituents-/
f
> "lf " rC*
TRC
Total Copper
Total Nickel
Calculated
Concentration
Log-normal ,
Mean Effluent
NA*
5.8
1.5
Federal
Chronic WQC

2.9
8.3
Most Stringent State Chronic
^ WQC
'"*"""'> <•• >
•* t/ --
7.5 (CT, m, MS, NJ, VA, WA)
2.9 (FL, GA)
7.9 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
CT = Connecticut
FL = Florida
GA= Georgia
ffl = Hawaii WA = Washington
MS = Mississippi
NJ = New Jersey
VA = Virginia
NA* = Not available. Concentrations estimated in Section 3.4.2.
Stern Tube Seals & Underwater Bearing Lubrication
15
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Table 3. Data Sources

NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
Data Source
Reported

UNDS Database

Sampling

Estimated

X
X
X
X

Equipment Expert
X
X
X
X
X
X
X
X
X
X
Stern Tube Seals & Underwater Bearing Lubrication
16
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NATURE OF DISCHARGE REPORT
Submarine Acoustic Countermeasures Launcher Discharge
1.0 INTRODUCTION

The purpose of the NOD report is to describe the discharge hi detail, including the system
that produces the discharge, the equipment involved, the constituents released to the
environment, and the current practice, if any, to prevent or minimize environmental effects.
Where existing process information is insufficient to characterize the discharge, the NOD report
provides the results of additional sampling or other data gathered on the discharge. Based on the
above information, the NOD report describes how the estimated constituent concentrations and
mass loading to the environment were determined. Finally, the NOD report assesses the
potential for environmental effect. The NOD report contains sections on: Discharge
Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data
Sources and References.
Submarine Acoustic Countermeasures Launcher Discharge
1
-------
2.0 DISCHARGE DESCRIPTION
i : s| • . , ' , ; ' . , ' • .» II
This section describes the submarine acoustic countermeasures launcher discharge and
includes information on: the equipment that is used and its operation (Section 2.1), general
description of the constituents of the discharge (Section 2.2), and the vessels that produce this
discharge (Section 2.3).
1 ;i • i" , . i . •
:'. !; , • : !
2.1 Equipment Description and Operation
"' • ;!•; \ ' '.,••':.,'••• \.~ , ;
Navy submarines are equipped with acoustic countermeasures devices that, once
launched, improve submarine survivability by generating sufficient noise to be observed by
hostile torpedoes, sonars, or other monitoring devices. The only acoustic countermeasure
systems used by the Navy that result in a discharge are Countermeasures Set Acoustic (CS A) Mk
2 launch systems. Other countermeasures systems do not generate a discharge within 12 nautical
miles because their launch tubes are always open to the ocean.1 Countermeasures devices are
launched from the CSA Mk 2 systems for training purposes.

The CSA Mk 2 system encompasses the countermeasure device, a gas generator, an
externally-mounted launch tube, and all associated.electronic controls for the countermeasure
device. Figures 1 and 2 provide the location of the launch tubes on submarine hulls, and the
location of components within the launch tube, respectively. Figure 3 shows the mechanism by
which gas is captured within the launch tube. A gas generator at the rear of the launch tube
provides the propulsive charge for launch of the countermeasure device. When the generator is
activated, hot gasses expand, forcing a metal "ram" plate and the countermeasure device out of
the launch tube. The ram plate lodges in the end of the launch tube, which forms a watertight
end cap after launch. For vessel and crew safety, a check valve and bleed holes in the ram plate
are used to allow equalization of internal gasses and liquids with external pressures that vary as
the submarine changes depth. The one-way check valve allows seawater to flow into the tube
after launch, but does not allow any of the liquids to be released through the opening. The
seawater that flows into the tube mixes with the gasses generated by the ammonia perchlorate gas
generation propellant, which results in an acidic liquid. The ram plate contains three 3/8-inch
diameter bleed holes with plugs that dissolve approximately 3 days after the launch, allowing
limited contact between the tube contents and the environment.2 Each launch assembly, with the
exception of the acoustic countermeasure device, is identical on all submarines, regardless of
vessel class or hull location.

While the submarine is underway and the launch tubes are underwater, the bleed holes
allow some exchange of the launch tube liquid contents with the seawater outside of the launch
tube. Actual discharge rates are very difficult to obtain due to the non-homogeneous nature of
the liquid mixture, the continuous dilution of the liquid contents through the bleed holes, and
variations in seawater flow surrounding the bleed holes due to changes in submarine speed and
maneuvers. On some submarines, launch assemblies are located above the waterline when the
submarine is traveling on the ocean surface. On these submarines, most of the liquid contents of
the launch assemblies drain freely from the bleed holes onto the submarine hull before entering
the water. The location of the bleed plug holes prevent the expended launch tube from
Submarine Acoustic Countermeasures Launcher Discharge
2
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completely draining; approximately one-quarter to one-half gallon (1 to 2 liters) of the liquids
remain, depending on the orientation of the ram plate within the launch tube.1 On other
submarines where the launch assembly is always below the water surface, the liquid drains
through the same bleed holes directly into the harbor during the assembly's replacement.

In order to protect workers from exposure to the potentially acidic water that remains in
the tube subsequent to launch, the Navy has started adding a one-pound packet of sodium
bicarbonate to the system to neutralize pH levels.3 Also, the Navy is reducing cadmium in the
discharge by removing hardware with cadmium-containing coatings from Navy stock.3 All
launchers will be equipped with these changes by the end of March 1999.4

2.2 Releases to the Environment

Within three days following the launch of a countermeasure device, bleed hole plugs in
the ram plate dissolve, which allows pressure equalization of the launch assembly contents with
the external seawater environment. The liquid contents of the launch tube are slowly exchanged
with seawater through these bleed holes while the submarine is moving. While the submarine is
stationary, little or no exchange with seawater occurs. For the submarines where the launch
tubes are located above the waterline, most of the liquid contents of the launch tube freely drain
through the bleed holes each time the submarine surfaces. For the submarines with launch tubes
located below the waterline, the major discharge occurs when the tubes are replaced pierside
while the submarine is stationary. The largest potential volume discharge event would occur
when all countermeasure launch tubes have been expended, there has been no discharge through
the bleed holes while the submarine was underway, and all launch tube contents are released at
one time in port. Therefore, for this analysis, it was assumed that all of the discharge from the
CSA Mk 2 system occurs during pierside replacement of the launch assembly.

2.3 Vessels Producing the Discharge

The CSA Mk n system is installed on 24 Navy submarines of two different classes: four
vessels of the Ohio (SSBN 726) Class, and 20 vessels of the Los Angeles (SSN 688) Class.
Launch assemblies on Ohio Class vessels are located above the waterline when the submarine is
surfaced; assemblies on Los Angeles Class vessels are located below the waterline. hi addition,
the number of launch assemblies differs by vessel class. Ohio Class vessels have 16 launch
assemblies while Los Angeles Class vessels have 14 assemblies.2 Neither the Army, Air Force,
U.S. Coast Guard, nor Military Sealift Command own or operate submarines.
3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and near-
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
Submarine Acoustic Countermeasures Launcher Discharge
3
-------
3.1 Locality
„ „ „ , ji '
Submarine countermeasures operations during training exercises typically occur outside
of 12 n.m. in the open ocean. Discharges from launch tubes located above the waterline may
occur within and beyond 12 n.m. while the submarine is underway on the surface as the effluent
drains from the bleed holes. Some additional leakage from these launch tubes could occur
pierside while the launch tubes are removed from the submarine. Discharges from launch tubes
legated below the waterline could also occur pierside when the launch tubes are offloaded. A
small amount of exchange between all submerged launch tubes and the surrounding waters could
occur continuously within and beyond 12 n.m.
• ' ,.. i • i
i
' ' ' "i
3.2 Rate

The volume of the launch tube is approximately 17 gallons (65 liters). Approximately 60
expended launch tubes are removed annually fleetwide.2 Therefore, approximately 1020 gallons
of effluent is generated per year. For the purposes of this report, the discharge event volume was
assumed to be 17 gallons, although in the cases where launch assemblies are above the waterline,
some of the launch tube effluent would be discharged prior to a launch assembly replacement
operation, and under normal circumstances even those tubes located below the waterline do not
discharge their entire contents.
n ! • ,,,r l:
When a submarine is traveling on the ocean surface, liquid contents of the launch
assemblies that are located above the waterline were estimated to discharge at a rate of one gallon
per minute through bleed holes. During a discharge event in port, the liquid contents are released
through the same bleed holes while being transported from the submarine to the pier, and
therefore also discharge at a rate one gallon per minute. For the purposes of this report, it was
assumed that all liquids in the launch assembly are discharged into surrounding waters before the
assembly is placed on the pier.
" ' II '
3.3 Constituents

Table 1 summarizes the analytical data from sampling of an actual gas generator and
launch tube assembly, with a sodium bicarbonate packet in place and no cadmium-containing
coatings.5 The constituents detected in sampling, i.e., lead, copper, cadmium, and silver, were
expected based upon the known components of the gas generator (e.g., ammonia perchlorate
propellant), hardware coating components, and solder within the system electronics.1 In addition
to analyzed concentrations, based upon knowledge of the components of the gas generator,
exhaust gas products that may become a part of the discharge can include hydrochloric acid,
carbon dioxide, water vapor, carbon monoxide, nitrogen, alumina, iron (II) chloride, titanium
dioxide, hydrogen, and iron (IT) oxide.6 Table 2 provides a complete listing of the types and
quantities of gas generator exhaust gas products. Of the discharge constituents, lead, copper,
cadmium, and silver are priority pollutants. There are no bioaccumulators that have been
identified in this discharge.
1 " ' , I: : '
3.4 Concentrations
Submarine Acoustic Countermeasures Launcher Discharge
4
-------
Table 1 provides a summary of the analytical results obtained from sampling of the
launch tube water immediately following a launch, and sampling five days after launch.5 Of the
two data sets, the analytical data from sampling five days after launch is more representative of
the actual pierside discharge because typical submarine operational schedules do not allow for
immediate replacement of the launched countermeasures devices. In reality, submarines usually
continue for months until a scheduled maintenance port call results in a launch tube change out
and discharge of launch tube water. For the data shown in Table 1, where a concentration value
was found to be below the detection limit, the mean concentration value was calculated using
one-half of the detection limit. The pH of the launch tube water five days after launch was 7.2,
which is similar to the pH of seawater (~8).
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The total annual discharge volumes provided in Section 3.2 were used to estimate
potential constituent mass loadings as follows:
Mass Loading (lbs/yr) = " ,
(avg. concentrations in |ig/L) (discharge in gal/yr) (3.785 L/gal) (2.205 Ib/kg) (10~
Analytical data from sampling five days after launch was used to calculate mass loadings
because that data set is more representative of the actual pierside discharge than data from
sampling immediately following launch. Even this overstates the potential mass loading, as most
submarines will continue to operate for months after the launch, before changing the launch
tubes. For example, the mass loading for copper was estimated as:
(80 ng/L)(1020 gal/yr)(3.785)(2.205)(10-9)
of an ounce per discharge event
' 7 x 10 lbs/yr, or approximately 2 ten-thousandflis
Table 3 provides annual fleet-wide mass loadings and discharge event mass loadings for
the metallic constituents listed in Table 1.

4.2 Environmental Concentrations
.
Submarine Acoustic Countermeasures Launcher Discharge
5
-------
Table '4 compares the concentrations of the Mk 2 system discharge to Federal and the
most stringent state water quality criteria (WQC). Copper, cadmium, and silver concentrations
are above both the Federal and most stringent state WQC. Lead was detected in only one of the
ten samples; lead in this sample exceeded the most stringent state WQC.
..!• M •!: • '. , I
• : ' ...lii "' , ' ' v , II
43 Potential For Introducing Non-Indigenous Species
i' ' .",::,': " ' ' • || i !
There is a low potential for this discharge to transport non-indigenous species because:
, " '! J , ' •. : ..•',' »:•, ' :! 'l> '' : ;
1) the 17-gallon launch tube is capped immediately following the launch of a
countermeasure device, with the only means of seawater entry being a one-way check
valve and three 3/8-inch diameter bleed holes. Therefore, there is limited opportunity
for organisms to ever enter the launch tube;
2) because launches of countermeasure devices are estimated to take place 60 times a
year fleetwide and typically take place in the open ocean;
3) any deep ocean water organism would be unlikely to survive in near-shore waters.7
4) the total volume of the discharge per year is small.
5.0 CONCLUSION
111 ' " 'i 'I; , I'
i ,!:'.' ' " " I! • . • '
Submarine acoustic countermeasures launcher discharge has a low potential to cause an
adverse environmental effect from constituents and the introduction of non-indigenous species
because:
1) The constituent mass loading is low. For example, the mass
receiving waters during one of the 60 discharge events
thousandths of an ounce.
loading of copper into
per year would be two ten-
2) The small volume of the discharge, combined with the low
organisms taken on could survive in port, make it unlikely that thi
transport viable non-indigenous species.
likelihood that the
e discharge could
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained.
Equipment expert information was used to estimate the rate of discharge. The constituents and
concentrations in this discharge were obtained from process knowledge and analytical data.
Table 5 shows the sources of the data used to develop this NOD report.
,! :. '':'! ' ' i!
Specific References

1. UNDS Equipment Expert Meeting - Submarine Acoustic Countermeasures Launcher
Discharge, 12 June, 1998.
I |
Submarine Acoustic Countermeasures Launcher Discharge
6
-------
2. UNDS Data Call Response, Countermeasure Set, Acoustic (CSA) Mk 2, PMS415D5,
Naval Sea Systems Command, 20 February 1998.

3. Engineering Change Proposal (ECP) CR-GG77-E0002, Naval Surface Warfare Center
(NSWC) Crane Division, 5 April 1997.

4. Personal Communication between Ken Burt, PMS415, Naval Sea Systems Command,
and Gordon Smith, SEA 03L, Naval Sea System Command, 23 February 1998.

5. Analysis of Products from Expended Propellant Billet Gas Generators, Naval Surface
Warfare Center, Crane, Code 4052, Ser 4052/7073,13 May 1997.

6. Excerpts from Naval Surface Warfare Center (NSWC) Crane Division Preliminary
Report for the Saltwater Immersion and Pressure Testing of the ADC Mk 3 Mod 0 with
Lithium Battery, EDD 95-068, NSWC Crane Division, May 1995.

7. "Stemming the Tide," Controlling Introductions of Nonindigenous Species by Ships'
Ballast Water, Committee on Ships' Ballast Operations, National Academy Press,
Washington D.C., 1996, p. 36.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22, 1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface
Water Quality Standards Effective April 8, 1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26, 1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The
Bureau of National Affairs, Inc., 1996.
Submarine Acoustic Countermeasures Launcher Discharge
7
-------
Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted
November16, 1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided
by The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13, 1995.
•. ; • • 'I
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9
VAC 25-260.
.11 !,- I ^_ , jl

Washington. Water Quality Standards for Surface Waters of the State of Washington.
Chapter 173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p' 15366. March 23,1995.
Submarine Acoustic Countermeasures Launcher Discharge
8
f
-------
CSAMK2MODO
Trident
Configuration
Launched Rack
Detailed View
CSA MK 2 MOD 1
SSN 688I Dihedral
Configuration
UNCLASSIFIED

Figure 1. Configuration of CSA Mk 2 Launchers
on SSBN 726 and SSN 688 Class Vessels
Submarine Acoustic Countermeasures Launcher Discharge
9
_
-------
111 ..'..M I' |l'i, illllli,' 4lK i'
Gas Gcnerati
Counterme
-Launch Tube
One Way CheckValve
UNCLASSIFIED
Figure 2. Location of Countermeasures Launcher Components Within a Launch Tube
Submarine Acoustic Countermeasures Launcher Discharge
10
I 1 ill, I
-------
-, \- i <
SS..S* ••••
Ram Plate
'^-—
Captured Gas "-"
UNCLASSIFIED
Figure 3. Countermeasure Launch Process
Submarine Acoustic Countermeasures Launcher Discharge

11
-------
Table 1. Constituent Concentration Data
Immediately and Five Days Following Launch
ill!!!,'11,, • i : : i;: , a , ; , ;• ; . • - .. . . . t , , i
Constituent
Metals
Barium
Lead
Copper
Cadmium
Chromium
Silver
Other
pH
Dissolved Concentrations Immediately
Following Launch
Ug/L
BDL'
BDL"
100
70
BDLC
BDLd
BDL
BDL
160
630
BDL
20
BDL
BDL
290
60
BDL
BDL
BDL
BDL
800
740
BDL
20
BDL
BDL
ISO
120
BDL
BDL
BDL
BDL
860
290
BDL
40
BDL
200
260
440
BDL
20
Mean
value
Dissolved Concentrations Five Days
Following Launch

BDL
110
380
340
BDL
20
BDL1
BDLb
70
40
BDLC
20
BDL
BDL
40
150
BUL
BDLd
BUL
BDL
70
100
BDL
BDL
BDL
BDL
90
20
BDL
BDL
BDL
BDL
60
20
BDL
BDL
BDL
BDL
170
90
BDL
30
BDL
BDL
80
30
BDL
BDL

Mean
value

BDL
100
80
60
BDL
10

7.2
6.0
6.0
5.7
6.3
5.3
5.9
5.8*
7.5
7.1
6.9
7.0
7.4
7.2
7.5
7.2*
* BDL = below detection limit; detection limit for barium is 1000 ug/L
b Detection limit for lead is 200 ug/L
0 Detection limit for chromium is 80 ug/L
d Detection limit for silver is 20 ug/L
Mean ptt calculated using arithmetic average of [H+] values
Table 2. Gas Generator Exhaust Gas Products 6
Exhaust Gas
Product
HC1
CO2
H2O
CO
N2
A1203
FeCl2
TiO2
H2
FeO
P2
PN
CHU
NH3
FeCl3
PO2
PO
PH3
Mass per Gas
Generator (g)
23.036
21.860
16.846
14.096
9.345
2.832
2.068
1.998
1.803
1.523
0.002
0.054
0.004
0.001
0.001
0.001
<0.001
<0.001
Table 3. Estimated Annual Mass Loadings
Submarine Acoustic Countermeasures Launcher Discharge
12
-------
(Constituent
-^
Cadmium
Copper
Lead
Silver
Loading (Ibs/yr)
0.0005
0.0007
0.0009
0.00009
Loading per Discharge Event* ^
•"• * (ounce/event) <• „"
0.0001
0.0002
0.0002
0.00002
= based upon 60 maximum-volume discharge events per year
Table 4. Comparison of Discharge Constituents with Water Quality Criteria (p.g/L)
Constituent
Cadmium
Copper
Lead
Silver
Mean Concentration
* or Value
60
80
100
10
Federal Acute WQC
/ ~* '
^ -j j"
42
2.4
210
1.9
Most Stringent State
Acute WQC ,
9.3 (FL, GA)
2.4 (CT, MS)
5.6 (FL, GA)
1.2 (WA)
FL = Florida
GA = Georgia
CT = Connecticut
MS = Mississippi
WA = Washington
Table5. Data Sources
~
NOB Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
2.3 Vessels Producing the - " „ -
Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4. 1 Mass Loadings
4.2 Environmental Concentrations,
4,3 Potential for Introducing Non-
Indigenous Species
' ," _ Data Source-
Reported

UNDS Database

X
X

' ' Sampling "

Estimated

Equipment Expert'
X
X
X
X
X
X

X
X
Submarine Acoustic Countermeasures Launcher Discharge
13
-------
-------
NATURE OF DISCHARGE REPORT
Submarine Bilgewater
1.0 INTRODUCTION

This section describes the submarine bilgewater discharge and includes information on:
the equipment that is used and its operation (Section 2.1), general description of the constituents
of the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
: ' ' II i'
| i
2.1 Equipment Description and Operation
i

Bilgewater in submarines is a mixture of discharges and leakage from a wide variety of
sources, which drain to the lowest compartment (bilge) of the submarine. Bilgewater includes
seawater accumulation, normal water leakage from machinery, and fresh water washdowns. It
can contain a variety of constituents including cleaning agents, solvents, fuel, lubricating oils,
and hydraulic oils.1

The submarine's drain system has a series of non-oily bilge collecting tanks, oily bilge
collecting tanks, and a waste oil collecting tank or tank complex. The Ohio (SSBN 726) Class
ballistic missile siibmarines and the planned New Attack Submarine (NSSN) use a waste oil
collecting tank complex partitioned into oily and clean sides. Los Angeles Class (SSN 688)
attack submarines use a waste oil collecting tank without the partitioning, where gravity
separation of oil occurs.1

Non-oily waste is sent via a segregated dram system to the nonoily bilge collecting tanks,
where it is discharged overboard. Waste that is oily or could possibly be oily, goes to the waste
oil collecting tank (WOCT) through a separate drain system. Submarine classes with partitioned
tanks, as listed above, use gravity separation enhanced by tank baffles to achieve some measure
of oil/water separation. The SSN 688 Class submarines use the aft bilge collecting tank (ABCT)
to receive and settle the bilgewater and non-oily drainage. The bottom portion of the water as
separated in the tank is discharged overboard.2 The upper portion of the ABCT which would
have any potential for containing oily waste is transferred to the WOCT. The lower portion of
the WOCT can be pumped overboard outside of 50 nautical miles (n.m.), but the upper portion
must be held for future transfer to appropriate shore/disposal facilities.1
• • ; : • • ' ' I'
While most submarines of the U.S. fleet operate as described above, the Sturgeon Class
(SSN 637) has bottomless bilge collecting tanks open to the sea, from which water is discharged
by displacement whenever bilge pumps are activated. Watches are set to monitor for a sheen
whenever oily water is to be pumped to the tank in port; pumping to the bilge collecting tank is to
cease if a sheen is reported.1
i '» " • , ' I

2.2 Releases to the Environment

Onboard SSN 688 Class submarines, clean drains and the lower portion, or water phase,
of the separated bilgewater in the ABCT are pumped overboard as necessary regardless of
distance from shore. The lower portion of the liquid in the WOCT can be disposed of outside of
50 n.m.2 The upper portion, or oily waste, from all of the drains, bilge water, and other sources
must be held on board until the submarine has access to appropriate shore or disposal facilities.
Submarine Bilgewater
2
t it; iiiiiii i
! iJiiiilu^ Jit:jiiiiliillllli i,iiaiiliilill:;i ijliiiiiilhih ;;, liiEiiij i,i;, ',; ia n!!i, iiliii J ,
...in,;,.,!, la:,fii, .,;„,;:::.
a 'a,." iili LJ;:;!,!, .ii\i
-------
2.3 Vessels Producing the Discharge

The Navy currently operates five classes of submarines .(presented in Table 1) that
generate bilgewater. However, not all of these classes discharge bilgewater to the environment.
Pierside, submarine bilgewater is transferred to shore facilities. In transit, SSBN submarines do
not discharge bilgewater within 12 n.m. SSN 688 Class submarines discharge some of the water
phase of the bilgewater collecting tank between 3 and 12 n.m.3
3.0 DISCHARGE CHARACTERISTICS

3.1 Locality

In most submarine classes, submarine drain and plumbing drain systems are used to
receive all drains and route them to their respective holding tanks. In these classes, discharges
which may contain any oily waste are not to be released within 50 n.m., except in emergencies.
Per OPNAVINST 5090. IB, submarines are instructed to:2

...pump all oily waste to the waste oil collection tank (WOCT). When the tank is full,
after allowing for adequate separation time, and the ship is outside 50 n.m. [nautical
miles], submarines shall pump the bottom, water phase of the WOCT overboard.

The upper, oil phase from the WOCT is discharged only to authorized shore facilities.

The location of this discharge varies by class and the activities of the submarine. The
operational factors that affect the location of bilgewater discharge include the operating depth,
type of operations, the submarine's requirement for quiet operations, and the duration of the
operations.

SSBN 726 Class submarines discharge all bilgewater either to shore facilities when
pierside, or hold bilgewater for discharge when outside 50 n.m. The SSN 688 Class discharges
some of the water phase of the bilgewater collecting tank between 3 and 12 n.m. due to the
limited size of the holding tank.3 For the SSN 637 Class submarines, discharges of bilgewater
can occur at any location when the bilge pumps are activated.1

3.2 Rate

The rate of this discharge varies considerably by class and with the submarine activities.
The volume of bilgewater generated can depend on the crew size, operating depth, the
Submarine Bilgewater
3
-------
submarine's requirement for quiet operations, the type of operations, the duration of operations,
and their location.
',! , '' '! i!
•'•,'' : ' ' ,"• • ..it.—
As shown in Table 1, there are three major submarine classes which generate bilgewater.
These are the SSBN 726 Class, the SSN 688 Class, and the SSN 637 Class. The SSN 637 Class
submarines are currently being phased out of service. At the present time, the entire class is
expected to be retired by the year 2001.4 Because of this, total discharge rates for SSN 637 Class
submarines will not be estimated.
L • f I! • ' (: • ii
Pearl Harbor Naval Station estimates that 2,000 to 3,000 gallons of bilgewater are
generated per submarine per day when pierside; the classes of vessels were not specified. For
the SSBN 726 and SSN 688 Class submarines, the following annual per-vessel flow estimates
were provided:3
'ii ' ,:, |
SSBN 726 31,500 gallons to shore facilities
0 gallons while transiting within 12 n.m.
300,000 gallons outside 12 n.m.
"' ' !|
SSN 688 54,000 gallons to shore facilities
80,540 gallons while transiting within 12 n.m.
400,200 gallons outside 12 n.m.

Available data indicate that for the other submarine classes, no bilgewater is discharged
within 50 n.m. Since bilgewater transferred to shore facilities is not released to the environment,
the above information indicates that only the SSN 688 Class submarines actually discharge
submarine bilgewater within 12 n.m. from shore.

Based on the value of 80,540 gallons per submarine per year discharged from the SSN
688 Class vessels between 3 and 12 n.m., a total flow was calculated as follows:
i r
(80,540 gal/vessel/year) (56 SSN 688 Class subs) = 4.5 million gallons/year
3.3 Constituents
• I
Potential constituents which have been detected in previous studies include oil and
grease, copper, cadmium, lead, nickel, iron, zinc, mercury, lithium bromide, citric acid, chlorine,
phenol, cyanide, sodium bisulfite, and the pesticides heptachlor and heptachlor epoxide.
Submarine bilgewater could possibly have high levels of total suspended solids (TSS) and
chemical oxygen demand (COD).6'7

Heptachlor, heptachlor epoxide, phenol, cyanide, copper, cadmium, lead, nickel, silver,
and zinc are priority pollutants. Mercury is the only bioaccumulator.

3.4 Concentrations
Submarine Bilgewater
4
-------
Table 2 summarizes concentration data from a sampling effort involving 10 submarines.
Samples in that program were analyzed for oil, 13 metals, pesticides, PCBs, and 46 organics
(vinyl chloride and 45 semivolatile organics).6'7 The sampling involved four SSBN 726 Class
submarines, four SSN 688 Class submarines, and two SSN 637 Class submarines. Samples were
taken from submarines that held their bilgewater while operating. Samples are representative of
discharges normally made outside 12 n.m.

Samples from open bilge compartments on all three classes of submarines were found to
contain an average of 20 parts per million (ppm) oil; bilgewater tanks averaged 76 ppm oil. hi
calculating arithmetic averages, six samples having values of greater than 1,000 ppm oil were
excluded. These were considered not representative of bilgewater discharged within 12 n.m. and
would be handled normally as waste oil and retained for shore disposal. These six samples
ranged from 1,030 to 820,000 ppm of oil. The arithmetic average of the 52 oil samples, ranging
between the detection limit of 5 ppm and 1,000 ppm, is 30 ppm. Including the 23 nondetects, the
result would be an arithmetic mean of 22.3 ppm when each non-detect sample was set equal to
the detect limit of 5 ppm.

Each sample was also analyzed for 13 metals. Eighteen pesticides, 7 PCBs, 45
semivolatile organics (base neutral aromatics), and one volatile organic (vinyl chloride) were
analyzed for in the 81 samples. Table 2 presents concentration ranges and the average
concentration calculated. No PCBs, semivolatiles, or vinyl chloride were detected in any sample.
Six of the 81 samples contained detectable levels of the pesticides heptachlor and heptachlor
epoxide.6'7
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. hi Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria, hi
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

The total annual mass loadings were calculated based upon the estimated discharge
volume for SSN 688 Class vessels and the average concentrations of constituents in submarine
bilgewater. The results are presented in Table 3.

4.2 Environmental Concentrations

Concentration data presented in Table 2 are measured concentrations in the discharge,
and do not reflect any dilution afforded by the receiving water.

Table 4 shows the water quality criteria (WQC) that are relevant to submarine bilgewater,

Submarine Bilgewater
5
-------
and compares measured concentrations of constituents to WQC. Reported levels of oil and
grease for bilgewater exceed the Federal and the most stringent state WQC. Mercury, heptachlor,
and heptachlor epoxide exceed the most stringent state WQC. Average measurements of
constituents in the discharge exceed the Federal and the most stringent state WQC for copper,
nickel, silver, and zinc. While there is no relevant Federal WQC, chlorine concentrations exceed
the most stringent state WQC. Cadmium concentrations exceed the most stringent state WQC,
but do not exceed the Federal WQC.
11 ' ' ' ii '
4.3 Potential for Introducing Non-indigenous Species
i ,.','!'' :
Non-indigenous species are not likely to be transported by submarine bilgewater. There
is limited seawater access to bilge compartments. Bilgewater storage capacity limitations require
processing bilgewater on a frequent basis, resulting in discharge in the same geographic area in
which it was generated.
5.0 CONCLUSIONS

Concentration data from submarine bilgewater were used to estimate constituent loadings
within 12 n.m. from shore. These data and estimates were based on the existing management
practices (i.e. shoreside bilgewater collection, discharging only the water phase, and refraining
from discharging within 12 n.m.). Discharges between 3 and 12 n.m. occur while the vessels are
underway thereby dispersing the pollutants. Removal of the existing practices could significantly
increase amounts of constituents discharged above WQC and discharge standards, especially oil.
Submarine bilgewater could potentially be discharged in port if these existing practices were not
in place. Therefore, submarine bilgewater, uncontrolled, has the potential to cause an adverse
environmental effect.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 5
shows the sources of data used to develop this NOD report.

Specific References
; ' i ': :;' | IS, ' ' jj
• ,', :• : >! ' " ' I!
1. UNDS Equipment Expert Meeting Minutes, Submarine Bilgewater. August 12,1996.

2. OPNAVINST 5090. IB. Environmental and Natural Resources Program Manual.
November 1,1994.

3. Data Call Response, Commander, Submarine Force, U.S. Atlantic Fleet. Submarine
Discharge Questionnaire. December 13,1996.

4. Personal Communication Between Mr. R.B. Miller (M. Rosenblatt & Son, Inc.) and Mr.
Submarine Bilgewater
6
-------
Paul Murphy (NAVSEA PMS 392A33) of October 15,1997.

5. Data Call Response, Pearl Harbor Naval Station. October 11,1996.

6. Bilge Water Sampling Study. Final Report. September 30,1996. Electric Boat
Corporation.

7. NSSN Review, June 5,1996. Subject: Fleet Bilge Water Sampling. Presented by: James
Triba, NSSN Seawater Systems, Electric Boat Corporation.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22, 1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural

Submarine Bilgewater
7
-------
Resource Conservation Commission. Effective July 13,1995.
|,
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.
I1: . , , i: |! '
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
•. , • " r " J
-------
Table 1. Submarines Producing Bilgewater Discharges
Vessel Class ?
SSBN726
SSN 637
SSN 640
SSN 671
SSN 688
, Description of Vessel „
Ohio Class Ballistic Missile Submarine
Sturgeon Class Attack Submarine
Benjamin Franklin Class Attack Submarine
Narwhal Class Attack Submarine
Los Angeles Class Attack Submarine
"Number sof Vessels ;
17
13
2
1
56
Table 2. Concentrations of Contaminants in Submarine Bilgewater Discharge (mg/L)6'7
'.";•• %*; "'^J&rameter ' - / -.
Oil
Arsenic
Barium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Zinc
Heptachlor
17 other pesticides
Heptachlor epoxide
PCBs
1 VGA plus 45 SVGAs note c
Ammonia
Chlorine
COD
Cyanide
PH
Phenols
Surfactants
TSS
s Range.(ing/L^
<5 - 820,000
O.01
O.01 - 3.3
<0.005 - 0.2
<0.01 - 1.7
0.065- 15
<0.2 - 20
<0.01 - 0.074
<0.01 - 1.7
O.0002 - 0.0007
O.04-11
<0.005 - 0.021
<0.01 - 0.035
O.02-11

<0.001

<0.1 - 68
0.0-1.6
<15 - 4500
O.01 - 0.03
2.94 - 8.95
<0.01 - 5.4
ND- 0.807
<7 - 2400
' Arifiiiii^iB;M*^(id^y*^^. !':.
30 mg/L (note a)
<0.01
0.014
0.02
0.050
1.42
1.89
0.01
0.12
0.00007
0.98
0.005
0.006
1.36
0.000005
noteb
0.000003
<0.001
noteb
6.95
0.21
595
0.004
6.9
0.19
0.16
177
Note a - The average of 30 mg/L provided in the primary reference6 omitted all nondetects and all (six) oil values >
1,000 milligrams per liter (mg/L). The average of the 75 samples less than 1,000 ppm (including nondetects,
assumed to equal the detection limit) is 22.3 mg/L.
Note b - No samples had detectable levels.
Note c - VGA is volatile organic analyte; SVGA is semivolatile organic analyte
Values preceded by "<" are non-detects
Submarine Bilgewater
9
-------
"I H T'fllli' II"!"!!"'
Table 3. Estimated Mass Loadings of Constituents
from Submarine Bilgewater Discharges (Ibs/yr)
Pollutant
Oil
Copper
Lead
Nickel
Silver
Zinc
Ammonia
Chlorine
Barium
Cadmium
Chromium
Mercury
Selenium
Heptachlor
Cyanide
Phenol
Surfactants
Concentration (mg/L)
30.01
1.42
0.01
0.98
0.006
1.36
6.95
0.21
0.014
0.02
0.05
0.00007
0.005
0.000005
0.004
0.19
0.16
688 Class 3-12 n.m.
1130
53.4
0.38
36.9
0.23
51.2
262
7.90
0.53
0.75
1.9
0.0026
0.19
0.00019
0.15
7.15
6.02
Submarine Bilgewater
10
-------
Table 4. Comparison of Measured Constituent Values and Water Quality Criteria (fig/L)
Constituent
Mercury*
Heptachlor
Heptachlor epoxide
Phenol
Cyanide
Oil
Copper
Nickel
Silver
Zinc
Chlorine
Cadmium
f Average -
Concentration
0.07
0.005
0.003
190
4
3,0010
1420
980
6
1360
210
20
Federal Acute WQC
1.8
0.053
0.053
-
1
visible sheen3 / 15,000b
2.4
74
1.9
90
-
42
Most Stringent State
Acute WQC
0.025 (FL, GA)
0.0001 1(GA)
0.00021 (FL)
170 (HI)
1 (CA, CT, FL, GA, HI,
MS,NJ,VA,WA)
5000 (FL)
2.4 (CT, MS)
8.3 (FL, GA)
1.2 (WA)
84.6 (WA)
10 (FL)
9.3 (FL, GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.

CA = California
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
NJ = New Jersey
VA = Virginia
WA = Washington

* Bioaccumulator

3 Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen
on receiving waters.
b International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as
implemented by the Act to Prevent Pollution from Ships (APPS)
Submarine Bilgewater
11
-------
Table5. Data Sources

NOD Section
2.1 Equipment Description and
Operation
22 Releases to the Environment
23 Vessels Producing the Discharge
3.1 Locality
33. Rate
33 Constituents
3.4 Concentrations
4.1 Mass Loadings
4,2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
Data Source
Reported

Data Call responses
UNDS Database
Data Call responses
Data Call responses
X
X

Sampling

Estimated

Equipment Expert
X
X
X
X

X
Submarine Bilgewater
12
-------
NATURE OF DISCHARGE REPORT
Submarine Emergeney Diesel Engine Wet Exhaust
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed in three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)-—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

The purpose of the NOD report is to describe the discharge in detail, including the system
that produces the discharge, the equipment involved, the constituents released to the
environment, and the current practice, if any, to prevent or minimize environmental effects.
Where existing process information is insufficient to characterize the discharge, the NOD report
provides the results of additional sampling or other data gathered on the discharge. Based on the
above information, the NOD report describes how the estimated constituent concentrations and
mass loading to the environment were determined. Finally, the NOD report assesses the
potential for environmental effect. The NOD report contains sections on: Discharge
Description, Discharge Characteristics, Nature of Discharge Analysis, Conclusions, and Data
Sources and References.
Submarine Emergency Diesel Engine Wet Exhaust
1
-------
2.0 DISCHARGE DESCRIPTION
1 - i- i" • • •. I
i- i" • . I :
•
This sgctiqn describes the submarine emergency diesel engine wet exhaust liquid
discharge and includes information on: the equipment that is used and its operation (Section
2.1), general description of the constituents of the discharge (Section 2.2), and the vessels that
produce this discharge (Section 2.3).
" I .1! . I
2.1 Equipment Description and Operation
ti •• , i
All submarines have emergency diesel engines for use during emergency situations, such
as providing electric power or emergency ventilation. However, emergency diesel engines are
routinely used during training exercises, pre-underway checks, and quarterly performance
analyses. All submarines have air induction and diesel exhaust systems for emergency diesel
engines. Air induction systems bring in outside air for combustion in the emergency diesel
engines, while exhaust systems discharge the combustion by-products overboard. Prior to
discharge, the exhaust gases are cooled by seawater injection into the exhaust. Water is injected
to reduce radiant energy from the exhaust piping and to reduce corrosion of the exhaust piping
from high temperatures.

Each submarine is equipped with one emergency diesel engine. Refer to Figure 1 and
Figure 2 for a representation of the wet exhaust system.

2.2 Releases to the Environment
it i ' . , • . ;:. • jj
The exhaust-water mixture is vented from the exhaust stack into the atmosphere. Some
of the water mist with entrained or dissolved exhaust products will settle into the seawater
surrounding the exhaust stack. For the purposes of this analysis, it is assumed that all of the
discharge settles to the water's surface.

2.3 Vessels Producing the Discharge

The Navy is the only branch of the Armed Forces that operates submarines. All active
submarines in the fleet produce this discharge. For this report, information on the discharge rates
'"US'': , ' I '' | • jfiHl ' ''Y'iitl ' I,' * • ^ , M| I II I , "I , '
from the three main submarine classes was used, representing 86 of the 89 active submarines.
The classes of submarines producing emergency diesel wet exhaust discharge analyzed in this
report are summarized in Table 1.
3.0 DISCHARGE CHARACTERISTICS

Each vessel operates the emergency diesel engine an average of 60 hours annually within
12 n.m. of shore.

3.2 Rate

Table 1 provides discharge rates for individual classes of submarines. Discharge rates
vary for each vessel class, from approximately 7 gallons per minute (gpm) to 15 gpm, and are
dependent on the water injection rate into the exhaust system.1'2'3'4 For this analysis, it was
assumed that all of the water injected into the exhaust system is eventually discharged to the
receiving water body. This represents an overestimate for total flow volumes, because much of
the injected seawater has the potential to vaporize.

3.3 Constituents

Constituents of exhaust from diesel engines include both organic and inorganic
substances. These substances originate primarily from the diesel fuel and also from engine
lubricants. Most of the substances that originate from the diesel fuel are products of combustion.
Some diesel fuel can pass through the engine unburned, along with combustion products in the
exhaust.5

Inorganic substances in diesel exhaust include combustion products such as carbon
dioxide (COa), carbon monoxide (CO), oxides of nitrogen (NOX), oxides of sulfur (SOX), and
metals. The specific substances and their concentrations in the exhaust depend on a number of
factors, including the composition of the fuel, engine temperature, engine use, and engine
condition. Many of the organic substances in diesel exhaust condense into particiilates, that is,
the oily soot visible in the exhaust.6

Standard air emissions factors for large stationary diesel industrial engines were used to
study the constituents in this discharge. EPA has published emission factors for large stationary
diesel engines 600 hp and over. These emissions factors relate quantities of released materials to
fuel input, as nanograms per Joule (ng/J), or as power output, as in grams per horsepower-hour
(g/hp-hr). Although intended for stationary industrial diesel engines, these emission factors can
be used to approximate emergency diesel engine emissions.6

Table 2 lists the emission factors for constituents present in the air exhaust of large diesel
engines.6 As the cooling water is injected into the air exhaust, many of these constituents have
the potential to be introduced into the water. Of the compounds shown in Table 2, benzene,
toluene, acrolein, naphthalene, acenaphthylene, acenaphthene, fluorene, phenanthrene,
anthracene, fluoranthene, pyrene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene,
benzo(k)fluoranthene, benzo(a)pyrene, indeno(l,2,3-cd)pyrene, dibenzo(a,h)anthracene, and
benzo(g,h,i)perylene are priority pollutants. This discharge is not expected to contain
bioaccumulators.
Submarine Emergency Diesel Engine Wet Exhaust
3
-------
3.4 Concentrations
'•• ",] • . ' ' ' |; ' .
Using submarine diesel engine power output specifications, the concentrations of the
chemical con?fitu§nts in the engine exhaust were estimated for each submarine class. By making
the assumption that all constituents in the discharge liquid resulted from exhaust gases dissolving
in the cooling water under equilibrium conditions, it is possible to estimate the concentration of
constituents in the liquid using Henry's Law. Henry's Law describes the solubility of gases in a
liquid and relates the concentration of a constituent in a liquid to the partial pressure of the
constituent in the gaseous phase surrounding the liquid. The calculation sheet at the end of this
report presents the assumptions made for this approach and provides a sample calculation for the
concentration of benzene in the wet exhaust of a SSN 688 class submarine. Estimated
concentrations are presented in Table 3.
4.0 NATURE OF DISCHARGE ANALYSIS
" In ' ' 1 |l
',„:': i , ' . I!
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented hi Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings
i" / , , ' , |!' ,
.. .. , . .),
Mass loadings were calculated for constituents that exceed WQC using annual flow
volumes (Table 1) and estimated constituent concentrations (Table 3). Annual flow volumes
Were calculated using the cooling water injection rate (Table 1) and an average operational tune
of 60 hours annually within 12 n.m. of shore, per submarine.1 Fleet-wide mass loadings for
individual chemical constituents were calculated through the following equation and are shown
in Table 4.
Annual Mass Loading (kg) •
*» (Concentration in Discharge (mg/L))(AnnualDischarge (gal))(3.785^ L/gai)(10'6 kg/rngV
The mass loading calculations are an overestimate. Calculations using Henry's Law
assumed that equilibrium conditions exist. However, due to the low residence time (<1 second)
of both exhaust products and water hi the wet exhaust system, equilibrium conditions are
unlikely.7 Therefore, constituent concentrations are expected to be lower than calculated.
'•' ' H :" :' !• . . • ' ' . ;:: • |i'
4.2 Environmental Concentrations
, i : ' ' ' ' !
A comparison of estimated constituent concentrations to corresponding Federal and most
stringent state water quality criteria (WQC) is presented in fable 5. The estimated
concentrations of phenanthrene, benzo(a)anthracene, chrysene, indeno(l,2,3-cd)pyrene,
dibenzo(ah)anthracene, and benzo(g,h,i)perylene individually exceed the most stringent state
,ll
•ii • - li
Submarine Emergency Diesel Engine Wet Exhaust
-
-------
(Florida) WQC. Concentrations have been based on a water temperature of 60°F. Since the
majority of submarines are located in warm water ports, it is believed that 60°F is a reasonable
assumption for an average water temperature. Concentrations may increase at colder
temperatures because of increased constituent solubilities. However, even if concentrations
triple, none of the individual constituents will exceed federal water quality criteria and only one
additional individual compound (benzo(a)pyrene) will exceed Florida criteria for total PAHs. All
other constituent concentrations are below relevant WQC.

4.3 Potential for Introducing Non-Indigenous Species

Because water intake and discharge occur at the same location, there is no significant
threat of non-indigenous species introduction to receiving waters.
5.0 CONCLUSION

This analysis concluded that submarine emergency diesel engine wet exhaust has a low
potential for adverse environmental effect. Although total PAHs (the total of the following
individual PAH compounds: acenaphthylene, benzo-(a)anthracene, benzo(a)pyrene,
benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene,
dibenzo(a,h)anthracene, indeno(l,2,3-cd)pyrene, and phenanthrene) exceeded water quality
criteria for the most stringent state (Florida), the annual Fleet-wide mass loading was only 0.056
pounds from 86 vessels.
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Table 6
shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Data Call Package Submission from COMSUBLANT, 688 & 726 Class
Submarine. December 13,1996.

2. Gerry Viers, Newport News Shipbuilding. Submarine Diesel Exhaust System, 5 February
1997, Doug Hamm, Malcolm Pimie, Inc.

3. Perry Buckberg, NAVSEA 03X33. Submarine Diesel Exhaust Temperatures, 13
November 1997, Russ Hrabe, M. Rosenblatt & Son, Inc.

4. UNDS Equipment Expert Meeting - Submarine Emergency Diesel Engine Exhaust. 3
September 1996.
Submarine Emergency Diesel Engine Wet Exhaust
5
-------
5. Faukner, M.G.; E.B. Dismukes; and J.R. McDonald. Assessment of Diesel Particulate
Control: Filters, Scrubbers, and Precipitators. U.S. Environmental Protection Agency.
EPA-600/7-79-232a. October, 1979.
; ? i • ;.j . .,. . , , f I :
6. United States Environmental Protection Agency Office of Air Quality Planning and
Standards. Compilation of Air Pollution Emission Factors. AP-42, Fifth Addition,
November, 1996.

7. Doug Hamm (MPI). Interoffice Memo: Estimation of Residence Time. March 4, 1998.
' ' ' !! '
General References
,<.! • ii :
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.
, ,, , , „ , i;
Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
ii ,1 , . , ' |: ' i
Mississippi. Water Quality Criteria for rntrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.
:' ; I! • • • i ii,
New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, me., 1996.
Submarine Emergency Diesel Engine Wet Exhaust
6
-------
Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Submarine Emergency Diesel Engine Wet Exhaust
7
-------
INDUCTION
; i ! : AIR
EXHAUST
PLENUM
DtESEL
EXHAUST
-INDUCTION MAST
(PARTIALLY RAISED)
LP. BLOWER
ISOLATION VALVE
LP. BLOWER
DIESEL
EXHAUST
WATER
TRAP
S.W.
DRAIN
FAIRWATER
HULL AND
BACKUP VALVES
PRESSURE HULL

R
3

~\_ ' JIOT IM ICT/TI/-IRI

13 .-TO FAN ROOli
_» INDUCTION SUM
r
S.W.
DRAIN
NS
*'

*l
FROM
DIESEL
S.W. SYS.
Figure 1. Typical Submarine Diesel Exhaust System
Submarine Emergency Diesel Engine Wet Exhaust
8
-------
(
SW/FWHTX
/ GENERATOR II lP
I AIR COOLER II Lft
,P-4"
^P-4"
tr
P-1-1/2"
DIESEL ENGINE
SW
INJECTION
(10gpm)
_ DIESEL
(f EXHAUST
I
ATTACHED DSW.-
PUMP
-HULL
Figure 2. Typical Submarine Diesel Seawater System
Submarine Emergency Diesel Engine Wet Exhaust
9
-------
Table 1. Emergency Diesel Engine Applicable Vessels,
Air Exhaust and Cooling Water Flow Rates, and Estimated Annual Discharge
Submarine Class
:• „-,„ • ' •. • v ,: ;.•.:•• ;• -;, •. .
SSN 688 (Los Angeles Class)
SSBN 726 (Ohio Class)
SSN 637 (Sturgeon Class)
Total
No. of
Submarines

56
17
13
86
Air Exhaust
Flow Rate
(cubic feet
per minute)
6500
8600
3600
N/A
Cooling Water
Injection Rate
(gallons per
minute)
11.5
15.0
7.0
N/A
Annual
Discharge per
Submarine
(gallons)*
41,400
54,000
25,200
N/A
Annual
Discharge for
Class (million
gallons)
2.3
0.92
0.33
3.55
* Based on 60-hour operating time annually per submarine
Table 2. Emission Factors for Large Uncontrolled Stationary Diesel Engines
Constituent
Benzene
Toluene
Xylenes
Formaldehyde
Acetaldehyde
Acrolein
NO,
CO
C02
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd) pyrene
Dibenz(a,h) anthracene
Benzo(g,h,i) perylene
Emission Factor
(lb/MMBtu)*
7.76E-04
2.81E-04
1.93E-04
7.89E-05
2.52E-05
7.88E-06
3.2
0.85
165
1.30E-04
9.23E-06
4.68E-06
1.28E-05
4.08E-05
1.23E-06
4.03E-06
3.71E-06
6.22E-07
1.53E-06
1.11E-06
2.18E-07
2.57E-07
4.14E-07
3.46E-07
5.56E-07
(ngOf
0.3337
0.1208
0.0830
0.0339
0.0108
0.0034
1376
365.5
70950
0.0559
0.0040
0.0020
0.0055
0.0175
0.0005
0.0017
0.0016
0.0003
0.0007
0.0005
0.0001
0.0001
0.0002
0.0001
0.0002
* Gaseous emission factors expressed in pounds per million British thermal unit (Ib/MMBtu)
To convert from Ib/MMBtu to ng/J, multiply by 430
Submarine Emergency Diesel Engine Wet Exhaust
10
-------
Table 3. Estimated Concentrations of Exhaust Constituents in Wet Diesel Exhaust (mg/L)
Submarine Class: * -
Engine Power/Exhaust Rater
Exhaust Constituents /
Benzene
Toluene
Xylenes
Formaldehyde
Acetaldehyde
Acrolein
NOx
CO
CO2
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd) pyrene
Dibenz(a,h) anthracene
Benzo(g,h,i) perylene
SSN688,JEA Class --
"(800kW,6500.cfoj)
'* * --
.000018
.000005
.000004
.005749
.00018
.000006
.013364
.001814
9.028866
.000038
.0000004
.000002
.000019
.000129
.000003
.0000002
.000039
.000039
.000105
.000007
.0000004
.000012
.000434
.000339
.000751
SSBN 726, Ohio Class
(100QkW/8600cfia) .,
.000017
.000005
.000004
.005431
.00017
.000006
.008234
.001714
8.530179
.000036
.0000004
.000002
.000018
.000122
.000002
.0000002
.000037
.000036
.000099
.000006
.0000004
.000011
.00041
.00032
.00071
SSN 637, Sturgedn
(460kW,;3600 cfa)
.000019
.000006
.000004
.005969
.000187
.000006
.009049
.001884
9.373719
.00004
.0000005
.000003
.00002
.000134
.000003
.0000002
.000041
.00004
.000109
.000007
.0000004
.000012
.00045
.000352
.00078
Note: Concentrations have been based on a water temperature of 60*1?.
exceeded (see Table 5).
Bold indicates that water quality criteria is
Submarine Emergency Diesel Engine Wet Exhaust
11
-------
Table 4. Fleet-Wide Estimated Annual Mass Loadings of Wet Diesel Exhaust Constituents
Within 12 n.m. of Shore
Submarine Class:
Engine Power:
Exhaust Rate:
No. Vessds:
Constituent
SSN688 Class
800 kW
6500 cfrn
56 Vessels
(kg)
SSBN 726 Class
1000 fcW
8600 cfin
17 Vessels
(kg)
SSN 637 Class
460kW
3600cftn
13 Vessels
(kg)
-'.:••' - '
- --"'. ••• TOTAL .--'-". -
'"". - -.FLEETWEDE ;/ ' ..

(kg)
(Ibs)
Polycyclic Aromatic
Hydrocarbons (PAIIs)
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Bcnzo(b)fluoranthene
Benzo(k)fluonmthene
Benzo{a)pyrene
Indeno(l,2,3-cd) pyrene
Dibenz(a,h) anthracene
Bcnzo
-------
Table 5. Comparison of Discharge Concentrations and Water Quality Criteria
Constituent
Estimated Discharge
Concentration1 '•
Federal Acute
,>'WQC .
Most Stringent State
Acute WQC t
Polyaromatic
Hydrocarbons (PAHs)
Acenaphthylene
Phenanthrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd) pyrene
Dibenzo (a,h) anthracene
Benzo(g,h,i) perylene
Total PAHs2
0.0005
0.134
0.04
0.109
0.007
0.0004
0.012
0.45
0352
0.78
1.89
None
None
None
None
None
None
None
None
None
None

0.031 (FL)2
0.031 (FL)2
0.031 (FL)2
0.031 (FL)2
0.031 (FL)2
0.031 (FL)2
0.031 (FL)2
0.031 (FL)2
0.031 (FL)2
0.031 (FL)2
0.031 (FL)2
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec.
22, 1992 and 60 FR 22230; May 4, 1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.

Bold number indicates that water quality criteria is exceeded.
HI = Hawaii
FL = Florida

1: Highest concentration of three submarine classes
2: Florida criteria for total PAHs is for the total of the following individual PAH compounds:
acenaphthylene, benzo-(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene,
benzo(k)fluoranthene, chrysene, dibenzo(a,h)anthracene, indeno(l,2,3-cd)pyrene, and phenanthrene.
Estimated discharge concentrations for total PAHs represent a sum of these chemicals.
Tabled. Data Sources

NOD Section
2.1 Equipment Description and Operation,
2.2 Releases to the Environment
2:3 Vessels Producing the Discharge
3vl Locality
-3.2;Rate
,33 Constituents
3.4 Concentrations
>4>t Mass Loadings
4.2 Environmental Concentrations
4;3 Botential for Introducing Non-
Indigenous Species
Data Source - '
'Reported

UNDS Database

Sampling

Estimated

X
X
X
X
X
X
Equipment Expert
X
X
X
X
X
X

X
Submarine Emergency Diesel Engine Wet Exhaust
13
-------
Calculation Sheet
Benzene
Biclcground:
Henry's Law was used to estimate the concentration of components in wet exhaust from submarine
emergency diesel engines. This calculation sheet shows the calculation for the concentration of benzene in
the wet exhaust of SSN 688 Class submarines. Calculations for the other exhaust components were similar.

An energy balance was used to determine the approximate wet exhaust equilibrium temperature. The
resulting temperature was determined using an air exhaust flow rate of 6,500 cfin at 200 °F, and a water
injection rate of 1 1 .5 gpm at 60 °F. For this calculation, we assume the exhaust gas to have similar thermal
properties to air.

AH: Change in enthalpy, m: mass of air or water, Cp: Specific heat capacity of air or water
- mCp (200°F-T)

* (6,500 ftVmin.) (0.0601 Ibn/ft3) (0.24 Btu/lbm°F) (200°F - T)

- 93.76 Btu/°F-min. ( 200°F-T) (1)

AHWMcr = mCp (T-60°F) = (1 1.5 gal/min.) (8.345 lbm /gal) (1 Btu/ lbm °F) (T-60°F)

- 95.97 Btu/°F-min. (T-60°F) (2)
Setting (1) = (2) we obtain the following:

93.76 Btu/°F-min. (200°F -T) = 95.97 Btu/°F-min. ( T-60°F) "

93.76 (T) + 95.97 (T) = 200°F (93.76) + 95.97 (60°F)

T = 129.18 °F = (9/5) °C + 32 = 54°C
. :: ' • ' "ill '. ' . ,: " II
This temperature was then used to determine the appropriate values for Henry's Law
constants, which vary with temperature.
At dilute concentrations, the concentration of benzene dissolved in water can be found from Henry's Law:
X», exhaust = (Ha) (Xa, water) /(Pt)
Where:
X^ exhaust ' Mole Fraction of Benzene in Exhaust
Ha : Henry's Law Constant (atm)
X^ water • Mole Fraction of Benzene in Water
P, : Total Exhaust Pressure (atm)
'
.. .
Rearranging, Henry's Law can be rewritten as:

X^ waier = (Xa, exhaust ) (ft) ' Ha
. :•;( ;! ;; , .• •:• ' " , : . , .' ;;; ..... ,
The mole fraction of benzene in exhaust can then be converted into a concentration of benzene in the wet
exhaust in mg/L using the molecular weight of benzene.
f
Given Conditions and Assumptions:
55.56 moles H2O in 1 liter [ (mole H2O / 18 g H2O) (lOOOg / Liter H2O) = 55.56 moles H2O/L ]
Exhaust temperature of 200°F (Reference 3)
li
Submarine Emergency Diesel Engine Wet Exhaust
14
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6,500 cfin air exhaust flow rate for 800 kW diesel engine
0.334 ng/J generation rate of benzene
Backpressure on engine is approximately 70% above atmospheric when surfaced (Pt = 1.70 atm)
Molecular weight of benzene is 78.11 grams per mole (78,110 mg/mole)
Based on a water temperature of 54 °C (327.15 K), Henry's Law constants (in atm) for the constituents are
the following:
Constituent
Ha (atm)
Benzene
Toluene
Xylenes
Formaldehyde
Acetaldehyde
Acrolein
Nox
CO
C02
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd) pyrene
Dibenz(a,h) anthracene
Benzo(g,h,i) perylene
7.30 E+03
8.89E+03
8.56E+03
2.30E+00
2.34E+01
2.22E+02
4.01E+04
7.85E+04
3.06E+03
5.71 E+02
3.45E+03
3.19E+02
1.13E+02
5.31E+01
7.96E+01
2.92E+03
1.59E+01
2.70E+00
2.44E+00
2.77E+01
9.17E+01
3.61E+00
1.60E-01
1.71E-01
1.24E-01
The conversion of Henry's Law constants into common units is presented at the end of the calculation sheet.

Solution:
1) Total number of moles per cubic foot in the air exhaust, including constituents and circulated air, nt

The number of moles per cubic foot can be determined using the ideal gas law; PV = ntRT

Where:
P: Pressure within the exhaust piping, 1.7 atm
V: Volume of space occupied by gas (assume 1 ft3)
R: Gas constant, 0.08206 L-atm/ K-mol
T: Temperature, 327.15 K

Rearranging the ideal gas law equation and solving for n/V yields:

n,/V =P/RT

n,IV = (1.7atm) (28.32 L/ ft3) / (( 0.08206 L-atm/ K-mol) (327.15 K))
= 1.79 moles/ft3

2) Concentration of benzene in air exhaust, Ab

Submarine Emergency Diesel Engine Wet Exhaust
15
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Ab= (0.334 ng/J) (800 kW) (3.6 x 106 J/kW-Hr) (lO'Vng) (1000 mg/g) (min./6500 f3) (Hr/60 rain.)
Ab= 2.47 x 10'3 mg/ft3 = (2.47 x 10'3 mg/ft3) ( g/1000 mg) ( mole benzene / 78.1 1 g)
= 3. 17 x 10"8 moles benzene/ft3 exhaust

3) Mole fraction of gas in exhaust, X^ exhaust
X^ adjust = At/total molar concentration
X«, exhaust = (3. 17 x 10"8 moles benzene/ ft3 exhaust) / (1 .79 total moles/ ft3 exhaust)
X^ exhaust = 1-77 x 10"8 moles benzene/ mole exhaust
4) Mole fraction of gas in water, Xa. water
water a, exhaust) (ft) ' Ha
= (1.77 x 1Q-8) (1.70 atm) / 7300 (atm)
= 4. 12 x lO"12 moles benzene / mole water
5) Concentration of gas in waten
Per 1 liter of water;
Moles benzene = (4.12 x 10'12 moles benzene / mole H2O) (55.56 moles H2O/ 1 h'ter) = 2
(2.29 x 10'10 moles/L ) (78.1 1 g benzene/mole) = 1.8 x 10'8 g/L benzene
(1 .8 x 10"8 g/L) (1000 mg/g) = 1.8 x 10'5 mg/L benzene
.29 x 10'10 moles/L
Submarine Emergency Diesel Engine Wet Exhaust
16
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Determination of Henry's Constants

Henry's constants for the constituents of concern were available, but units and temperature for the constants varied
between the references used. Henry's constants with the following units were available:

1) HI, atm
2) H2, atm-m3/mol

For purposes of clarity, the same calculation was used for each constituent of concern. It was therefore
necessary to convert all of Henry's constants to atm units, (1).

1) Conversion from H2 (atm-m3/mol) to Hi(atm):

HI = (H2 in atm-m3/mol) (55.6 mol water / L) (L / 10'3 m3 water) = H2 * (55,600)

Henry's constants with the following temperatures in degrees Celsius were available:

(1) 20 °C
(2) 24 °C
(3) 25 °C
(4) 40 °C

Henry's constants increase on average about threefold for every 10 °C rise in temperature for most volatile
hydrocarbons.3 Therefore, the constants will increase by a factor of AH = 3. All of the constants were
converted to 54 °C constants using the following conversions

For Henry's constant at 54 °C, and converting from Henry's constants at 20 °C, 24 °C, and 25 °C
respectively:

H54 = (H20)(41.9)

H54 = (H24)(27)

H54 = (H2S)(24.2)
Example - Henry's Constant Calculation

For Acrolein, Henry's constant was available in atm-mVmol for 20 °C (Ha = 9.54 x 10"5)
Therefore, at 54°C, Henry's constant will be:
Ha (atm) = (9.54 x 10'5 atm-m3/mol) (55,600 mol/m3) (41.9)
Ha = 222 atm

Using this approach, the constants were converted to atm units as shown in the table on the following page.
Submarine Emergency Diesel Engine Wet Exhaust
17
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Table of Henry's Constants
Temperature
Source
Units'
Benzene
Toluene
Xylenes
Formaldehyde
Acetaldehyde
Acrolein
NO,
CO
CO2
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Antliracene
Fluoranthene
Pyrene
Ben2o(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd) pyrene
Dibenz(a,h) anthracene
Benzo(g,h,i) perylene
54 °C
Cooper1*
(atm)

4.01E+04
7.85E+04
3.06E+03

20 °C
USEPAC
(atm-m3/mol)

9.87E-07

9.54E-05

1.48E-03

1.16E-06
1.05E-06
1.19E-05
3.94E-05
1.55E-06
6.86E-08
733E-08
5J4E-08
25°C
Mackay4
(atm-m3/mol)
5.43E-03
6.61E-03
637E-03

4.24E-04

237E-04
8.39E-05
3.95E-05
5.92E-05
2.17E-03
1.18E-05

40 °C
CH2MHJU*
(atm-ms/mol)

9.05E-05

Ha for 54 °C
(atm)
7.30 E+03
8.89E+03
8.56E+03
2.30E+00
2.34E+01
2.22E+02
4.01E+04
7.85E+04
3.06E+03
5.71E+02
3.45E+03
3.19E+02
1.13E+02
5.31E+01
7.96E+01
2.92E+03
1.59E+01
2.70E+00
2.44E+00
2.77E+01
9.17E+01
3.61E+00
1.60E-01
1.71E-01
1.24E-01
Bold: Original Referenced Number
a. Kavanaugh, Michael C. and R. Rhodes Trussell, Design of Aeration Towers to Strip Volatile
Contaminants from Drinking Water. American Water Works Association, December, 1980.

b. Cooper, David and F. Alley, Air Pollution Control, A Design Approach. Waveland Press, Inc., 1986.

c. United States Environmental Protection Agency Office of Air Quality Planning and Standards.
Ground-Water and Leachate Treatment Systems Manual. R-94, January 1995.

d. Mackay, Donald and Wan Ying Shiu, A Critical Review of Henry's Law Constants for Chemicals of
Environmental Interest. University of Toronto, Canada, 1981.
": ;' :!" • ;'. •' !;• '
e.' CH2M Hill. Bay Area Sewage Toxic Emissions Model. Version 3,1992.
Submarine Emergency Diesel Engine Wet Exhaust
18
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NATURE OF DISCHARGE REPORT
Submarine Outboard Equipment Grease and External Hydraulics
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS are being developed in three phases. The first phase (which this
report supports) will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs) — either equipment or management practice. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

This section describes the submarine outboard equipment grease and external hydraulics
discharge and includes information on: the equipment that is used and its operation (Section
2.1), general description of the constituents of the discharge (Section 2.2), and the vessels that
produce this discharge (Section 2.3).
V ' > J1'! • • ' I'
2.1 Equipment Description and Operation
•''ii ' : ' !
, : ' il • . ' ' . ' i i , .
This discharge occurs when grease applied to a submarine's outboard equipment is
released to the environment by erosion from the mechanical action of the seawater while the
Ji'llrj'i • ,; " ' I ,i j i mi' , " ,,i ** • , , . i ,. . , , , ,•• • • • ir i,
submarine is underway and, to a much lesser extent, by slow dissolution of the grease into
sdawater. The discharge also includes any hydraulic oil that could leak past the seals of the
hydraulically operated external components of a submarine.
':' , ' i!:- '. ;i ' , " " •...,, II
I' I1 I I •• , • Ii
nil • . • ' , • .. . ; , • I
2.1.1 Grease from Outboard Equipment
, i! ,
'. It 1' ' •, ' , ., ' . > , " ' . ' :,. • " •' ii •'. - I,1
Submarine outboard equipment that requires lubrication includes steering and diving
control mechanisms and control surface bearings. Grease is applied quarterly while a submarine
is in port.1 Figure 1 shows the various grease points on a submarine that can come into contact
with seawater under partially or completely submerged conditions. Of these, the ones that are
operated within 12 nautical miles (n.m.) and could release grease to the environment are the
retractable bow planes, and the fairwater (sail planes). The retractable bow plane components
require the largest amount of grease for operation. Figure 2 is a cut-away diagram of the
refractable bow plane cavity where grease is applied to its various components.
vi; , i..i - • . .. • . •• ,: : i, ••
Bow Plane Mechanisms. The retractable bow planes are a set of fins or control surfaces
that are housed within the envelope of the hull and are extended to provide depth control while
the submarine is moving underwater. These bow planes have mechanisms that slide in and out
causing the bow planes to change position in response to commands from the helm. The sliding
c|mponents are lubricated by an automatic system that applies grease every time they move back
and forth. This movement may cause some grease to loosen and detach from the components
and deposit in the bow plane compartment (20 feet wide by 6 feet long by 5 feet high) which is in
contact with the sea through a narrow, half-inch-wide gap around each bow plane. Because of
this relatively narrow opening to the sea as well as a protective brush that covers this gap
completely around the retractable bow plane, the probability of loose grease in the cavity
washing out of the compartment is low. Currently, only 22 submarines have retractable bow
plane compartments, but future design trends will increase this number.2

Fairwater Plane Mechanisms. Submarines that do not have retractable bow planes have
cgptrpl surfaces that perform a similar function, but which are located on the sail structure.
These are the fairwater planes. Currently, there about 72 submarines in the fleet with fairwater
planes. Fairwater planes have components similar to the retractable bow planes that also
lubricated by greasing, but the components do not contact seawater while the submarine is within
Submarine Outboard Equipment Grease and External Hydraulics
[ i ill,, UiiSiJ'ii' , :!i,,;,,,ll I ;,,, I, ;,i,i, ililllllllUili ,,1,1,!,;, fill",,, mi,,,,, g,,,i'j,!!!l';l !i,,,,l
-------
12 n.m. because the fairwater planes are located well above the water line when the submarine is
surfaced.

2.1.2 External Hydraulics

The external hydraulic system on a submarine supplies hydraulic fluid under pressure to
operate the following equipment:

• masts (e.g. radio antennas, radar, electronic counter measures, etc.), periscopes, and
their associated fairings (e.g., hydrodynamic covers for the various masts and
. periscopes needed to reduce the turbulence while the submarine is running submerged
with the masts and/or periscopes raised);

• retractable bow plane actuator mechanisms; and

• secondary propulsion motor hoist cylinders located outside the pressure hull.

Figure 3 shows the location of masts, antennas, and periscopes on a submarine's hull.
The secondary propulsion motor hoist cylinders (not shown in the figure) are located in an aft
ballast tank.

Navy submarines use specially formulated oil in their external hydraulic systems. The
hydraulic oil is normally pressurized to approximately 1,400 pounds per square inch (psi) and
stored in a reservoir that holds approximately 200 gallons. The total amount of hydraulic oil in
the system, including that in piping and the reservoir, is approximately 250 gallons. On
submarines that have hydraulically-operated retractable bow planes (22 of 94 submarines), the
total amount of hydraulic oil is approximately 400 gallons.3 Of those items identified above
operated by the external hydraulic system, only the retractable bow plane actuator mechanisms
will have any possible release to the environment. In the case of the masts, antennas, and
periscopes, they are located well above the waterline, well away from any contact with the
seawater, where there is no possible erosion of the any oil film generated by the equipments'
operation. In the case of the secondary propulsion motor, it is only operated hi rare emergency
situations, and as such is not covered by the UNDS criteria.

2.2 Releases to the Environment

Grease transport is produced through the mechanical action of the water against
components covered with grease. Underway, some of the loose grease in the bow plane
compartment can be eroded by the mechanical action of the flowing seawater. The amount of
grease released is directly proportional to the force of turbulent water in the vicinity of the grease
resulting in erosion, which, in turn, is directly proportional to submarine speed. Within 12 n.m.,
a submarine's speed is low by comparison to its speed when submerged. It increases speed once
it submerges. Therefore, the amount of mechanical erosion within the 12 n.m. zone is less than
when the submarine is in open ocean.
Submarine Outboard Equipment Grease and External Hydraulics
3
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Very little, if any, grease is discharged when a submarine is pierside because the outboard
equipment is not being actuated, and the erosive action of seawater is minimal when the
submarine is stationary.
1 : ',::,, ' !! '
Periodically, when the submarine is dry docked (typically every two years), grease that
has accumulated in the retractable bow plane compartment is removed and disposed of in an
approved manner by a qualified shore facility.1

Under normal operating conditions, little hydraulic oil is released within 12 n.m. of shore.
Within this zone, the snorkel masts and the antennas are above the water line and do not contact
seawater (except for an occasional sea spray). Hydraulic oil may be released when the external
hydraulic systems are tested during outbound transits. Leaked oil, if any, is likely to be small
quantities that adhere to the component surface. Only when the submarine submerges (beyond
12 run.) will the oil be washed away. Oil releases from bow planes generally remain in the
upper area of the cavities surrounding the planes. Because of the small size, configuration,
location of the bow plane cavity opening, and minimal seawater turbulence, transport of trapped
oil to the sea is unlikely. Further, only 22 of the 94 submarines in service have hydraulically
operated bow planes. The secondary propulsion motor is available as a backup option to
maneuver close to port when needed. Typically, tugs are available for this purpose and the
secondary propulsion motor is not used under normal operating circumstances.

2.3 Vessels Producing the Discharge

All submarines have lubricated outboard equipment and external hydraulic systems.
Because all submarines belong to the Navy, this discharge is not produced by vessels belonging
to the Army, Air Force, U.S. Coast Guard, and the Military Sealift Command.
3.0 DISCHARGE CHARACTERISTICS

Outboard equipment grease can be discharged within 12 n.m. of shore. The amount is
dependent on how much contact there is between the seawater and the greased components, and
how fast the vessel is traveling. Most hydraulically operated outboard equipment does not
contact seawater within 12 n.m. of shore because submarines usually run surfaced in this zone
and the outboard equipment is mostly above the waterline. Submarine dive points are outside the
12 n.m. zone except for those dive points off the coast of the Hawaiian islands and Washington
state.
4,5
Submarine Outboard Equipment Grease and External Hydraulics
-------
3.2 Rate

This discharge is the washout of oil and grease when lubricated components and
components with hydraulic oil come in contact with flowing seawater.

Grease. A rough estimate of grease discharge can be made based on the total amount
used. Each attack submarine (SSN) uses approximately 425 pounds of grease annually, while
each missile submarine (SSBN) uses an estimated 800 pounds annually.2 Approximately 81% of
the submarine fleet are SSNs and 19% are SSBNs. On a weighted average basis, therefore, each
submarine uses approximately 496 pounds of grease each year.

The grease is released primarily by the mechanical action of the seawater against the
greased submarine components and, therefore, happens only when the submarine is underway.
Each submarine enters and leaves port approximately six times per year.3'6 A typical one-way
trip through the 12 n.m. zone lasts approximately 4 hours; therefore, the total annual transit time
through that zone is 48 hours per submarine ((6) (4) (2) = 48).6 A submarine typically spends 6
months, or 183 days, moving in the water so transit time accounts for less than 1.1% of this total
time at sea. Therefore, 1.1% of the total grease used can be assumed to be released during
transits.3'4' The resulting 1.1% of the 496 pounds of grease per vessel per year is equivalent to a
discharge rate of approximately 5.5 pounds of grease for each vessel per year within 12 n.m.

Hydraulic Oil. Hydraulic oil is retained in the system by internal and external seals; the
former prevents hydraulic oil from leaking into the submarine, while the latter prevents oil from
leaking outside the hull. Because some leaks still occur, the Navy has established acceptable
leak rates.7 For newly installed seals, the specification allows "a slight wetting of the tailrod or
other visible part of the sealing area." In addition to the "slight wetting" qualitative criterion, the
specification also provides a quantitative leak rate standard of one drop every 25 cycles for each
inch (or fraction) of rod (length) or seal diameter. For example, a cylinder with a 2.25-inch
diameter rotating tailrod would be allowed to leak at a rate of three drops every 25 cycles. A
cycle is defined as moving from a fully retracted position to a folly extended position and back.7

The specification also contains seal replacement criteria. If leaks occur when a
component is not operating, the seal should be replaced when the leak rate is four milliliters (mL)
or more per hour for each inch (or fraction) of seal diameter. If leaks occur when a component is
cycled, the seal should be replaced when a leak rate of one mL or more per inch of seal diameter
(or fraction) for every 10 cycles is observed.

Leak rate standards can be used to estimate the amount of oil that leaks into the sea from
external hydraulic systems seals. For example, the two bow planes, when deployed, are each 7.5
feet long. At a rate of one drop of oil every 25 cycles for each inch of rod length, the acceptable
leak rate for the two diving planes, which are a combined 15 feet long, is 180 drops (15 feet =
180 inches) every 25 cycles. Assuming that 10 drops are equivalent to one mL,2 18 mL of oil
will leak every 25 cycles. Therefore, each time the bow planes are extended and retracted (one
cycle), approximately 0.72 mL (18 mL/ 25 cycles) of oil will be released but will likely remain in
the bow plane cavity. Assuming six outbound transits per year for each vessel and that the vessel
Submarine Outboard Equipment Grease and External Hydraulics
5
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cycles its retractable bow planes twice during each transit, this would result in a discharge rate of
8.64 mL of oil discharged per vessel per year. This calculation assumes that external hydraulic
systems are tested during outbound transits only.

33 Constituents

This discharge consists of Termalene #2 grease and hydraulic oil. Termalene #2 consists
of mineral oil, a calcium-based rust inhibitor, an antioxidant, and dye.8 Hydraulic oil consists of
heavy paraffinic distillates and additives.

In general, greases are made from lubricating stocks generated during petroleum
fractionation. These fractions contain organic compounds (Cn or higher). Lubricating oils are
composed of aiiphatic, olefinic, naphthenic (cycloparaffinic), as well as aromatic hydrocarbons,
depending on their specific use. Lubricating oil additives include antioxidants, bearing
protectors, wearresisters, dispersants, detergents, viscosity index improvers, pourpoint
depressors, and antifoaming and rust-resisting agents.9 Lubricating oils and greases could have
priority pollutants. No bioaccumulators are expected.

3.4 Concentrations

The discharge consists of 100% grease and oil in their pure form as they are washed away
from the vessel's surface due to mechanical action of water. Because the oil or grease do not
become mixed with water until they contact the surrounding seawater, concentrations in the
discharge cannot be defined in the conventional sense. It is known that the hydraulic oil consists
of 95-99% heavy paraffinic distillates.10 The remainder consists of additives.
• ii i

4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.6, the nature of discharge
and its potential impact on the environment can be evaluated. The estimated mass loadings are
presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents after release
to the environment are estimated and compared with the water quality criteria, hi Section 4.3,
the potential for transfer of non-indigenous species is discussed.

4.1 Mass Loading

4.1.1 Grease From Outboard Equipment

Using the assumption that 100% of the applied grease is washed away, the annual amount
of grease discharged by each submarine within 12 n.m. is 1.1% of the total grease used (Section
3.2), or approximately 5.5 pounds per vessel per year. Based on 94 submarines, the total amount
of grease discharged within 12 n.m. on an annual basis is 517 pounds.

4.1.2 External Hydraulics

Submarine Outboard Equipment Grease and External Hydraulics
6
,.i •iiiiiiiiiiii:,-,,, italic ^
-------
Based on a per vessel discharge rate of 1.44 mL per vessel per transit (six transits per
vessel per year) or 8.64 mL per vessel per year and given that there are 22 submarines currently
existing in the fleet that contribute to this discharge, the fleet wide mass loading is 190 mL per
year. This is equivalent to 0.0029 pound (Ib) per vessel per transit (at a density of 7.51 Ib/gallon)
or 0.3755 Ib of oil released per year by the entire submarine fleet.

4.2 Environmental Concentrations

As a submarine moves, it creates a disturbance in the surrounding seawater. This
disturbed volume of seawater maybe thought of as a mixing zone in which discharges from the
submarine would be dispersed. This volume of seawater was estimated and used in
concentration calculations. A sample calculation for a SSN 688 Class submarine is presented
below. The calculation was based on the following assumptions:

• SSN 688 Class submarine has a total width of 33 feet.11
• Width is the diameter of the vessel's cross section.
• A mixing zone of 10 feet around the hull, based on the width of wake behind a
typical SSN.
• The discharge is mixed uniformly throughout the mixing zone over the entire
transit.
• The submarine is only partially submerged, at an approximate depth of 28 feet
1) ^Cross-sectional area=(area of submarine cross section and,disturbed width) -Xarek of the
chord representing that portion of the circle above the,$urface of the water)
area= 1(3.14) (33/23- 10)2J - [area of a chord of height 15 ft of a circle of radius 26.5 ft]
area = 2,206 ft2 -514 ft2 = 169241? , '; . -"*;

2) Volume of water swept = (area) (12 sum; distance)
volume.» (1,692 fl?) (72,960 ft) = 1.23Ix lO^ft3, or 123 million cubic feet
The width of submarines ranges from 31.8 feet (SSN 637 Class) to 42.3 feet (SSN 21
Class).11 Therefore, the range of volume of water swept, using similar calculations to those
above, would be 118 million cubic feet to 158 million cubic feet per submarine per transit.

4.2.1 Grease from Outboard Equipment

To develop environmental concentration estimates for grease, it is assumed that the 5
pounds of grease discharged per year are evenly distributed over the 12 transits through the 12
n.m. zone. Therefore, for each transit, approximately 0.46 pound (5.5 pounds of grease per
submarine per year divided by 12 transits per year) of grease is discharged. Based on the
previous calculations, the smallest volume of water swept by a submarine is 118 million cubic
feet by the SSN 637 Class. Therefore, the concentration in the environment was estimated as
Submarine Outboard Equipment Grease and External Hydraulics
7
-------
i;]!!'"!)'' i
*;:Jl:l!,'-11:!!i|1 1 II
l i ill
presented below: (Note: The calculations were based on the area swept by the SSN 637 class
hull as it represents the smallest swept area.)
0.46 pound of grease * 1 .18 x 108 ft3 of water
= 208.6 g of grease in 3.34 x 1Q9 Liters of water
= 6.2 xJLQ-*g/L = 0.062
This estimated concentration was based on 100% of the grease being washed away. Most
grease discharged remains in hull cavities and is removed from the submarine during
maintenance. Although open to seawater, the 0.5-inch-wide gaps around retractable bow planes
are well shielded by close-fitting brushes, and the seawater in the compartment or cavity is
quiescent compared to water moving over the hull. Therefore, the rate of grease erosion will be
lower than the amount calculated.

4.2.2 External Hydraulics

To estimate environmental concentrations for hydraulic oil, the following assumptions are
made:

- Volume of water swept by the submarine is 118 million ft3 or 3.34 x 109 liters per
;: transit.,
- The discharge rate of hydraulic oil is 0.0029 Ib per vessel per transit uniformly
distributed throughout the transit.
. ,!,;: ! ! ', ' ' ' ' ,j|, I
Based on the above assumptions, the environmental concentration can be estimated as follows:
1) Oil released = 0.0029 Ibs = 1.32 g of oil released per vessel per transit
2) Concentration = (g of oil released)*- (liters of water)
= (1.32 §)-=- (3.34 x!09L)
= 3.95 x 10'™ g/L = 3.95 x 10"* {ig/L
4.2.3 Total Releases
i1 r • * . ii i

Based on the environmental concentrations estimated above, the total oil & grease
concentration in the surrounding water would be the sum of individual concentrations, i.e., 0.062
plg/L + 0.000395 p.g/L = 0.062395 |J.g/L, or approximately 0.06 |ig/L. This concentration does
ndt exceed federal discharge standards and state water quality criteria as shown in Table 1.
•j , '! • • ' .'•'•' . * ; ' il . 1
„(! '
-------
5.0 CONCLUSIONS

The submarine outboard equipment grease and external hydraulics system discharge has a
low potential to cause an adverse environmental effect. This is due to the small amounts of
lubricant released when the vessel is underway is dispersed to concentrations below water quality
criteria. The estimated concentrations of oil and grease in the environment that results from
movement of submarines, is 0.06 ppb, which is far below Federal and most stringent state water
quality criteria. These concentrations were estimated based on the volume of water (3.3 billion
liters) swept by a submarine while in transit through the 12 n.m. zone, and the conservatively
estimated amount of oil and grease released during transit (1.44 mL and 0.46 pounds,
respectively).
6.0 DATA SOURCES AND REFERENCES

To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge. Based on this estimate
and on the reported concentrations of oil and grease components, the concentrations of oil and
grease in the environment resulting from this discharge were then estimated. Table 2 shows the
sources of the data used to develop this NOD report.

Specific References
1. UNDS Equipment Expert Meeting, Submarine Outboard Equipment Grease. September
1,1996.

2. UNDS Round 2 Equipment Expert Meeting Minutes, March 24, 1997.
3.

7.
Personal Communication between Commander, Submarine Forces, Atlantic Fleet, Staff
Environmental Officer, LCDR L. McFarland and Bruce Miller, MR&S. April 28,1997.

Commander, Submarine Forces, Atlantic Fleet, Staff Environmental Officer, LCDR L.
McFarland. CINCLANTFLT meeting with SEA OOT/03L, May 13, 1997.

Personal Communication between Commander, Submarine Forces Pacific Fleet, Staff
Environmental Officer, LCDR W. Jederberg and Bruce Miller, MR&S, Sept 11,1997.

Pentagon Ship Movement Data for Years 1991-95, March 4,1997.

Naval Ship's Technical Manual (NSTM), Chapter 556, Revision 2, Hydraulic Equipment
Power Transmission and Control, pp 11-1 and 11-2. March 1,1993.
8. Bel-Ray Company, Inc., Material Safety Data Sheet for Termalene #2, May 5,1998.

Submarine Outboard Equipment Grease and External Hydraulics
9
-------
"i :•
9. Patty's industrial Hygiene and Toxicology, Volume JJB, 3rd Revised Edition, 1981, pp
3369,339?:

10." Material Safely Data Sheet, Imperial 2075 TH Petroleum Base Hydraulic Fluid, January
1998.

11. Jane's information Group, Jane's Fighting Ships. Capt. Richard Sharpe, Ed. Sentinel
House: Surrey, United Kingdom, 1996.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B| 40 CFR Part 131.36.
' : . i, . i ' • , , | ;
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.
. I :' , • , ' .11
,rM' , V : ' ! , •.!".. I
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
"I iii i ' :•', ji, •
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. 62, Number 150. August 5,1997.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.
.' .!.! ' , ' ' "l • , ||' '
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
;; , . ::," ' 'iii:J , ' . ' • ' •• :;l' " ' in .
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
Submarine Outboard Equipment Grease and External Hydraulics
10
-------
Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. 23 March 1995.
Submarine Outboard Equipment Grease and External Hydraulics
11
-------
Table 1. Comparison of Environmental Concentration with Relevant Water Quality
Criteria
Constituent
Oil & Grease
Concentration
6ng/L
Federal Discharge Standard
visible sheen" / 15,000 ng/Lb
Florida Acute Water
Quality Criteria
5,000 ng/L
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
* Discharge ofOil^AO CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen
on receiving waters.
b International Convention for the Prevention of'Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as
implemented by the Act to Prevent Pollution from Ships (APPS)
Table 2. Data Sources

NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
33 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
43 Potential for Introducing Non-
Indigenous Species
Data Source
Reported

UNDS Database

Sampling

Estimated

X
X
X
Equipment Expert
X
X
X
X

X
X

X
Submarine Outboard Equipment Grease and External Hydraulics
12
-------
\
Figure 1. Submarine Points of Contact of Grease and Seawater
Submarine Outboard Equipment Grease and External Hydraulics
13
-------
Figure 2. Retractable Bow Plane Arrangement (Typical)
Submarine Outboard Equipment Grease and External Hydraulics
14
1
-------
-------
-------
NATURE OF DISCHARGE REPORT
Surface Vessel Bttgewater/OU Water Separator {OWS) Discharge'
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the armed forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed in three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.

A nature of discharge (NOD) report has been prepared for each of the discharges that
have been identified as candidates for regulation under UNDS. The NOD reports were
developed based on information obtained from the technical community within the Navy and
other branches of the armed services with vessels potentially subject to UNDS, from information
available in existing technical reports and documentation, and, when required, from data
obtained from discharge samples that were collected under the UNDS program.

This section describes the bilgewater/OWS discharge and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
tfip discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
'"'' ' |! "" " • •' i; "" '!'
2.1 Equipment Description and Operation

2.1.1 The Bilge Area

The lowest inner part of the hull where liquid drains from the interior spaces and the
Upper decks of the vessel is referred to as the bilge. The primary sources of drainage into the
bilge are the main engine room(s) and the auxiliary machinery room(s), which house the vessel's
propulsion system and auxiliary systems (i.e., steam boilers and water purification systems),
respectively. Other spaces that collect and contain fluid drainage in their bilge are the shaft alley,
steering gear rooms, pump rooms, and air conditioning and refrigeration machinery rooms.
Some oil lab sink drains are also directed to the bilge. The liquid collected in the bilge is known
as "bilgewater" or "oily wastewater".

2.1.2 Composition of Bilgewater

The composition of bilgewater varies from vessel to vessel; the composition of bilgewater
also varies from day to day on the same vessel. Certain wastestreams, including steam
condensate, boiler blowdown, drinking fountain water, and sink drainage located in various
machinery spaces, can drain to the bilge. The propulsion system and auxiliary systems use fuels,
lubricants, hydraulic fluid, antifreeze, solvents, and cleaning chemicals, as part of routine
operation and maintenance. Small quantities of these materials enter the bilge as leaks and spills
in the engineering spaces. On some older vessels, excess potable water produced by onboard
water purification systems is directed to the bilge, although this practice is being phased out.1 On
sgme Navy and Coast Guard vessels, water from gas turbine washdowns can contribute to
bilgewater generation; these washdowns are described hi the Gas Turbine Water Wash NOD
report.

2.1.3 Bilgewater Treatment and Transfer System

Every surface vessel has an onboard system for collecting and transferring bilgewater.
Vessels pump collected bilgewater to a holding tank which the Navy refers to as the oily waste
holding tank (OWHT). Some vessels are capable of transferring bilgewater from the OWHT to
shore facilities while pierside. OWS systems are installed on vessels, as appropriate, to reduce
the oil content of bilgewater prior to overboard discharge. These systems receive bilgewater
from the OWHT and use gravity-phase separation, coalescence, centrifugal separation, or
Combinations of these technologies to treat the waste.
1 i i.i,i , • IB " : • • i

A commonly used Navy OWS is a coalescing plate gravity separator. This type of
separator has a horizontal set of oleophilic plates. Oil droplets rise and coalesce as they flow
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
2
-------
through the plates. The droplets cling to and wet the oleophilic plates once they rise to a plate's
underside. When sufficient oil has accumulated, large oil droplets rise through weep holes in the
plates and flow to the top of the OWS. The separated oil is then transferred to a waste oil tank
(WOT). Figure 1 is a process flow diagram of the standard OWS system used on most Navy
vessels.

On some vessels, oil content monitors (OCMs) are installed to prevent the discharge of
unacceptable effluent. If the oil content is above the set point limit, the OCM alarms and diverts
the OWS effluent back to the OWHT for reprocessing until an acceptable oil concentration
reading is obtained.

In addition to the oil removed by the OWS, waste oil from routine maintenance is also
collected in the WOT and held for pierside disposal.

Synthetic lubricant oils (SLOs) are not collected in the WOT, and measures are taken to
prevent their introduction into the bilge. SLOs have a specific gravity close to that of water and
cannot be separated in the OWS. These oils are normally found in engine spaces and are
collected in drip pans located underneath the engines. The drip pans drain through segregated
piping to dedicated collection tanks. SLOs within these tanks are disposed of on-shore separately
from non-synthetic waste oils. Therefore, SLOs, except for tank overflows, are not likely to be in
bilgewater at significant levels.

Some ships (e.g., DDG 51 Class destroyers) use non-oily machinery wastewater
collection systems that segregate oily wastewater from non-oily wastewater. These ships collect
non-oily machinery wastewater in dedicated collection tanks instead of the bilge, and discharge it
directly overboard. All oily wastewater collects in OWHTs and is processed by a shipboard
OWS or off-loaded for shore facility treatment.

2.2 Releases to the Environment

Untreated bilgewater is expected to contain oil and grease (O&G), an assortment of
oxygen-demanding substances, and organic and inorganic materials. These materials include
volatile organic compounds (VOCs), semi-volatile organic, inorganic salts, and metals. OWS
effluent releases to the environment contain the same constituents present in bilgewater but with
lower concentrations of O&G and oil-soluble components.

2.3 Vessels Producing the Discharge

All vessels produce bilgewater. OWS systems have been installed on most vessels of the
Armed Forces. Some small boats and craft are not outfitted with OWS systems; thus, bilgewater
is stored for shore disposal. Table 1 lists all surface vessels equipped with OWSs. Submarine
bilgewater is addressed in the Submarine Bilgewater NOD report.
3.0 DISCHARGE CHARACTERISTICS
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
3
-------
This section contains qualitative and quantitative information which characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and near-
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

The Armed Forces do not discharge untreated bilgewater to surface waters. On ships
without OWS systems, untreated bilgewater is held for transfer to a shore treatment facility.
Bilgewater treated by an OWS can be discharged within or beyond 12 nautical miles (n.m.). On
Navy vessels with an OWS and OCM, oil concentrations must be less than 15 parts per million
(ppm) prior to discharge. However aboard Navy vessels, discharge of bilgewater with an oil
Concentration Jess than 100 ppm is allowed outside 12 n.m. if concentrations less than 15 ppm
cannot fee acrueved because of operating conditions.

3.2 Rate
j; . •? '•;•.. :', . . j i . .
Bilgewater generation rates vary by vessel and vessel class because of the differences in
Vessel age, shipboard equipment (e.g., type of propulsion system), operations, and procedures.
Vessels with non:pily machinery wastewater collection systems will generate significantly less
Bilgewater because of their capability to keep non-oily waste streams out of the bilges. The DDG
Jl and CVN 68 class ships are two examples of ship classes that have non-oily machinery
wastewater ppllection systems. Other factors influencing bilgewater generation rates are whether
a vessel is operating in-port or at-sea, and when in port, whether it is operating hi an auxiliary
steaming m63e or receiving shore electrical/steam power (cold iron mode). In the auxiliary
steaming mode, a vessel provides its own services while moored at the pier (i.e., power,
freshwater, etc.). In the cold iron mode, a vessel receives these services from shore facilities,
minimizing me amount of shipboard equipment in operation. Older vessels without non-oily
machinery wastewater collection systems have historically generated more bilgewater while
operating in the auxiliary steaming mode than in the cold iron mode because of the discharge of
Utilities wastewater to the bilge.
i :.i • .11 ' « . ' i . . , • I • • . • • .. .
:,;. , , , . i;
Table 2 shows the in-port bilgewater generation rates for certain destroyers (DD 963 and
DDG 51 Classes) and aircraft carriers (CVN 68 Class). For the destroyers, bilgewater generation
rates were developed by monitoring the levels of bilgewater in the bilges.1'2 Aircraft carrier class
(CVN 68) data was gathered from an analysis of a carrier's (CVN 74) OWS operator log sheets
in order to determine the amount of bilgewater that had passed through the OWS over an
extended period of time, thus providing an estimate of the bilgewater generation rate.3

Table 3 summarizes the bilgewater/OWS flow rates that were developed for an aircraft
carrier class (CVN 68), "other ship classes," and the overall fleet based on the average values
from Table 2. The assumptions that were made in developing the estimates are summarized as
follows:
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
"i ',' 4
-------
1. The average and maximum daily bilgewater OWS discharge flow rates for a carrier
(CVN 74) of 3,000 and 25,000 gallons per day (gpd), respectively, represents the
average and maximum daily bilgewater/OWS flow for all aircraft carriers.

2. The destroyer (DD 963) bilgewater flow estimate of 1,000 to 3,000 gpd represents a
typical range of flows for other U.S. Navy surface ship classes. An average of 2,000
gpd is assumed to be the average bilgewater generation rate.

3. Aircraft carriers spend approximately 147 days in port annually.

4. Other ships are in port for approximately 193 days annually.

The calculations used to estimate the total fleet bilgewater OWS effluent discharge to
surface waters within 12 n.m. are presented as follows:

CVN 68 Class
.FcvN(flow rate) =% CRCVN)(DCVN) (New)
RCVN - ship flow rate, gpd ..
- DCVN =
-------
previous studies, samples of bilgewater were collected from a variety of Navy vessels, including
aircraft carriers, cruisers, destroyers, dock landing ships, tank landing ships, amphibious assault
ships, amphibious transport docks, and submarines. There have been no similar studies or
documentation available for the other services.

Bilgewater samples collected in the previous studies were analyzed for a variety of
parameters, such as classicals, metals, and organics (including pesticides). Over 25 priority
pollutants were identified from these samples, including metals such as arsenic, copper,
cadmium, chromium, lead, mercury, selenium, and zinc; and organics such as benzene, the BHC
isomers (isomers of hexachlorocyclohexane), ethyl benzene, heptachlor, heptachlor epoxide,
naphthalene, phenols, phthalate esters, toluene, trichlorobenzene, and trichloroethane. The
bioaccumulators identified in these samples were the BHC isomers and mercury. A variety of
substances that are neither priority pollutants nor bioaccumulators were also detected, including
metals such as barium and manganese and organics such as chloroform and xylene.
!" ' . •••,', 'il|fl ' ' ' • •', ,•'':, 1 i ,

The analytical results from these studies are shown in Tables 4 through 8. The results
provide a general overview of the constituents that have historically been detected in bilgewater
and the effluent from bilgewater OWS treatment.
T ' •' T" «i •• •• • • • , i

3.4 Concentrations
• ;.fr , i , i ' ' i
The concentrations of constituents detected during UNDS Phase I testing of
bilgewater/OWS effluent samples collected aboard an aircraft carrier (CVN 74) are summarized
in Table 9. Many of'the same constituents that were detected in the previous studies were also
detected in the aircraft carrier samples. This includes classicals, oil & grease as indicated by
hexane extractable materials (HEM) or total petroleum hydrocarbons (TPH) as indicated by silica
gel treated hexane extractable materials (SGT-HEM), certain metals, and the bioaccumulator,
mercury. Neither pesticides nor PCBs were detected in the aircraft carrier bilgewater/OWS
samples. Table 10 presents the general statistics of the aircraft carrier data.

Analytical results from previous bilgewater studies are shown in Tables 4 through 8.
These tables provide concentrations of constituents that have historically been detected in
bilgewater and the effluent from bilgewater OWS treatment.
4,0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. Estimated constituent
mass loadings are presented in Section 4.1. In Section 4.2, the available concentration data for
the discharge constituents are evaluated, including comparison with federal and state water
quality criteria. la Section 4.3, the potential for the transfer of non-indigenous species is
discussed.

4.1 Mass Loading
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
6
-------
Validated bilgewater/OWS constituent concentration data from the aircraft carrier 4 and
the flow rate estimates referenced in NOD report Section 3.2 were used to estimate the mass
loading of pollutants to the environment. Historical data were not used to estimate mass loadings
because these data were not validated.

Table 11 provides a bilgewater/OWS effluent mass loading summary for all constituents
detected in the aircraft carrier samples. Sampling data have identified copper, nickel, and zinc as
exceeding Federal water quality criteria (in addition to the most stringent state criteria) in the
bilgewater/OWS samples analyzed. Also, the concentrations for ammonia, nitrogen (as
nitrate/nitrite and total kjeldahl nitrogen), phosphorous, iron, and total petroleum hydrocarbons
exceeds the most stringent state water quality criteria.

The constituent loading estimates are based on the assumption that vessels with an on-
board OWS system will always process bilgewater through the system and discharge the effluent
overboard while in-port, rather than off-loading untreated bilgewater to shore facilities for
disposal.

Sample calculations for TPH, as indicated by SGT-HEM, are provided to show how the
total fleet constituent discharges to surface waters less than 12 n.m. from shore were calculated.
The assumptions and calculations are presented below.

1. The total amount of OWS effluent discharged annually from aircraft carriers is 4.9 million
gallons (Table 3).

2. The sample data from CVN 74 (Table 10) are assumed to be representative of all aircraft
carriers. ... . ......'
where:
„ M(tph)cvN (pounds/year) = (Vcw (sallion gals/year)) (CcvN (rag/Liter)) (CF)

~ Total bilgewater/OWS generation rate/year ., ,
= TPH (SGT-HEM) concentration ~ i
CF\= conversion factor = 8.34= (3.785 liters/gal') (Ixl0s gals/million aals>
(454 grams/pound) (1,000 mg/gram)

- (4.9) (9.64) (8.34) = 394 pounds/year
The mass loading of constituents for the entire fleet can be estimated by multiplying the estimate
for aircraft carriers by a discharge ratio. The discharge ratio is the total fleet discharge rate
divided by the total discharge from aircraft carriers. Use of this ratio to estimate fleet mass
loadings assumes sample data from CVN 74 (Table 10) is representative of all vessels of the
armed forces.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
7
-------
2. Ratioing the total flow for the fleet (89.8 mgd) to the aircraft carrier class (CVN 68) flow for
(4.9 mgd) , and multiplying the aircraft carrier loading by the ratio.
MFLEET =

MFLEET = (89.8/4.9)(394)=7220 pounds/year
4.2 Environmental Concentrations
. !. '' : . • . ' .. ' il i ' '
Table 11 identifies bilgewater OWS effluent constituents in the aircraft carrier samples
whose log mean average concentrations (dissolved and/or total) were above Federal water quality
criteria, and/or the most stringent state water quality criteria. With regard to oil concentration
data, the samples were analyzed for HEM and SGT-HEM. The HEM values correspond to oil
and grease and the SGT-HEM values correspond to total petroleum hydrocarbon (TPH) which is
a subset of oil and grease.

4.3 Potential for Introducing Non-indigenous Species
: •" . • "" .!' ' • •'"'.
There is a low potential for transporting non-indigenous species hi this discharge. There
is pnly minor seawater access to bilge compartments, and bilgewater is generally processed
before it is transported over long distances.
5,0 CONCLUSIONS
; . i i •; i! ' • ' , • • ; " '
Surface vessel bilgewater and OWS discharges have the potential to cause an adverse
environmental effect for the following reasons:

1) Bilgewater, if discharged without treatment, would contribute significant amounts of oil to the
environment at concentrations exceeding water quality criteria and discharge standards.
1 ' . ;i.,;! ! ,i '^'liii ' ' ' ' I
2) OWS effluent contributes significant amounts of oil to the environment at concentrations
exceeding water quality criteria and discharge standards.
6.0 DATA SOURCES AND REFERENCES
Based
To characterize this discharge, information from various sources was
information and assumptions were used to estimate the rate of discharge.
and on the reported concentrations of oil and grease constituents, the concentrations
and grease constituents in the environment resulting from this discharge
! were
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
8
obtained. Process
on this estimate
of the oil
then estimated.
-------
Table 12 shows the source of the data used to develop this NOD Report.

1. Bilgewater Characterization and Generation Surveys Aboard DD-963 Class Ships. April,
1981. David Taylor Naval Ship Research and Development Center. Report #:
DTNSRDC/SME-81/09.

2. In-Port Oily Wastewater Generation on USS ARLEIGH BURKE (DDG 51), NSWCCD-TR-
63-96/37. November 1996.

3. USS John C. Stennis (CVN 74) OWS log sheets obtained from CVN 74 by J. Jereb of DLS
Engineering Assoc. and submitted to Malcolm-Pirnie via facsimile on February 13,1997.

4. Correspondence from Commander, Naval Surface Warfare Center, Carderock Division,
Philadelphia Site to Commander, Naval Sea Systems Command (Code 03L13), Uniform
National Discharge Standards (UNDS) Sampling Program Data, Ser 631/225,1-6310-280,
dated June 19,1997.

5. The Characterization of Bilgewater Aboard U.S. Navy Ships. October 1992. Naval Surface
Warfare Center Carderock Division. Tech. Report #: CDNSWC/SME-CR-10-91.

6. Weaver, George, An Analysis of Bilgewater. Undated, Analytical data for period from 1993
to 1995. Navy Public Works Center Environmental Department, Naval Station San Diego.

7. Wastewater Characterization Data from USS L Y Spear (AS 36) and USS Carney (DDG 64),
NSWCCD, 6330-270/KA, February 19, 1997, Enclosures (4) and (6).

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
9
-------
Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.

Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

ifawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
•'.; . ' . ;.i .',!!. . .:: . -,' ,jl
Ivflississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.
liti" , • v, ' ' i" •
New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).

Navy Small Craft Bilge Generation and Characterization. March, 1987. David W. Taylor Naval
Ship Research and Development Center, Report No. DTNSRDC/SME-86/32.

Personal Communication between C. Geiling, Malcolm-Pirnie, and Brian Gordon, NAVSTA San
Diego, Week of February 17,1997, Topic of discussion: bilgewater characterization.
"' ' ' i W ' ' , i i ' »
Erivironmental and Natural Resources Program Manual, OPNAVTNST 5090. IB, Department of
the Navy, November 1,1994.

Department of Defense (DoD) Directive 6050.15 of 14 June 1985, Prevention of Oil Pollution
from Ships Owned or Operated by the DoD (NOTAL).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.

UNDS Equipment Expert Meeting Minutes. "Surface Vessel Bilgewater and Oily Waste". July
29,1996.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
10
-------
Pentagon Ship Movement Data for Years 1991-95, March 4,1997.

UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.

UNDS Ship Database, August 1,1997.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
11
-------
I
po ys
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is

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ao
es
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en
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;«,„„„ iilllll!: j ,. jji itiii:,! ti.il lililli: .••li..idiliiiiiij lil iiillli i !,;,!! ijillli,. iliiai,.„:,'..",;..i„.-:, rll 'itiiLiii i i .,i:,l: I:.,t:., ili. j., iM i..!:.;.:i: i.ii:,!,!.i,,.i iiiilM^^^^^^^^^^!;:" iiii^ li.J-rfci;.;,. 4 h iJiiHit '
-------
Table 1. Vessels Equipped With Oil/Water Separator Systems
SHIP CLASSIFICATION INFORMATION , *- ,
CLASS"
ID NO.
AE 26
AFS 1
AG 194
AGF3
AGF11
AGM 22
AGOS 1
AGOS 19
AGS 26
AGS 45
AGS 51
AGS 60
AH 19
AKR 287
AKR 295
AO 177
AO 187
AOE 1
AOE 6
AR
ARC 7
ARS 50
AS 33
AS 39
ATF 166
BD
BO
BOSL
CG 47
CGN 36
CON 38
CV 63
CVN 65
CVN 68
DD 963
DDG 51
DDG 993
FFG 7
LCC 19
LCU
LHA 1
LHD 1
ARMEIX
SERVICE
MSC
MSC
MSC
NAVY
NAVY
MSC
MSC
MSC
MSC
MSC
MSC
MSC
MSC
MSC
MSC
NAVY
MSC
NAVY
NAVY
NAVY
MSC
NAVY
NAVY
NAVY
MSC
ARMY
USCG
USCG
NAVY
NAVY
NAVY
NAVY
NAVY
NAVY
NAVY
NAVY
NAVY
NAVY
NAVY
ARMY
NAVY
NAVY
'-" CLASS
NAME
Cilauea
ilars
Vanguard
Austin (Converted)
Austin (Converted)
Converted Haskell
Stalwart
Victorious
Silas Bent and Wilkes
Waters
(ohn McDonnell
Pathfinder
Mercy
Algol
NA
Jumboised Cimarron
Henry J. Kaiser
Sacramento
Supply
Vulcan
Zeus
Safeguard
Simon Lake
Emory S Land
Powhatan
264B
NA
NA
Ticonderoga
California
Virginia
Kitty Hawk
Enterprise
Nimitz
Spruance
Arleigh Burke
Kidd
Oliver Hazard Perry
Blue Ridge
2000
Tarawa
Wasp
f'~* ," " •*, a,
SHIP TYPE,
Ammunition Ship
Combat Store Ship (ROS)
Navigation Research Ship
Miscellaneous Command Ship
Miscellaneous Command Ship
Missile Range Instrumentation Ship
Ocean Surveillance Ship
Ocean Surveillance Ship
Surveying Ship
Surveying Ship
Surveying Ship
Surveying Ship
Hospital Ship (ROS)
Vehicle Cargo Ship (ROS)
Vehicle Cargo Ship (ROS)
Oiler
Oiler
Fast Combat Support Ship
Fast Combat Support Ship
Repair Ship
Cable Ship
Salvage Ships
Submarine Tender
Submarine Tender
Fleet Ocean Tug
Barge Derrick(FIoating Cranes)
Buoy Boat
Stern Loading Buoy Boat
Guided Missile Cruiser
Guided Missile Cruiser
Guided Missile Cruiser
Aircraft Carrier
Aircraft Carrier
Aircraft Carrier
Destroyer (Typical)
Guided Missile Destroyer
Guided Missile Destroyer
Guided Missile Frigate
Amphibious Command Ship
Utility Landing Craft
Amphibious Assault Ship
Amphibious Assault Ship
NO. OF
SHIPS
8
8
2
1
1
1
5
4
2
1
2
4
2
8
3
5
12
4
3
6
1
4
1
3
7
12
5
14
27
2
1
3
1
7
31
18
4
43
2
48
S.
4
PROPULSION
-. SYSTEM
Steam
Steam
Steam
Steam
Steam
Steam
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Steam
Steam
Diesel
Steam
Diesel
Steam
Gas
Steam
Diesel
Diesel
Steam
Steam
Diesel
Diesel
Diesel
Diesel
Gas
Nuclear
Nuclear
Steam
Nuclear
Nuclear
Gas
Gas
Gas
Gas
Steam
Diesel
Steam
Steam
TRANSIT - '
INFORMATION
TRAN- DAYS IN
sirs PORT
4 26
7 148
10 151
NA NA
NA NA
4 133
4 70
5 107
6 44
1 7
6 96
NA NA
2 184
3 109
NA NA
10 188
6 78
11 183
6 114
8 131
2 8
22 208
6 229
6 293
16 127
NA NA
NA NA
NA NA
12 166
11 143
11 161
7 137
6 76
7 147
12 178
11 101
12 175
13 167
8 179
NA NA
9 173
13 185
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
13
-------
Table 1. Vessels Equipped With Oil/Water Separator Systems (cont'd)

1 .,,,,,„„ „ ,,, , , ,,, „,
CLASS
ID NO.
LPD 4
LPD 7
LPD 14
LPH 2
LSD 36
LSD 41
LSD 49
LST 1179
LSV
LT
MCM 1
MHC 51
WAGB 290
WAGB 399
WHEC 378
WIX 295
WLB 180A
WLB180B
WLB1SOC
WLB 225
WU 65303
WU 65400
WU 100A
WU 100C
WUC 75A
WUC 75B
WUC 75D
WUC 100
WUC 115
WUC 160
WLM 157
WLM 551
WLR 65
WLR75
WLR 115
WMEC210A
WMEC 210B

ARMED
SERVICE
NAVY
NAVY
NAVY
NAVY
NAVY
NAVY
NAVY
NAVY
ARMY
ARMY
NAVY
NAVY
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
SHIP CLASSfflCATKXt-

CLASS
NAME
Austin
Austin
Austin
Iwo Jima
Anchorage
Whidbey Island
Harpers Ferry
Newport
Frank S Besson
100/130
Avenger
Osprey
Mackinaw
Polar
Hamilton/Hero Class
Eagle
Balsam
Balsam
Balsam
Juniper
Blackberry
Bayberry
Blue Bell
Blue Bell
Anvil/Clamp
Anvil/Clamp
Anvil/Clamp
Cosmos
7
Pamlico
Red
Keeper
Ouachita
F/Gasconade
Sumac
Reliance
Reliance
INFORMATION

SHIP TYPE
Amphibious Transport Dock
Amphibious Transport Dock
Amphibious Transport Dock
Amphibious Assault Helicopter
Carrier
Dock Landing Ship
Dock Landing Ship
Dock Landing Ship
Tank Landing Ship
Vehicle Landing Ship
Large Tug
Wine Countermeasure Vessel
Minehunters Coastal
Icebreaker
Icebreaker
High Endurance Cutter
Sail Training Cutter
Seagoing Tender
Seagoing Tender
Seagoing Tender
Seagoing Tender
Buoy Tender, Inland
Buoy Tender, Inland
Buoy Tender, Inland
Buoy Tender, Inland
Construction Tenders, Inland
Construction Tenders, Inland
Construction Tenders, Inland
Construction Tenders, Inland
Construction Tenders, Inland
Construction Tenders, Inland
Buoy Tender, Coastal
Buoy Tender, Coastal
Buoy Tender, River
Buoy Tender, River
Buoy Tender, River
Medium Endurance Class
Medium Endurance Class

NO-OP
SHIPS
3
3
2
2
5
8
3
3
6
25
14
12
1
2
12
1
8
2
13
2
2
2
1
1
2
3
2
3
1
4
9
2
6
13
1
5
11

PROPULSION
SYSTEM. „
Steam
Steam
Steam
Steam
Steam
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
: TRANSIT
INFORMATION
TRAN- DAYS JEN
SITS PORT
11 178
12 188
11 192
11 186
13 215
13 170
NA • NA
13 191
NA NA
NA NA
28 232
NA NA
NA NA
4 139
13 151
7 188
18 190
5 120
16 123
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
13 235
9 149
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
14
-------
r
Table 1. Vessels Equipped With Oil/Water Separator Systems (cont'd)
SHIP CLASSIFICATION INFORMATION -
ClASS v
-"BONO.
WMEC213
WMEC 230
WMEC 270A
WMEC 270B
WPB82C
WPB82D
WPB110A
WPB110B
WPB110C
WTGB 140
WYTL 65A
WYTL 65B
WYTL 65C
WYTL 65D
ARMED
SERVICE
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
USCG
CLASS
NAME
Diver
Storis
Bear
Bear
Point
Point
Island
Island
Island
Bay '
NA
NA
NA
NA
<*- X
> - " v- * \
, V SHIP TYPE
Medium Endurance Class
Medium Endurance Class
Medium Endurance Class
Medium Endurance Class
Patrol Craft
Patrol Craft
Patrol Craft
Patrol Craft
Patrol Craft
Icebreaking Tug
Harbor Tug
Harbor Tug
Harbor Tug
Harbor Tug
TOTAL:

Subtotals:
Navy
MSC
USCG
Army
,NO.OF
SHIPS
1
1
4
9
28
8
16
21
12
9
3
3
3
2
640

231
70
248
91
PROPULSION
.^SYSTEM
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
AVG:

TRANSIT
INFORMATION
TRAN- DAYS IN
SITS PORT
9 98
11 167
6 137
7 164
NA NA
NA NA
2 72
7 137
5 157
1 8
NA NA
NA NA
NA NA
NA NA
9 145

13 197
5 92
8 140
NA NA
Notes:
1. NA = Information not available
2. One transit = travel from one port to another, or from one port to sea and returning back to same port.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
15
-------
Table 2. In-Port Bilgewater Generation Rates1'23
Ship Class
DD963
DDG51
CVN68*
Gal/Day (Range)
1,000-3,000
N/A
5,000-25,000
Avg Gal/Day
2,000
335
3,000
* Values based on recording information over a 30 day period. All bilgewater was processed by
the OWS during six individual days, in volumes ranging from 5,000 to 25,000 gallons per
processing event The total volume processed over 30 days was 91,000 gallons, yielding an
average daily processing rate of 3,000 gallons per day.
, , ...,,.., ,
Table 3. In-Port Bilgewater/OWS Discharge Rates From U.S. Navy Ships
Ship Class
Aircraft Carriers
All Other Ships (Avg.)
Average Daily Flow
per Ship (gals/day)
3,000
2,000
Annual Flow per Ship
(gals/yr)
Days in
Port
147
178
Total
Flow
441,000
356,000
Total Ann
(million
No.of
Ships
11
220
Total:
ual Flow
eals/yr)
Total
Flow
4.9
84.9
89.8
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
16
-------
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-------
Table 6. Naval Station San Diego Bilgewater Characterization Data Summary
(Calendar Years 1993 through 1995)
, I

, Parameter
Oil & Grease
Phenols
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Nickel
Selenium
Silver
Thallium
Zinc
Benzene
Chloroform
Ethyl Benzene
Methylene Chloride
Tetrachloroethane
Toluene
Xylene
2,4-Dimethyl Phenol
Fluorene
Naphthalene

No. of,
Analyses "
45
83
(a)
(a)
84
85
85
85
85
1
84
(a)
82
82
81
81
68
82
80
17
82
83
79
Values Above MJ>L (units in |ig/L) '-
, No. Of x Mia.
Values . - '•>; '-"
45 5
12 15
(a) (a)
(a) (a)
33 10
31 20
84 10
52 39
83 20
0 NA
14 4
(a) (a)
80 100
29 0.5
1 47
38 6
18 5
7 7
52 5
12 28
14 30
41 5
37 11
..Max. : Median - Std.Dev.
%
12,900
901
80
1
610
2,320
80,400
3,360
10,300
NA
1,440
277
97,000
179
47
1,360
4,220
74
2,220
9,440
840
1,890
3,070
NOTES: (a) References contain summary tables and raw data laboratory logs that are
'
146
116
(a)
(a)
20
70
420
100
150
NA
23
(a)
688
30
47
50
16
18
77
16
89
42
85
incomplete.

2,234
0.309
(a)
(a)
118
492
9,250
509
1,590
NA
398
(a)
14,500
42
NA
221
1,000
24
383
2,600
23
411
613

Summary tables indicate single peak results for antimony, arsenic and thallium in 1993.
However, log sheets showing Ihe corresponding data are not included. The above statistical
analysis is based on log sheet data that was provided, except for the maximum values
for the three metals, which were obtained from the PWC summary table
(b) NA = Information not available.

for 1993.

shown

Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
19
-------
Table 7. Navy Destroyer (DDG 64) OWS Effluent Discharge Data Summary7
•»"•. May to September,

Parameter

Oil in Water (Navy)
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Iron
Manganese
Mercury
Nickel
Selenium
Silver
Zinc

No. of
Analyses
28
11
18
18
18
18
18
18
18
18
18
11
18
18
1996

values ADoveivijuj., (jig/ jb) .-•;.-..
No. Of Mfn.
Values
28
6
18
3
10
18
15
18
18
2
18
11
1
18

13
10
30
10
10
430
10
300
20
10
140
70
10
480
Max.

670
70
535
10
60
6,110
195
4,620
150
10
1,510
210
10
8,880
Median

151
20
118
10
20
1,.410
40
1,280
48
10
320
100
10
2,190
Std.I»ev.

205
23
124
NA
16
1,400
62
1,210
41
NA
317
40
NA
1,930
; :: ' " , :/. ,, ' ' , ' ' v: Juiy30,i99S(ng/L) : ,, , . . .....^ ,•.;,', . , -
|,«; ,,J.;i ;1:!y; Parameter i - .
OH and Grease (EPA 418.1)
Petroleum Hydrocarbons
MBAS
Benzene
Ethylbenzene
Metfaylene Chloride
Toluene
Xylene (total)
Diethyl Phthalate
2,4-Dimethylphenol
Dimethyl Phthalate
Fluorene
Naphthalene
Phenanthrene
Phenol
Sample A
NRL
—
79
71
<5
170
460
—
LLI
29
38
0.13
50
59
64
80
289
<10
110
11
12
63
16
46
SampleB
NRL
—
77
59
<5
170
450
—
LU
70
73
0.11
49
54
63
78
266
10
110
12
17
61
27
47
Sample C
•- NRL • '
E
70
64
<5
150
410
—
JULI
66
70
0.16
55
54
20
81
264
12
110
13
20
14
30
30
NOTES: (a) Volatile and semi-volatile analysis performed on random samples collected over two hour period.
Sample A during first hour. Samples B and C during second hour.
(b) LLI = Lancaster Labs Inc. NRL = Naval Research Laboratory.
(c) — = Samples were not analyzed by LLI for the parameters shown.
(d) NA = Information not available
(e) < = less than
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
20
-------
r
Table 8. Auxiliary Ship (AS 36) OWS Effluent Discharge Data Summary7
(May 2 through September 12,1996)
^Parameter*
!
Oil in Water
BOD
COD
TSS
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Iron
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Method
- Detection Level
NA
NA
NA
NA
600
10
5
10
20
NA
100
NA
0.2
NA
10/5
30
10
NA
- Ntf. of '
Analyses
44
8
14
10
14
14
14
14
14
14
14
11
14
14
14
14
14
14
Values Above MDL (ug/L)
No. of " Mi0. - Max. Median ,St&,
Values , " ' '1 ' _ Dev.
44 0.5 93 5.4 20.1
8 1 34 3.5 10.1
14 26 260 61 79.5
10 1 57 12.5 16
0 NA NA NA NA
0 NA NA NA NA
0 NA NA NA NA
0 NA ' NA NA NA
0 NA NA NA NA
14 44 661 257 166
0 NA NA NA NA
11 786 2,200 1,050 427
1 1.6 1.6 NA NA
14 75 471 117 103
0 NA NA NA NA
0 NA NA NA NA
14 NA NA NA NA
14 164 1,100 382 283
NOTE: NA = Information not available.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
21
-------
Table 9. Aircraft Carrier (CVN 74)
Oil/Water Separator Influent/Effluent Raw Data4

Parameter
COD
BOD
TOC
TSS
O&G
TKN
Ammonia
Nitrate + Nitrite (As N)
Total Phosphorous
TDS
Chloride
Sulfate
Sulfide
Total Alkalinity
Cyanide
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
rr
iron
Lead
Manganese
Nickel
Selenium
Silver
Thallium
Zinc
Bis(2-cthy!hexyl) phthalate
N,N-Dimethylformamide
Toluene
Xylene (o+p)

Units
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
UE/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L

Mg/L
M§/L
Mg/L
Mg/L
Mg/L
Mg/L
MS/L
Mg/L
Mg/L
M&/L
Hg/L
Mg/L
Mg/L
Mg/L
CVN 74-OWSI-01
Influent
132
31
28
38
50
1.6
0.14
054
3.2
7,360
4,126
498
5
36
<10
69{B)
<20
<10
49
1(B)
6
<10
581
455
<46
34
304
<20
5(B]

1,590
9S
14
24
Effluent
179
5
9
64
22
1.7
<0.10
0.20
1.2
16,620
9,742
1,290
2
64
<10
229
<2
33
32
<1
<5
<10
284
482
<46
29
98
<20
<5
<1C
519
33
<1C
<10
CVN 74-OWSI-02
Influent
258
17
24
38
269
2.0
0.19
0.44
3.7
5,570
3,616
411
10
40
<10
74(B)
<20
<1
50(B)
<1
5.7
<10
567
471
<46
34
318
<31.5
<5
<10
1,760
30
124
12
20
Effluent
258
11
21
46
17
1.7
0.17
0.30
2.7
9,720
7,359
643
8
46
<10
108(B)
2.6(B)
3(C)
43(B)
<1
<5
<10
426
442
<46
33
245
41(C)
5(B)
<10
1,330
88
<1C
13
CVN 74-GWSI-Q3
Influent
86
18
26
36
42
1.4
0.15
0.50
3.9
5,920
3,531
446
10
40
<10
83(B)
5.6(B)

55(B)
<1
5.1
<10
554
560
<46
37
321
<20
<5
<10
1,840
22
102
13
19
Effluent
148
18
20
48
36
1.6
0.17
0.40
2.2
10,260
8,125
780
8
48
<10
104(B)
<20
33(B)
40(B)
<1
5.6
<10
363
432
<46
30
208
<20
<5
<1C
1,110
65
<1C
<10
CVN 74-OWSI-04
Influent
195
22
19
70
122
1.2
<0.10
0.62
3.1
8,970
3,956
643
10
48
NA
143(B)
<20
<1
44(B)
<1
<5
<10
574
610
<46
35
277
26(C)
<5
<1C
1,350
38
85
12
19
Effluent
148
10
11
23
27
1.0
<0.10
0.0
2.0
13,320
8,040
958
5
58
<10
220
<1C
<1
34(B)
<1
<5
<1C
316
531
<46
31
162
<20
<5
<1(
786
51
<1(
12
Note: (a) < = less than
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
22
-------
Table 10. Summary of Detected Analytes: Oil/Water Separator Effluent Data
Constituent *
/ —
- '
Oil Water Separator Effluent
Classicals (mg/L)
ALKALINITY
AMMONIA AS NITROGEN
BIOCHEMICAL OXYGEN
DEMAND
CHEMICAL OXYGEN
DEMAND (COD)
CHLORIDE
HEXANE EXTRACTABLE
MATERIAL
NITRATE/NITRITE
SGT-HEM
SULFATE
TOTAL DISSOLVED SOLIDS
TOTAL KJELDAHL NITROGEN
TOTAL ORGANIC CARBON
(TOC)
TOTAL PHOSPHOROUS
TOTAL RECOVERABLE OIL
AND GREASE
TOTAL SULFIDE
(IODOMETRIC)
TOTAL SUSPENDED SOLIDS
VOLATILE RESIDUE
Hydrazine (mg/L)
HYDRAZINE
Mercury (ngflL)
MERCURY
Me^l£(Mg/L) /
ALUMINUM
Total
ANTIMONY
Total
ARSENIC
Total
BARIUM
Dissolved
Total
BORON
Dissolved
Total
Log Normal
Mean "•
-
N
v
53.51
0.09
8.78
178.34
8273.63
23.54
0.27
9.64
887.29
13238.57
1.5
14.53
1.81
39.96
5.03
42.46
13285.59
s
0.15
^ •"•
51.8

154.49

6.15

6.09

34.98
36.58

1562.43
1505.6
Frequency of
Detection
y

j»
4 of 4
2 of 4
3 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4

4 of 4
"* <
4 of 4
-

4 of 4

Iof4

2 of 4

4 of 4
4 of 4

4 of 4
4 of 4
- Minimum i
Concentration

%
^
46
BDL
BDL
148
7360
17.5
0.2
6
643
9720
1.1
9.3
1.2
15.05
2
23
9770
',-• ;
0.095
-
32,05
,'

104

BDL

27.8
30.65

1280
1240
Maximum
Concentration
"
/ ~"

64
0.17
18
258
9740
27
0.4
16
1290
21600
1.7
21
2.7
173
8
64
21600

0.2

79.8
t

230.5

2.6

41.8
42.9

2030
1945
Mass
Loading
Obs/yr)

40,013
67
6,565
133,356
6,186,728
17,602
202
7,208
663,484
9,899,334
1,122
10,865
1,353
29,881
3,761
31,750
9,934,494

112

0.04

116

26
27

1,168
1,126
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
23
-------
CADMIUM
Total
CALCIUM
Dissolved
Total
COPPER
Dissolved
Total
IRON
Total
MAGNESIUM
Dissolved
Total
MANGANESE
Dissolved
Total
MOLYBDENUM
Dissolved
Total
NICKEL
Dissolved
Total
SODIUM
Dissolved
Total
TIN
Total
TITANIUM
Total
ZINC
Dissolved
Total
Organics (ug/L)
N.N-DIMETHYLFORMAMIDE
O+PXYLENE
Pesticides (ug/L)
2,4-DB
DICAMBA
MCPA
MCPP
PYRETHRINI

3.06

135123.39
129848.08

162.56
341.25

472.36

392878.32
423465.92

26.21
30.35

21.29
9.29

176.4
168.54

3606853.89
3585080.31

16.59

4.5

855.7
878.8

57.3
7.9

1.66
0.29
28.45
113.25
183

Iof4

4 of 4
4 of 4

4 of 4

4 of 4
4 of 4

4 of 4
2 of 4

4 of 4
4 of 4

Iof4

2 of 4

4 of 4
4 of 4

4 of 4
2 of 4

2 of 4
3 of 4
Iof4
4 of 4
lofl

BDL

105000
104000

116
277.5

432

262000
333000

22.2
28.25

18.6
BDL

109
97.75

2680000
2770000

BDL

511
514

32.5
BDL

BDL
BDL
BDL
41.3
183

5.6

184000
172500

201
426

531

486000
593500

31.1
32.5

24.3
28.1

247
245

5200000
5000000

41.2

9.2

1260
1330

88
13

2.88
0.48
58.9
167
183

101,040
97,096

122
255

353

293,780
316,653

20
23

16
7

132
126

2,697,078
2,680,796

640
657

43
6

1
0.2
21
85
137
Log normal means were calculated using measured analyte concentrations. When a sample set contained one or
more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations
equivalent to one-half of the detection levels were used to calculate the mean. For example, if a "non-detect" sample
•vyas analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used in the log normal mean
calculation.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
J 24
-------
Table 10 a. Estimated Annual Mass Loadings of Constituents
;* > Constituent;" .
Classicals (mgflL)
AMMONIA AS NITROGEN
NITRATE/NIRITE
TOTAL KJELDAHL
NITROGEN
TOTAL NITROGENA
TOTAL PHOSPHOROUS
SGT-HEM
Mercury , (ng/L) ~
MERCURY
Metals (fig/L) , ~,
COPPER
Dissolved
Total
IRON
Total
NICKEL
Dissolved
Total
ZINC
Dissolved
Total
Log Normal
Mean

0.09
0.27
1.5
1.77
1.81
9.64

51.8

162.56
341.25

472.36

176.4
168.54

855.7
878.8
"Frequency of
Detection.'
~ „
2 of 4
4 of 4
4 of 4

4 of 4
4 of 4
j "*
4 of 4
* v ^

4 of 4
4 of 4

4 of 4

4 of 4
4 of 4

4 of 4
4 of 4
>% Minimum
Concentration

BDL
0.2
1.1

1.2
6
s "
32,05
„ „ ,

116
277.5

432

109
97.75

511
514
~~ Maximum
Concentration
^ ^ M* •
0.04

122
255

353

132
126

640
657
Notes:
A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
25
-------
Table 11. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituent
Classicals (mg/L)
AMMONIA. AS
NITROGEN
NTTRATE/NrTRITE
TOTAL KJELDAHL
NITROGEN
TOTAL
NITROGEN8
TOTAL
PHOSPHOROUS
TPH(SGT-HEM)
Mercury (ng/L)
MERCURY*
Metals (ug/L)
COPPER
Dissolved
Total
IRON
Total
NICKEL
Dissolved
Total
ZINC
Dissolved
Total
Log
Normal
Mean

0.09
0.27
1.5
1. .77
1.81
9,64

51.8

162.56
341.25

472.36

176.4
168.54

855.7
878.8
Minimum
Concentration

BDL
0.2
1.1
1.2
6

32.05

116
277.5

432

109
97.75

511
514
Maximum
Concentration

0.17
0.4
1.7
2.7
16

79.8

201
426

531

247
245

1260
1330
Federal Acute Water Qjiality
Criteria

None
None
None
None
None
visible sheen" / 15b

1800

2.4
2.9

None

74
74.6

90
95.1
Most Stringent State
Acute Water Quality
Criteria

0.006 (HI)A
0.008 (HI)A
0.2 (HI)A
0.025 (HI)A
5(FL)

25 (FL, GA)

2.4 (CT, MS)
2.5 (WA)

300 (FL)

74 (CA, CT)
8.3 (FL, GA)

90 (CA, CT, MS)
84.6 (WA)
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 13 1.36 (57 FR 60848; Dec. 22,
f 992 W 60 FR 22230: Mav 4. 19951
4JT7.6 anu ou rts. AAAJV; iviay t, lyyjj
A - Nutrient criteria are not specified as acute or chronic values.
§ - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
* - Mercury was not found in excess of WQC; concentration is shown only because it is a bioaccumulator.

CA™ California
CT - Connecticut
FL = Florida
GA "= Georgia
fOC-Hawaii ' '„ \
MS m Mississippi
WA ** Washington

* Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen
on receiving waters.
b International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as
implemented by the Act to Prevent Pollution from Ships (APPS)
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
:,1 ' , 26
-------
Table 12. Data Sources
tu *
NOD Section
2.1 Equipment Description and " " ^ ,
Operation ' „-* "* *,
2.2 Releases to the Environment
23 Vessels Producing the Discharge
3,1 Locality ,
3.2 Rate - ,
3.3 Constituents s; <
'3.4 Concentrations
4.1 Mass Loading
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species"
Data Source" -, ;>
Reported
Equipment
Literature
OPNAVINST
5090. IB
UNDS Database

X
X
X
X
X

Sampling

X
X

Estimated -

X
X

Equipment Expert
X
X
X
X
X
X

X
Surface Vessel Bilgewater/Oil Water Separator (OWS) Discharge
27
-------
";iiIIUL1!1!!!,!,,:.i,,!«;," liliL'il l
, ft IB', ' •,. I*' Illi'1, '
-------
NATURE OF DISCHARGE REPORT
A > UntterwaterSMpHusbandry
1.0 INTRODUCTION

This section describes the underwater ship husbandry discharge and includes information
on: the equipment that is used and its operation (Section 2.1), the general description of the
constituents of the discharge (Section 2.2), and the vessels that produce this discharge (Section
2,3).

2.1 Equipment Description and Operation
» ,,: • ' 'II
For the purpose of this evaluation, underwater ship husbandry is defined as the
inspection, grooming, maintenance, and repair of hulls and hull appendages performed while a
vessel is waterbpme. In the case of repairs, they may be classified as permanent (equivalent to
dry-dock repair); temporary (to be reworked at the next scheduled dry-docking); and emergency
(allowing the ship to transit to a facility for further repair). Underwater ship husbandry includes
the following operations:112
; F ii • . . ' j , '
• hull cleaning,
• fiberglass repair,
• welding,
• sonar dome repair,
* non-destructive test/inspection,
• masker belt repairs, and
• paint operations, and
• SEAWOLF propulsor layup.
j,
All of these activities are typically conducted while ships are pierside. Cleaning of
Underwater hulls is the major activity within this category, and is performed on a routine basis.1
Layup of SEAWOLF propulsors occurs approximately 6 times per year.3 The remaining
operations are unplanned repair activities incidental to normal vessel operation.
I , 'I, v I1! . , ' , ' , il f ' . '
2.1.1 Underwater Hull Cleaning

Underwater hull cleaning is performed to remove fouling organisms which have adhered
to a vessel and its appendages.4 Biological growth is undesirable since it increases ship drag,
thereby increasing fuel consumption and decreasing speed. Hull cleanings can be either full
cleanings or interim cleanings. Full cleanings are those which include the entire painted
Underwater Ijull surface, propellers, and propeller shafts. Interim cleanings include the cleaning
of propellers and shafts only.

Hull Boating Systems. Ablative hull coating systems are typically comprised of two
coats (layers) of epoxy anticorrosion (AC) paint applied to the bare hull and two coats of copper
antifouling (AF) paint applied over the AC coating. The function of the AC coat, in conjunction
with cathodic protection, is to prevent hull corrosion. The AC coat also provides bonding
between the Hull and the AF topcoats] AF topcoats control biological growth by ablating and/or
leaching antifouling agents into the surrounding water (as described in the Hull Coating Leachate
,, , j, , .
Underwater Ship Husbandry
: '• • 2
-------
NOD report). The total design thickness of this system is 20 mils (1 mil = 0.001 inches), of
which 10 mils are the AF coating, although the actual application maybe thicker.5

Most ships of the Navy, Military Sealift Command (MSC), and U.S. Coast Guard
(USCG) use AF paint qualified to MIL-PRF-24647 "Paint System, Anticorrosive and
Antifouling, Ship Hull."6'7 While several types of AF topcoats conform to this specification, the
most common types are ablative, copper-based coatings.8 An ablative coating thins as it erodes
or dissolves. Through this action, a fresh layer of antifouling agent (e.g. copper) is exposed,
mauitaining the paint's antifouling properties. Self-polishing AF paints are a type of ablative
coating which undergoes chemical hydrolysis when it comes into contact with the slightly
alkaline seawater. Any toxic agents which are chemically bound to the paint matrix will be
released at a rate dependent upon the rate of hydrolysis.

Other vessels of the Armed Forces use non-ablative paint systems which do not
appreciably diminish in thickness during service.7 Non-ablative paints containing tributyltin
(TBT) are still found on some aluminum-hulled small craft because some copper-based paints are
incompatible with aluminum hulls.8 However, TBT paints are no longer approved for any Navy
vessel, including aluminum-hulled craft, effective as of fiscal year (FY) 1998.5'9

Coating Service Life. Ablative copper AF coatings for naval vessels are designed to
meet five-, seven-, or ten-year dry-docking periods.9 Typically, ablative copper AF coatings
remain free of fouling for about three years after application before they require in-water hull
cleaning. After the first cleaning, they typically require an annual hull cleaning, which is
usually performed just prior to deployments, to optimize fuel consumption underway. This is
only a guideline, since the frequency of cleaning is also influenced by the ship's schedule and
location.4

Inspection and Evaluation. Navy vessels are inspected quarterly and before
deployments, and are assigned a Fouling Rating (FR) on a scale of 0 to 100.1'4 This rating is
established by comparing photographs of the fouled hull with photographic standards
representing values on the FR scale. The criteria for performing hull cleaning is FR 40 or higher
(for ablative and self-polishing paint systems) over 20% of the ship's hull; or the presence of FR
50 or higher (for non-ablative paint systems) over 10% of the ship's hull.4

Underwater Hull Cleaning Process. Underwater hull cleaning can be accomplished
with hand-held rotary brush units, self-propelled multi-brush cleaning vehicles, water jets, and
hand-held scrapers.4 Most often, it is conducted by divers using the Submerged Cleaning and
Maintenance Platform (SCAMP) or the similar SeaKlean multi-brush systems.1 These
mechanical devices are held next to the hull from the thrust and suction generated by a large
impeller, which pumps seawater at approximately 13,500 gallons per minute (gpm). While the
brushes rotate and sweep biofouling off of the hull, the system moves forward at a maximum rate
of 1 foot per second (ft/sec), but typically at 0.75 ft/sec. A small percentage of the hull, gratings,
and struts; which are inaccessible to these multi-brush machines, must be cleaned using hand-
held single-brush cleaning units.10
Underwater Ship Husbandry
3
-------
I::;;
2.1.2
Other Underwater Repair, Maintenance, And Inspection Processes
Fiberglass Repair. Two activities comprise this class of ship husbandry: fiberglass hull
repairs an
-------
that the hull shape remains "fair," or smoothly curved, so the masker belt does not protrude and
increase drag. Waterborne repairs by divers consist of cutting away damaged belt sections and
installing replacement sections. An insert is used to join the replacement with existing sections.
Finally, an epoxy sealer is applied to ensure a positive air seal.11

Paint Operations. Underwater touchup painting is required after welding, shaft
lamination repairs, and masker belt repairs. Touchup painting is also performed to repair paint
damage or deterioration on surfaces such as rudders, dielectric shielding for the cathodic
protection system, struts, and stem tubes. Epoxy paint is mixed on the surface (above water),
supplied to the diver, and applied to the affected area with a brush or roller.11

SEAWOLF Propulsor Layup. The newly commissioned SEAWOLF attack submarine
utilizes vinyl covers to prevent fouling of the propeller (also called propulsor) when it is in port
for extended periods. The covers, referred to as the Propulsor Protective Covering System
(PPCS), restrict sunlight and the supply of fresh nutrient-rich water into the propulsor. Reducing
the amount of fouling that occurs on the propulsor in port reduces the need for underwater
cleaning of the propulsor.2

2.2 Releases to the Environment

2.2.1 Underwater Hull Cleaning

Underwater hull cleaning is accomplished by divers operating hand-held rotary brush
units, self-propelled multi-brush cleaning vehicles, water jets, and hand-held scrapers.4 These
tools sweep or dislodge biofouling from the wetted surface of the hull and appendages.1 The
discharge from the cleaning process consists of seawater (from the impeller of the cleaning
vehicle), living and dead marine organisms, and antifouling paint.10 Variables affecting the
amount of this discharge include hull surface area, condition of the paint system, degree of
fouling, brush selection, conditions in the water, and the skill of the operators.

2.2.2 Other Underwater Repair, Maintenance, And Inspection Processes

Fiberglass Repair. A two component system consisting of an epoxy resin and a
hardener is mixed topside and transferred to the underwater habitat to accomplish the fiberglass
repairs.15 Due to the rapid curing time of the resin system, it is applied to the surface to be
repaired soon after mixing, and then covered with glass tape. Releases of fiberglass and resin can
occur when materials fall through the open bottom of the enclosure.11 Since the resin being
applied quickly solidifies, any releases from the enclosure will fall to the bottom of the harbor.
Welding. Small amounts of welding consumables can enter the marine environment
upon entry into or exit from the dry welding habitat, or by passing directly into the water during
wet welding.11 Slag, which is molten refuse material from the welding process, may fall from the
welding area into the water column. Some spent welding rods and welding gases may also be
released.
Underwater Ship Husbandry
5
-------
Sonar Dome Repair. When the diver removes the loose rubber from the sonar dome
and affixes a rubber patch with adhesive, a discharge of solid rubber waste and/or adhesive may
result
il
Non-Destructive Test/Inspection. The slurry of iron flakes applied to the weld is
discharged directly into the water column.11

Masker Belt Repairs. Waterbome repairs consist of cutting away damaged belt sections
aild installing replacement sections as described in Section 2.1.11 Portions of the damaged belt or
some of the epoxy sealer can be released during this operation.

Paint Operations. While a diver is performing underwater touchup painting with epoxy
coatings, some paint can be incidentally released into the water in the vicinity of the painting
operation.11 Neither the epoxy resin nor the amine compound of the primary products in use are
16
water-soluble.

SE AWOLF Propulsor Layup. Use of the PPCS creates a relatively isolated volume of
water of approximately 21,000 gallons inside the propulsor. The chemistry of this volume of
\fater can change over time, primarily due to the generation of small amounts of chlorine from
titie installed Impressed Current Cathodic Protection (ICCP) system and the decay of trapped
organic matter. (Descriptions of the purpose and function of ICCP systems can be found in the
Cathodic Protection NOD report). Releases to the environment resulting from the layup of the
propulsor include decaying organic matter, chlorine, and Chlorine Produced Oxidants (CPO).
CPO is used to describe the combination of oxidant species that may, hi this case, be formed by
the ICCP system in both primary and secondary reactions, and includes various chlorinated and
brominated species.17

2.3 Vessels Producing the Discharge
:", l\. '•••! . ' ' • '' ' • •, :' ';".' ' , 'in1 :•'•',' •• ti' . '.. '' 1
All Navy surface ships and submarines undergo periodic underwater ship husbandry.
However, the predominant discharge is from underwater hull cleanings. Underwater cleanings
aje performed on larger vessels between dry-docking periods. The Navy, with the greatest
Climber of large vessels, produces this discharge more frequently than the other Armed Forces.
The U.S. Coast Guard (USCG), Military Sealift Command (MSC), Army, and Air Force dry-
dock then- vessels more frequently, at which time hull cleaning is performed.18'I9> 20 Small boats
and craft are typically removed from the water for maintenance and repairs.1 Layup of
SEAWOLF Propulsors is currently limited to the SEAWOLF Class of attack submarines. The
first of this class, SSN 21, was commissioned in the fall of 1997, with a total of 3 submarines
planned. The next attack submarine class, commonly referred to as the "New Attack
Submarine," is also expected to use a PPCS type system.
3.0 DISCHARGE CHARACTERISTICS

This section contains qualitative and quantitative information that characterizes the

Underwater Ship Husbandry
6
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discharge. Section 3.1 describes where the discharge occurs with respect to harbors and near-
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

3.1 Locality

Underwater ship husbandry is conducted pierside.1

3.2 Rate

Because of the variability in vessel surface area and in the volume of these releases for
underwater ship husbandry, rates are discussed in terms of frequency of the event.

3.2.1 Underwater Hull Cleaning

On average, each Navy surface ship will receive five underwater hull cleanings every six
years.1 These statistics vary regionally depending on fouling rates, water temperatures, and the
coating service life. Vessels in Pearl Harbor, HI, for example, would have higher fouling rates,
and, therefore, a higher cleaning frequency than those in Norfolk, VA. An average of 136 full
cleanings (including the hull surface, propeller, and shaft) are performed annually fleetwide,
based on the following four years of data:21
1993:
1994:
1995:
1996:
131 vessels
131 vessels
135 vessels
148 vessels
An additional 170 interim cleanings (i.e., the cleaning of propellers and shafts only) are
estimated to occur each year.1

Although flow rates from the SCAMP have not been measured, based on impeller
characteristics, motor speed, and expected efficiency, the flow rate has been estimated to be
13,500 gallons per minute (gpm), or 51,100 liters per minute (L/min).10

3.2.2 Other Underwater Repair, Maintenance, and Inspection Processes

Table 1 lists the estimated releases from Navy underwater ship husbandry activities other
than hull cleaning.22 Coating shafts with fiberglass is performed on an infrequent basis. Sonar
dome repairs are necessary only on submarines and surface combatants equipped with sonar
equipment. The other listed activities apply to all vessels. Since the other services have fewer
large ships than the Navy, these activities are expected to be less frequent among vessels of the
other Armed Forces. For example, there have been three documented instances of underwater
weld repairs conducted on MSC vessels in the past five years, and no rubber dome or fiberglass
repairs.23
Underwater Ship Husbandry
7
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Fiberglass Repair. On Navy vessels, fiberglass shaft coatings are estimated to be
applied 12 times per year. Based on operational experience, it is estimated that approximately
oiie quatt of resin could possibly be released per fiberglass wrapping event. Given this amount, it
is* estimated that'll quarts (11.4 liters) of the resin system (i.e., resin mixed with hardener) could
possibly be released per year.22
" '!, ; Mfl1! ' ' II • ' ' • "i
>Velding. Small amounts of welding consumables can enter the marine environment
through the dry habitat or directly when wet welding is performed.11 Slag and spent welding rods
may also be released. From operational experience, it is estimated that approximately five
pounds of slag or spent welding rod are discharged during each underwater welding operation,
apd approximately 12 of these operations are performed fleet-wide each year on Navy ships.22
Metals from the welding operation will not be readily dissolved in the surrounding waters and
will fall to the harbor floor.

Sonar Dome Repair. A discharge of solid rubber waste and/or adhesive can result from
this operation. This is a site-specific operation, and this discharge is dependent on the size of the
patch being repaired. It is estimated that 19 Navy surface ships and submarines undergo sonar
dome repairs yearly.22 Rubber pieces from the sonar dome repair operations will not be
dissolved in the surrounding water and will settle on the harbor floor.

Non-Destructive Test/Inspection. During magnetic particle inspection, a slurry of iron
flakes is discharged directly through the water column. It is estimated that 20 Navy vessels
undergo magnetic particle inspections yearly.
22
Masker Belt Repairs. Waterbome repairs consist of cutting away damaged belt sections
and installing replacement sections. Based on operational experience, it is estimated that six
Navy vessels undergo masker belt repairs yearly.22 Releases can occur from the removal of the
damaged belt and the application of the epoxy sealer.11 Similar to the epoxy resin used in
propeller shaft repair, the epoxy sealant will quickly solidify into a hard, insoluble material.

Paint Operations. While a diver is performing in-water touchup painting with epoxy
coatings, some paint can be incidentally released into the water in the vicinity of the painting
operation. It is estimated that roughly 60 operations of this type are performed on Navy vessels
annually.24 The surface area involved may be as small as two square feet for a weld touchup, or
as large as 1,500 square feet when several areas of the ship require touchup painting. The
amount of paint released will vary with the size of the area painted and the skill of the operator.1
"fhe release of material during these operations is accidental and highly variable.
f:'. ''.;!.' 1 ;;:| :M:: ,:: '•><•••>•'>[ .\; ''••' fr ' •••f • • • s '••'•
SEAWOLF Propulsor Layup. Current operational procedures require the PPCS to be
installed with 12 hours after entering port when the in port time is expected to be greater than 72
hours.2 Exceptions to this requirement exist for maintenance and engine testing, during which
the PPCS will be removed, or perhaps not installed at all. This is similar to the requirement for
putting the main condensers of earlier submarine classes on a fresh water layup for which an
estimate of 6 times per year was developed.3
Underwater Ship Husbandry
8
• I! Li,, I'.J .1 Bin..:...!...!!;!!!Jllllli! ,» o^-iJUJ ifliLiii,:; iili
i iiiiiiiiiiiiiii:.,:,.!!!!,..!,.. ,i i a;1 ,
mi. •: a,; iiiiii jinn,' a,.,. :.,„.. •
-------
3.3 Constituents

Materials associated with underwater ship husbandry activities and which maybe
constituents of the various discharges are discussed in this section.

3.3.1 Underwater Hull Cleaning

The primary constituents found in the hull cleaning discharge are copper and zinc from
the antifouling paint. These constituents are priority pollutants; neither are bioaccumulators.
TBT is not a constituent of concern since small craft with aluminum hulls are not typically
cleaned waterborne.1

3.3.2 Other Underwater Repair, Maintenance, And Inspection Processes

The primary constituents which may be found in the discharge from underwater repair,
maintenance, and inspection processes other than hull cleaning are listed in the following
paragraphs. Constituents which are classified as bioaccumulators or priority pollutants are
identified.

Fiberglass Repair. The primary constituents found in the discharge from fiberglass
repair activities are proprietary resins and fiberglass. The resin material is fluid for only a short
period of time; will not be dissolved in the surrounding water; and will fall to the harbor floor,
where it will complete its curing. The hardener can contain triethylenetetramine;
tetraethylenepentamine; 2,4,6-tris(dimethylanunomethyl)phenol; and amidoamine.25

Welding. The primary constituents found in the discharge from underwater welding are
metals in the slag associated with welding rods. These may contain chromium, iron, nickel,
beryllium, manganese, and trace quantities of other metals.11 Chromium, nickel, and beryllium
are priority pollutants.

Sonar Dome Repair. The primary constituents found in the sonar dome repair discharge
are rubber from the patches and the sealant. The sealant adhesive contains epoxy resin, amine
polymer, iron oxide, and silica.11

Non-Destructive Test/Inspection. The primary constituents found in the discharge from
crack or weld inspection are fluorescent iron powder or flakes, water conditioner, and a
surfactant mixture suspended in water.26 The particles used are required by specification to be
non-toxic, finely divided ferromagnetic material free from rust, grease, oil, paint, or other
materials which can interfere with their proper functioning.14

Masker Belt Repairs. The primary constituents found in the discharge from masker belt
repairs are portions of the damaged belt and adhesive. Sealant adhesive contains amine polymer,
iron oxide, and silica.11

Paint Operations. The primary constituents found in the discharge from touchup paint

Underwater Ship Husbandry
9
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Operations are epoxy paint which contains 4,4'-methylene dianiline, benzyl alcohol, and traces of
epichlorohydrin.11

SEAWOLF Propulsor Layup. Constituents from the layup of the SEAWOLF propulsor
\Vill include decaying organic matter, and CPO that may build-up in the enclosed volume of the
propulsor. CPO is the primary constituent.

3.4 Concentrations

3.4.1 Underwater Hull Cleaning

The Navy studied the environmental effects of m-water hull cleaning on six ships during
the period from 1991-1993. Measurements of total copper were taken directly within the
SCAMP discharge plume for three of these ships.10 This data serves as the basis for the analysis
of copper concentrations in and loading from the SCAMP effluent.
Table 2 summarizes both dissolved (0.45 micron filtered) and total (unfiltered) copper
concentrations from the effluent of the SCAMP for the three ships.10 Samples were collected in
the plume created by the cleaning operation near the point of discharge, and thus are
representative of the highest anticipated levels in the marine environment attributable to
linderwater hull cleaning. The mean for total copper in the samples ranged from 1,565
rijicrograms per liter (j*g/L) to 2,619 pg/L. The dissolved fraction was 4 to 9 percent of the total
copper (66 jig/L to 146 pg/L). Zinc levels were not measured in this study, but can be roughly
estimated from the original ratio of constituents in the paint. Assuming a ratio of 2.5 parts
copper to 1 part zinc, it can be estimated that the total zinc concentration is 626 to 1,048 fxg/L.27
'•','. • •"!' ':'• i : " ' " •';; ' !•• ' '' • ••;
3.4.2 SEAWOLF Propulsor Layup

The concentration of organic matter in the released volume of water will be related to the
amount of biological matter in the harbor water when the PPCS is Installed. The concentration
Of CPO will be proportional to the current output of the ICCP system and the length of time the
PPCS is installed, and inversely proportional to the oxidizable component of the harbor water at
the time of ppCS installation.
'''•: ' • '' :'!:!: ' '' ' • ' <.''• '•'•'['•'•' ' ' '
Typical in port ICCP system output for the SEAWOLF Propulsor is less than 1 ampere.
An equation based on Faraday's Law is used to determine the maximum CPO generation rate of
1.3gCl/hr.
Generation Rate of Chlorine Produced Oxidants (CPO)

'• (1 amp) (1 coulomb/amp-sec) (3,600 sec/hr) (35.45 g chlorine/mole) (mole/96,484 coulomb)
= 1.323gchlorme/hrwl.3g/hr ;
Underwater Ship Husbandry
10
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Since ICCP systems (i.e., anode materials and system operating voltage) are designed to
maximize cathodic protection provided to the hull, and generation of chlorine or CPO is a
secondary reaction, actual CPO generation rates are expected to be significantly lower.

This generation rate of CPO will be further offset by the consumption of CPO in the
harbor water. In the first stage of CPO decay, a portion of the CPO disappears within one
minute, consumed by the instantaneous oxidant demand. This first decay is assumed to be a 25%
reduction, based upon a range of values reported for studies performed in waters between 0°C
and 33°C.28'29 Following this, decay is assumed to occur at a rate of 50% concentration
reduction per hour. While actual decay rates for CPO will vary significantly due to temperature,
flow, and amount of biological matter, these average decay rates can be used to determine an
estimate of the resultant CPO concentration and mass loading as shown in Calculation Sheet I.30
The resultant concentration and mass loading converge to steady-state values of 18 ng/L CPO
and 1.4 g CPO per event, respectively, in the enclosed volume of water after ten hours of system
operation.

One set of field was data obtained for this application, and in this, a CPO concentration of
less than 40 ug/L was measured hi the enclosed water of the propulsor over a 52 day period.31'32
This testing was accomplished in the context of local environmental limits for CPO of 0.2 ppm
(200 |xg/L), and test results only confirmed CPO concentrations within the lowest range of the
test apparatus (0.0 ppm to 0.04 ppm) rather than precise values.32 This is hi agreement with the
18 ug/L estimated from the previous CPO decay calculation. The larger of the two estimates (40
ug/L) will be assumed for subsequent calculations.

3.4.3 Other Underwater Repair, Maintenance, and Inspection Processes

lii accordance with the specifications, the concentration of magnetic particles in the slurry
used for underwater weld inspection is between 0.1% and 0.7% by volume.14 The remainder of
the suspension is water. The estimated release amounts from other underwater ship husbandry
activities are infrequent and in small quantities. In addition, these discharges are mostly
insoluble and are unlikely to remain suspended in the water column or be dissolved. Pollutant
concentrations resulting from fiberglass repair, welding, sonar dome repair, masker belt repair,
and painting were not estimated.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. hi Section 4.2, the concentrations of discharge constituents
are compared with water quality criteria, hi Section 4.3, the potential for the transfer of non-
indigenous species is discussed.

4.1 Mass Loadings
Underwater Ship Husbandry
11
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4.1.1 Underwater Hull Cleaning
Differences in ship assignments and deployments create different rates of hull fouling on
individual vessels. However, the decision to initiate hull cleaning operations is based on visual
inspection and by ship performance indicators as outlined in NSTM, Chapter 081. Based upon
this standard approach to assessing the need for cleaning, it is reasonable to assume that cleaning
operations are initiated under similar fouling conditions. Therefore, the SCAMP discharges
sampled are assumed to provide a reasonable basis for the approximation of SCAMP discharges
fleet-wide. The total volume of a release from an underwater hull cleaning operation is
proportional to the area of the hull cleaned. Therefore, the total volume of the discharge is
related to the class of ship, with larger releases generated from the cleaning of larger hull areas.
•.I . • " , • , , ,-',,] ,
For the purposes of calculating mass loading from ships and the fleet, the mean
concentration of the copper in the SCAMP discharge from the three vessels studied was used.
The total copper was measured to be 1,950 fj.g/L and the dissolved copper fraction averaged
approximately 107 jag/L, or approximately 5.5%.
, •: ' J .,,:i' . ' ; , •. . "' |l >' '
In order to calculate the mass loading, data are needed on the flow rate (F) from the
SCAMP impellers, and the rate (R), or area cleaned per unit time. The mass of copper released
(Cu) per unit area cleaned (A) can be calculated by the following formula:10
i,,,, ,Cu/4^^
where Cu is in grams (g)
A is in square meters (m2)
Cu concentration is in grams per liter (g/L)
F is in liters per xninute ^niin)
R is in square meters per minute (m2/min)
Using the^following assumptions, a sample calculation of the mass of copper releasedper
unit area cleaned is provided below:
SCAMP flow rate is 51,100 L/min (equivalent to 13,500 gpm), (Section 3.2)
Cu concentration = 0.00195 g/L (mean concentration)
Flowrate(F) = 51,100 Unrin
''Cleaning;rate (R) '"""" = 20.8 m2/nun(225fr2/min)
(based on 45 ft/mm travel speed, and a 5 ft wide cleaned path)
Cu/Area = (0.()0195g^)(5UOOUmin)/(20.8m2/mitt)
Copper release= 4.8 g Cu per m2 of surface cleaned
Assuming the entire hull area exposed to the water is cleaned, the wetted surface area of
{he ships can be used for the area cleaned. The wetted surface area of the ships was taken
Underwater Ship Husbandry
12
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directly from tables in NSTM Chapter 633, "Cathodic Protection," or estimated by the following
formula presented in the same source:33
' " _ - o* '
where: S=wetted surface area (fr) „ - ~*_ ±r/V
L= length between perpendiculars (ft) „
~ d=molded mean draft atfull displacement (ft) ,
V = molded volume of displacement ft3
(for seawater, 35 $ of water per ton displacement)
As an example for an individual ship, from the NSTM the Spruance Class destroyer has a
wetted hull area of 35,745 ft2 (3,321 m2).33 Therefore, the mass loading is estimated to be 15.9
kilograms (kg), or 35 pounds (Ibs) total copper released during a full hull cleaning.

Fleetwide Hull Cleanings. A list of Navy vessels which received full hull cleanings
during the period from 1993-1996 was used to determine a weighted average mean hull surface
area cleaned annually.21 This weighted average was estimated to be 2,973 m2. The estimated
copper release rate and the mean hull wetted surface area can be applied to all Navy ships to
derive a total mass release fleet-wide. Dissolved copper releases are based on the average ratio
(5.5%) of dissolved to total copper measured.10
Mean wetted hull area (aE vessels),- 2,973'm*l . "; '-/ " '.
Approximate number of NaVy.vessels cleaned annually = 136
Total area cleaned annually=404,328 m2" (assuming full hull cleanings)
Total copper release - (4.8 g/m2) (404,328ra!) = 1,941 kg/yr; or,4,£79/lbs/yr
Dissolved copper release = (1,941 kg/yr) (5.5%) = 108 kg/yr; or 238 Ibs/yr
Since zinc was not measured in the Navy studies, it was assumed that releases from hull
cleaning contain the same copper to zinc ratio (2.5:1) as is found in AF paint prior to its
application. The annual mass loading for zinc was estimated.
Total zinc release « (1,941 kg Cu/yr) / (2.5 (Cu/Zn ratio)),» 776 kg/yr; or 1,712 Ibs/yr
4.1.2 SEAWOLFPropuIsorLayup

Based on information previously provided, the annual mass loading of CPO due to the
layup of the SEAWOLF propulsor is estimated to be a maximum of 19 g of chlorine.
Underwater Ship Husbandry
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Annual mass loading=(concenfration)(volume per discharge)(number of discharges)

Maximum concentration = 40 p.g/L (see Section 3 A2)
^^^^•^^ I
•Number of discharges per year = 6

Mass loading per event = 3.2 gCPO -
Maximum annual massioading=1.9x I07{xg,or 19gCPO
4.1.3 Other Underwater Repair, Maintenance, And Inspection Processes

Based on the information presented in Section 3.2 and Table 1, the total discharges
associated with underwater ship husbandry operations outside of underwater hull cleaning are as
follows:
! "' " ' ' ,|l I '
• 12 quarts of fiberglass resin released annually from shaft coatings over the course
of 12 events
• Approximately 60 pounds of welding consumables released annually, including
spent welding rods and slag over 12 events

The estimated release amounts from other underwater ship husbandry activities are
infrequent and in small quantities. In addition, these discharges are mostly insoluble and are
unlikely to remain suspended in the water column or be dissolved.

4.2 Environmental Concentrations

Total copper has been measured in the effluent stream near hull cleaning operations at
levels of approximately 1,600 to 2,600 ug/L.10 These measured copper concentrations exceed
water quality criteria (WQC) by three orders of magnitude. Dissolved copper in those same tests
ranged from 66 to 146 ug/L, which is 28 to 61 times the Federal criterion for copper.

Using the compositional ratio of copper to zinc in antifouling paint, zinc concentrations
in the releasifiroip underwater hull cleaning are estimated to be approximately 780 ug/L. This
Value exceeds W(^dJ by one order of magnitude.
" " ' ' ' ' ... '
, .
Table 3 shows Federal and most stringent state WQC relevant to the underwater ship
husbandry discharge in comparison with the measured copper concentrations and estimated zinc
concentrations from the SCAMP discharge.

For the SEAWOLF propulsor lay-up, most states have ambient WQC for CPO of 7.5 - 13
jlg/L. The sole measured concentration available reported the concentration as being between 0
and 40 ug/L.
Underwater Ship Husbandry
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4.3 Potential for Introducing Non-Indigenous Species

Transport of non-indigenous species on the hulls of commercial vessels has been
documented.34 Although the cleaning practices, frequency of transits, and operating locations
differ for the Armed Forces, there is the potential for non-indigenous species to be transferred.
Fouling and the presence of marine organisms is most serious around intakes, grates, and sea
chests.
5.0 CONCLUSIONS

Underwater ship husbandry has the potential to cause an adverse environmental effect
because measured concentrations of copper and estimated concentrations of zinc from
underwater hull scrubbing exceed ambient water quality criteria and these constituents are
discharged in significant amounts. The potential also exists for introducing non-indigenous
species during hull cleaning.

Discharges from the other ship husbandry operations are infrequent, and are small in
terms of volume or mass loading. Therefore, these discharges have a low potential for
environmental effect.
6.0 REFERENCES

To characterize this discharge, information from various sources was obtained, reviewed,
and analyzed. Process information, engineering studies, and engineering analyses were used to
estimate the rates of discharge and the concentrations of copper and zinc released to the
environment. Table 4 shows the sources of data used to develop this NOD report.

Specific References

1. UNDS Equipment Expert Meeting Minutes - Underwater Hull Husbandry, 22 October
1996.

2. Wendel, A., Naval Sea Systems Command (SEA 03Z52), UNDS Equipment Expert
Meeting Structured Questions, "Chlorine Produced from SEAWOLF Propulsor," 8
December 1997.

3. McFarland, L., SUBLANT. Freshwater Layup, Submarine Main Steam Condensers.
Personal Communication. Miller, R.B., M. Rosenblatt & Son, Inc., 7 January 1997.

4. Naval Ships' Technical Manual (NSTM) Chapter 081, Waterbome Underwater Hull
Cleaning of Navy Ships. 4 August, 1997.

5. NAVSEA Standard Work Item (SWI009-32) FY-98, Cleaning and Painting
Requirements.
Underwater Ship Husbandry
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6. Qualified Products List of Qualified Products Under Military Specification MIL-PRF-
24647 Paint System, Anticorrosive and Antifbuling, Ships Hull. QPL-24647-3,2 April
1996.
I. , . i , . , . ji
.! i ' l! . , , ' ' , . ' " , "Jl .
7. Military Specification, MIL-PRF-24647B, 'Taint System, Anticorrosive and Antifouling,
Ship Hull," August 1994.

g." UNDS Equipment Expert Meeting Minutes - Hull Coating Leachate Discharge, M.
Rosenblatt & Son, Inc., 20 August 1996,

9. Naval Ships' Technical Manual (NSTM) Chapter 631, Preservation of Ships in Service,
Volume 3, Section 8. 1 November 1992.

10. The Naval Command, Control, and Ocean Surveillance Center, RDT &E Division, Marine
Environmental Support Office, San Diego, California. "UNDS Underwater Hull
Husbandry Evaluation: In-Water Hull Cleaning." 13 February 1997.

11. Naval Sea Systems Command Code OOC, Underwater Ship Husbandry: Compilation of
Summary Sheets and Material Safety Data Sheets for the UNDS Program, 1997.

12. Military Standard for "Glass Reinforced Plastic Coverings for Propeller Shafting," MEL-
STD-|l99,11 May 1990.

13. Naval Ships' Technical Manual (NSTM) Chapter 074, Volume 1, Section 6.1-6.9.4.3,
Welding and Allied Processes, 15 June 1995.

14. Military Standard for "Requirements for Non-Destructive Testing Methods", MDL-STD-
271F(SH), 27 June 1986.
• • ! '
-------
21. Naval Sea Systems Command, SEA OOC. Computer Assisted Information Retrieval
System (CAIRS) Underwater Ship Husbandry Database Retrieval, September 1997.

22. Dean, M., Naval Sea Systems Command, SEA OOC. Memorandum to M. Wenzel,
NSWCCD Code 632,10 April 1996.

23. Weersing, P., Military Sealift Command. Underwater Ship Husbandry Activities of the
MSC, Personal communication to UNDS file. 16 April 1997.

24. Naval Sea Systems Command, SEA OOC. Underwater Ship Husbandry Paint Operations
Data from May 1996 through August 1997.

25. Material Safety Data Sheet for ITW Philadelphia Resins, PfflLLYCLAD 1775/620TS
Resin, 7 October 1996.

26. Material Safety Data Sheet for Circle Systems, Inc. Mi-Glow Underwater 1, May 1995.

27. Material Safety Data Sheet for Courtaulds BRA 640 Interviron Red Antifouling Paint,
March 1996.

28. Davis, M.H. and J. Coughlan. "A Model for Predicting Chlorine Concentrations within
Marine Cooling Circuits and its Dissipation at Outfalls," in Water Chlorination:
Environmental Impact and Health Effects, Vol. 4, Book 1, Eds. Jolley, R.L. et al., Ann
Arbor Science, 1983.

29. Naval Sea Systems Command, SEA 03L. Chlorination Report, Malcolm Pirnie, Inc., 14
July 1997.

30. Thomann, R. V. and J. A. Mueller. Principles of Surface Water Quality Modeling and
Control. Harper Collins Publishers, New York, NY. 1987. pp. 180-185.

31. Electric Boat Corporation, Supplemental Information Relative to SEA WOLF Propulsor
NOD, Alan Wendel, Naval Sea Systems Command, 16 December 1997.

32. Electric Boat Corporation, "SEAWOLF PPCS/ICCP System Compatibility" Draft
Engineering Report, 10 June 1998.

33. Naval Ships' Technical Manual (NSTM) Chapter 633, Section 4.3.1 and Table 633-5.
Cathodic Protection. 1 August 1992.

34. Ruiz, Greg. Non-Indigenous Species Presentation - Notes by Dan G. Mosher, Malcolm
Pimie,Inc. 18 September 1996.

General References
Underwater Ship Husbandry
17
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'* I ','isj . i : . • :••...' ' I I ,
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. 62, Number 150. August 5,1997.
i i II1 "il"
Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.
, i V ' ,. ' |i '
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.

Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.

Mississippi. Water Quality Criteria for Ihtrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995:
, ( ,. r ' ' i . .

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
." '. ,.:'.•', , i

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.

Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Wafer Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).

Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
Underwater Ship Husbandry
18
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The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, pg. 15366. March 23,1995.
Underwater Ship Husbandry
19
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Table 1 - Releases Associated with Underwater Ship Husbandry on Navy Vessels
(Exclusive of Hull Cleaning)
,22
Operation
Underwater Fiberglass
Repair
Underwater Welding
Rubber Sonar Dome or
Sub Tile Repair
Non-Destructive Testing
Masker Belt Repairs
Paint Operations
Underwater/Waterline
Propulsor Protective
Covering System (PPCS)
Material Released
fiberglass resin
epoxy paint, welding
consumable, slag
rubber sealant, epoxy
iron flakes, dye,
surfactant
epoxy paint and filler;
rubber sealant
epoxy paint
chlorine produced
oxidants (CPO)
Quantity Released
per Event
1 quart
5 Ibs. (welding
consumables)
minimal
minimal
minimal
minimal
3.2 g
Events per Year
12
12
16 (surface ships)
3 (submarines)
20
6
60
6
Table 2 - Total And Dissolved Copper Concentrations From In-Water Hull Cleaning
Effluent Generated By SCAMP10
{PRIVATE }Vessel Name
USS Fort Fisher (LSD 40)
USS Tuscaloosa (LST 1187)

mean:
standard deviation:
USS Ranger (CV 61)

mean:
standard deviation:
Grand Mean:
standard deviation:
Cu,ng/L
(Filtered)
66
141
146
137
125
135
136.8
+/-7.0
106
116
118
120
124
116.8
+/'6.0
106.5
29.8
% Dissolved
4

8.7

4.5

5.5

Cu,pg/L
(Unfiltered)
1,668
1,475
1,520
1,600
1,597
1,633
1,565
+/'58.3
2,499
2,503
3,287
2,441
2,362
2,619
+/-338
1950
474
Underwater Ship Husbandry
20
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Table 3. Comparison of Constituent Concentrations with Water Quality Criteria (p.g/L)
Constituent
Copper (total)
Copper
(dissolved)
Zinc (total)
CPO
Concentration
1950
107
780
0-40
Federal Acute WQC
2.9
2.4
95.1
-
Most Stringent State Acute WQC
2.5 (WA)
2.4(CT,MS)
84.6 (WA)
10 (FL)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)

CT = Connecticut
FL = Florida
MS = Mississippi
WA = Washington
Table 4. Data Sources
\l ' " ' .
NOD Section '
2.1 Equipment Description and ^ '
Operation
2.-2 Releases to the Environment
23 Vessels Producin^lhe Discharge
3.1 Locality '"" -
3~2Rate
3.3 Constituents
3.4 Concentrations'
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species - '
Data Source.
Reported ,

X
UNDS Database

X
MSDS
X

Sampling

Estimated

X
X

Equipment Expert
X
X
X
X

X
Underwater Ship Husbandry
21
-------
Chlorine Produced Oxidants (CPO) generation rate (R) = 1 .3 g/hr
PPCS volume (V) = 21,000 gal (3.785 IVgal) = 79,485 L

Q> ~ concentration after first minute (considered 'time zero" due to first stage decay)
Ct = concentration at a given time (t)
Ct = Co e t"ktj, where k = decay constant
For t = 1 hr and C0 = 12.3 ug/L, Ct = (12.3ug/L) (50%) = 6,15 ug/L
In (Q/Co) = In (12.3/6.15) = In (0.5) = -0.693 = -kt
k = - (-0.693) / (1 hr) = 0.693 / hr
Q = Co e^ = (12.3 ug/L) e (a693t)

However, since CPO is generated simultaneously with the decay of previously
introduced CPO, a steady state concentration wiii be reached when the decay rate
equals the generation rate, which can be expressed as:30
k(CssV) = 0.
k = decay constant (hr"1)
CssV = (steady state CPO concentration) (volume) = mass (g)
R = generation rate (g/hr)
Mass=1.4 gCPd/eventor8^4gCPO/yr
Calculation Sheet 1. CPO Concentration and Mass from SEAWOLF Propulsor Layup
Underwater Ship Husbandry
22
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UNDERWATER SHIP HUSBANDRY
MARINE POLLUTION CONTROL DEVICE (MPCD) ANALYSIS
Several alternatives were investigated to determine if any reasonable and practicable
MPCDs exist or could be developed for controlling discharges from underwater ship husbandry
activities. An MPCD is defined as any equipment or management practice, for installation or use
onboard a vessel, designed to receive, retain, treat, control, or eliminate a discharge incidental to
the normal operation of a vessel. Phase I of UNDS requires several factors to be considered
when determining which discharges should be controlled by MPCDs. These include the
practicability, operational impact, and cost of an MPCD. During Phase I of UNDS, an MPCD
option was deemed reasonable and practicable even if the analysis showed it was reasonable and
practicable only for a limited number of vessels or vessel classes, or only on new construction
vessels. Therefore, every possible MPCD alternative was not evaluated. A more detailed
evaluation of MPCD alternatives will be conducted during Phase n of UNDS when determining
the performance requirements for MPCDs. This Phase n analysis will not be limited to the
MPCDs described below and may consider additional MPCD options.

MPCD Options

Underwater ship husbandry activities include inspecting, grooming, maintaining, and
repairing hulls and hull appendages while a vessel is waterborne.1 Underwater hull cleaning is, by
far, the most common underwater ship husbandry process and has the highest potential for
environmental impact. Underwater hull cleaning is performed for numerous reasons including fuel
savings, extending service life of hull coatings, and extending the interval between dry dockings
and associated coating replacement. To determine the practicability of mitigating the potentially
adverse environmental effects of these activities, three potential MPCD options were investigated.
The purpose of these MPCDs would be to reduce or eliminate the release of antifouling agents,
specifically copper and zinc, into surrounding waters during underwater hull cleaning operations.
The MPCD options were selected based on initial screenings of alternate materials, equipment,
pollution prevention options, and management practices. They are listed below with brief
descriptions of each:

Option 1: Vary hull cleaning brush type and brush pressure - The goal of this
option would be to more closely match brush stiffness and pressure to the degree
of fouling to minimize antifouling coating removal. More brush types would be
developed, and several different brush types may be used and interchanged during
the cleaning of any one vessel. By properly selecting brushes, effective cleaning
can be conducted with a minimal release of antifouling agents and associated
discharges.
Underwater Ship Husbandry MPCD Analysis
1
-------
Option 2: Mandate the maximum allowable frequency of underwater hull
cleaning - This option would reduce the number of hull cleanings permissible
within a given time period or at any one location to limit the amount of discharge
within each harbor.

Option 3: Collect water discharged from the multi-brush cleaning vehicle -
This option would provide a means to collect the discharge from the underwater
hull cleaning vehicles to prevent water that contains antifouling agents from
entering the surrounding environment.

MPCD Analysis Results
, i „ i ,i:' ,1 i ' ,,!,:jiii ' ' i ' • ' M " „; ' , ' ii i'i , • ' "i ii i '
Table 1 shows the findings of the investigation of the selected MPCD options. It
contains information on the elements of practicability, effect on operational and
warfighung capabilities, cost, environmental effectiveness, and a final determination for
each option. Based on these findings, Option 1 — varying hull cleaning brush type and
bjush pressure — offers the best combination of these elements and is considered to
represent a reasonable and practicable MPCD.
Underwater Ship Husbandry MPCD Analysis
2
-------
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-------
REFERENCES

1 Equipment Expert Meeting Minutes, Underwater Hull Husbandry, 22 October 1996.

2 McCue, T. (NAVSEA Code OOC). Personal communication with K. Thomas. Estimate of
Cleaning Brush Costs based on previous R&D of same. 1997

3 Naval Ships' Technical Manual S9086-CQ-STM-010 R3 Chapter 081, Waterbome Underwater
Hull Cleaning of Navy Ships. 4 August 1997.

4 Hundley, L. L. and Tate, C. W., Sr. (David W. Taylor Naval Ship Research and Development
Center). "Hull Studies and Ship Powering Trial Results of Seven FF 1052 Class Ships,"
DTNSRDC-80/027. March 1980.

5 Naval Petroleum Office Instruction. July 1997.
Underwater Ship Husbandry MPCD Analysis
5
-------
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NATURE OF DISCHARGE REPORT
Wetlfteck Discharges.
1.0 INTRODUCTION

The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)J. UNDS is being developed in three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,.
construction, installation, and use of MPCDs.

This section describes the welldeck discharges and includes information on the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).

2.1 Equipment Description and Operation

Several Navy ship classes have a welldeck in the aft section of the ship for embarking,
storing, and disembarking landing craft. These welldecks range from 50 to 78 feet in width, 168
to 440 feet in length, and 20 to 30 feet in height.1 During an amphibious operation or beach
assault, the ship can be positioned anywhere within proximity of land. However, the operations
are more likely to occur near the 12 nautical mile (n.m.) limit so the ship is less susceptible to
enemy gunfire from shore. The landing craft carried onboard the ship serve to ferry U. S. Marine
Corps (USMC) personnel, vehicles, and equipment to and from shore. Depending on the type of
landing craft used, the ship might fill ballast tanks with seawater to lower the ship so that the .
welldeck floods with water (see Figure 1).

The types of craft that typically operate from these ships are utility landing craft (LCUs),
air-cushion landing craft (LCACs), and assault amphibian vehicles (AAVs)i LCUs have diesel
engines to power the propellers. LCACs are gas-turbine-driven hovercraft. AAVs propel
themselves through the water with waterjets, but use tracked running gear on land. Although
AAVs can enter and exit the welldeck independently, they are also carried onboard LCUs and
LCACs. Mechanized landing craft (LCM), once common to amphibious operations, are no
longer carried by amphibious ships.1>2

Vehicles and equipment are stored hi the vehicle storage areas forward of the welldeck.
These areas are located on two levels and are connected by ramps. Vehicles and equipment are
also stored onboard the LCUs and LCACs hi the welldeck but not in the welldeck itself due to
space constraints. Similarly, containers and products are not stored in the welldeck but rather in
the vehicle storage areas or elsewhere on the ship. Examples of the vehicles carried onboard
include light armored vehicles (LAVs), AAVs, tanks, jeeps, trucks, high mobility multipurpose
wheeled vehicles (HMMWVs), and motorcycles. Examples of equipment carried onboard
include howitzers and trailers.2

The floors of the welldeck are lined with pressure treated lumber. The walls are lined
with either pressure treated lumber or synthetic batter boards except near the stern gate where the
walls are lined with rubber panels.

Vehicle and equipment maintenance is performed where the vehicles and equipment are
stored, which can include on the deck of a host LCU or LCAC. Waste products and spills
produced during vehicle maintenance are collected and held in accordance with shipboard
procedures for spill containment. Oily patches on the decks are cleaned with a detergent.2

There are five primary overboard discharges from a welldeck: (1) washout from the
Welldeck Discharges
2
-------
welldeck when the ship ballasts to embark or disembark landing craft; (2) water or detergent and
water mixture used for LCAC gas turbine engine washes; (3) graywater and condensate that can
be discharged from the LCUs; (4) freshwater wash to remove salt and dirt from vehicles,
equipment, and landing craft; and (5) U.S. Department of Agriculture (USDA) washes of the
welldeck, vehicle storage areas, and all vehicles, equipment, and landing craft. These discharges
can occur almost anywhere within 12 n.m., except for the USDA work which occurs pierside.

2.1.1 Welldeck Washout

Washout occurs when the welldeck is flooded to allow landing craft to enter or exit the
ship. However, LCACs and AAVs do not need the welldeck to be flooded to enter or exit,
although some water will naturally enter. Therefore, this discussion is primarily applicable to
LCU operations. The ship submerges the welldeck by flooding clean ballast tanks with
seawater.3 See Figure 1. When the welldeck is submerged, any debris or fluid in the welldeck is
mixed with the seawater and will eventually flow to the open sea.

2.1.2 LCAC Engine Washes

The LCAC engine washes are performed on the four gas turbine engines provided for
propulsion and the two auxiliary power units (APUs) provided to supply electrical power. There
are two types of LCAC engine washes: thorough preventive-maintenance washes that uses a
detergent to remove engine deposits and those performed daily with only distilled water to
remove salt deposits. During winter conditions, methanol may be added to the mixture to
prevent the wash water from freezing.4

Preventive-maintenance washes are scheduled every 25 operating hours for the gas
turbines and quarterly for the APUs. Because the purpose of these washes is to prevent engine
degradation, any noticeable reduction in engine performance will usually result in a wash. There
are currently two separate methods used to perform these washes but both involve flushing
distilled water and detergent through the engine while it is being rotated on the starter. One
method uses an automated cleaning system, if installed, and a detergent called ZOK-27. The
other, a more manual procedure, uses a detergent called B&B 3100 (MIL-C-85704). Following
the detergent wash, a separate distilled water wash is performed to flush out the engine. APUs
are washed hi a similar way except that the detergent is Stoddard Solvent, FedSpec P-D-680,
type m.2'3

Daily washes are performed when the LCACs have been operating, but not if preventive
maintenance washes are scheduled for the same day. This wash consists of a rinse of distilled
water through the propulsion gas turbines, but not the APUs. However, if a cleaning system is
installed it may also be used for the daily wash as it is for the preventive maintenance wash.

2.1.3 Landing Craft Discharges

LCU crews live aboard their craft in the welldeck. As such, they generate graywater (i.e.,
water from drains, sinks, and showers) as well as condensate from air conditioning systems. The
Welldeck Discharges
3
-------
4 I Ml, I,
I" '
graywater and condensate produced is drained to the welldeck. LCUs do not create blackwater
(sewage) because the crew uses the ship's sanitary facilities.3 LCACs do not have living spaces,
do not produce graywater, and do not discharge condensate into the welldeck.2 For more
information on graywater, see the Graywater NOD Report.

i,1.4 Ve|icle, Equipment, and Landing Craft Washes

Dirty vehicles and equipment returning to the ship are washed ashore, if possible. They
also will receive a freshwater wash on the ramp leading from the welldeck to the vehicle storage
area. The engine compartments are not washed.2 The wash water flows into the welldeck and is
drained overboard or pumped overboard by an eductor. The motive water for the eductors in the
welldeck and vehicle storage areas is provided by the firemain.

The aluminum structure of an LCAC is unpainted and susceptible to the corrosive effects
of seawater. To prevent this corrosion, the exterior is washed with fresh water at the conclusion
of daily operations If the LCACs are not being used, a biweekly wash is required.5 No cleaners
oj detergents are used for these washes. LCUs and AAVs are not washed in the welldeck.

2.1.5 USDA Washes and Inspections

The USDA requires that vehicles, equipment, craft, and internal shipboard areas that have
contacted foreign soil be thoroughly washed and inspected to prevent the importation of non-
indigenous species. These washes and inspections are performed prior to returning to, or upon
return to, the U.S. These washes and inspections fall into three categories; those done on the
welldeck and vehicle storage areas, those done on the vehicles and equipment, and those done on
the landing craft. These three operations normally occur in foreign ports, but can occur in the
U.S. or U.S. territories.2
:i, !||' i ' ijj , , || :
The welldeck and vehicle storage areas are washed when all of the vehicles, equipment,
and landing craft mat can be off-loaded are removed. Those that remain are too large to fit down
the exit ramp on the side of the ship. Their normal path is through the stem gate. One example
is the M-9 armored combat earthmover (ACE) which is 10.5 feet wide and 8.75 feet high.
During the washes all surfaces (decks, bulkheads, and overheads) are cleaned. The process for
the welldeck begins with a seawater wash of all surfaces followed by a freshwater wash. Unlike
the welldeck, the vehicle storage areas are only washed with fresh water. Following the washes,
the USDA inspects to ensure that no foreign species, soil, or plants are in those areas. All of the
water effluent drains overboard or is pumped overboard by an eductor.2
! , il i nili ,,:,,, , '' 'ill!, I,1;, ' ,i •' ll I ''' , ' •,
The vehicles and equipment are washed pierside, except for those discussed above that
cannot be off-loaded. They will be washed and inspected in the welldeck. The process begins
with the vehicles and equipment being parked in a designated contaminated area. Each, in turn,
is then moved to an area to have the interior cleaned. They are then moved to the wash racks and
thoroughly washed (including the engine compartments) with fresh water. The wash racks are
long wheel ramps that allow the undersides of the vehicles to be washed and inspected.
following the wash, each vehicle or piece of equipment is inspected by the USD A for foreign
Welldeck Discharges
4
-------
organisms, plants, and soil, and then moved to a designated clean area to await reloading on the
ship. The effluent from the vehicles and equipment washed in the welldeck drains overboard or
is pumped overboard by an eductor.2

The landing craft are also washed and inspected. LCACs, however, are not usually given
a special wash because enough sea spray is created in their operation that all the exterior surfaces
are flushed free of foreign organisms, plants, and soil before the LCAC boards the ship at sea and
is inspected. LCUs are washed with fresh water hi the welldeck or pierside and then inspected.2

2.2 Releases to the Environment

Effluent is discharged to the environment by washout or surge when landing craft are
operating in the welldeck. Effluent from the various washes performed in the welldeck are
discharged as it drains overboard from the welldeck or is pumped overboard by an eductor.

Welldeck washout and the effluent from the washes can contain fresh water, distilled
water, firemain water, graywater, air-conditioning condensate, sea-salt residues, paint chips,
wood splinters, dirt, sand, organic debris, oil, grease, fuel, detergents, combustion by-products,
and lumber treatment chemicals.

2.3 Vessels Producing the Discharge

Only the Navy has ships with welldecks. Ship classes with welldecks include general
purpose amphibious assault ships (LHAs), multipurpose amphibious assault ships (LHDs),
amphibious transport docks (LPDs), and dock landing ships (LSDs). While there are differences
among welldeck designs, the primary process variance is due to the type and number of landing
craft onboard. Applicable data is listed below.1

Ship No. of Welldeck Landing Craft
Class Ships Dimensions Loading Schemes

LHA1 5 268'x 78' 4 LCU, 1 LCAC, or 45 AAV
LHD1 4 267'x 50' 3 LCAC or 2 LCU
LPD4 8 168'x 50' 1 LCU or 28 AAV
LSD 36 5 430'x 50' 4 LCAC, 3 LCU, or 52 AAV
LSD 41 8 440'x 50' 4 LCAC, 3 LCU, or 64 AAV
LSD 49 3 265'x 50' 2 LCAC or 1 LCU
3.0 DISCHARGE CHARACTERISTICS

Welldeck discharges can occur both within and beyond 12 n.m.

'•'. • 3.2 ..Rate

3.2.1 Welldeck Washouts

The flow from a welldeck washout can be estimated based on the welldeck dimensions
listed in Section'2.3. The washout volume was estimated by multiplying the dimensions of the
welideck (length and width in feet) by the approximate height of water needed by an LCU (5'
forward, 9' at the stem gate).2 The numbers shown in parenthesis are estimated values for the
ainqunt of water entering the welldeck during LCAC operations (using an assumed depth of 4
inches of water spread uniformly across the welldeck). The water in the welldeck during LCAC
operations is the result of the surge created when the LCACs enter the ship and is not the result
of ballasting.
Ship Class

LHA1
'LHDl
LPD4
LSD 36
LSD 49
Estimated Gallons Per Washout (or Surge)

1,100,000(52,000)
700,000(33,000)
440,000 (0, no LCACs)
1,130,000(54,000)
1,150,000(55,000)
700,000(33,000)
On average, an amphibious ship will have one six-month deployment every two years.
During such a deployment, ballasting/deballasting will take place approximately 40 times (unless
LCACs are deployed in which case the seawater surge will enter the welldeck 40 times).2 It is
Variable how many times the ballasting/surge will take place within U.S. waters or how many
local exercises will take place during that two year period. This is because the amount of time
trial a ship spends in U.S. waters varies from ship to ship.
iiri '•• 'i! , , .''•.' ' ' j !
3.2.2 LCAC Gas Turbine Engine Washes

Approximately 12 gallons of distilled water is used for a propulsion gas turbine daily
Wash. The flow from a detergent wash would be 12.5 gallons of distilled water/detergent mix
followed by 12 gallons of distilled water rinse for a total of 24.5 gallons. For each APU, the flow
from a detergent wash would be 0.375 gallon of distilled-water-detergent mix followed by a 0.25
gallon distilled water rinse for a total of 0.625 gallon. Thus, each LCAC is capable of producing
48 gallons of effluent from the daily washes of the four propulsion gas turbines and 99.25 gallons
of effluent ifall of the engines (four propulsion and two APUs) are washed with a water-
detergent mix.2'6
Welldeck Discharges
6
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3.2.3 Graywater and Air Conditioning Condensate

LCUs discharge graywater into the welldeck because they do not have the capability to
collect and hold graywater. Air-conditioning condensate is also not collected.

During the transit of an amphibious ship from port to 12 n.m., the LCU would have 4
hours to generate graywater. The rate of graywater generation for Navy personnel is given as 30
gallons per person per day. Thus, an LCU with a typical load of six crew members could
generate 180 gallons of graywater per day or 30 gallons of graywater during the 4-hour transit
period. However, little or no graywater is produced and discharged within 12 n.m. because the
crew of the LCU is occupied with preparations for, or stand down from, welldeck operations.

The generation of graywater on an LCU while the host ship is operating within 12 n.m.
has not been estimated since the time that a host ship will be operating within 12 n.m. varies.
LCU air-conditioning capacity varies from 5 to 8 tons which, under severe heat and humidity
conditions, can produce 30 to 48 gallons of condensate per day.

3.2.4 Vehicle, Equipment, and Landing Craft Washes

When returning to the ship, vehicles and equipment receive a freshwater wash on the
ramp leading from the welldeck to the vehicle storage area. This freshwater wash uses a 1.5-inch
firehose at a rate of about 95 gallons per minute (gpm).2 The wash typically takes 30 seconds, so
it is estimated that 48 gallons of fresh water is used per wash. A typical ship contains about 100
to 125 vehicles and pieces of equipment, so approximately 4,800 to 6,000 gallons could be
discharged if all of the vehicles and equipment are returned to the ship and washed consecutively.

The exterior wash of the LCACs is performed at the end of daily operations. This wash
also uses a 1.5-inch firehose at a rate of 95 gpm and lasts for about 10 minutes. Estimates from
LCAC personnel indicate that about 1,000 gallons of water are used per LCAC, which is
consistent with a 10 minute wash at 95 gpm.2 Since the number of LCACs carried onboard a
ship can vary as shown in Section 2.3,1,000 to 4,000 gallons of water could be released by these
washes. However, if the LCACs are not being used, only a biweekly wash is required.5

3.2.5 USDA Washes and Inspections

The welldeck and vehicle storage areas are washed differently. The welldeck is first
washed with seawater via the firemain, and then washed with fresh water. The vehicle storage
areas are only washed with fresh water. Each wash takes about 45 minutes. The seawater wash
of the welldeck uses a 1.5-inch firehose at a rate of about 95 gpm of seawater. Based on the
estimated time of 45 minutes, about 4,275 gallons are used. The freshwater wash of the welldeck
also uses a 1.5-inch firehose at a rate of about 95 gpm. Again, based on the estimated time of 45
minutes, about 4,275 gallons are used. The upper and lower vehicle storage areas are washed
separately with fresh water, each taking about 45 minutes, and using a 1.5-inch firehose at a rate
of about 95 gpm. To summarize these estimates, 4,275 gallons of firemain water and 4,275
gallons of fresh water are used to wash the welldeck and 8,550 gallons of fresh water are used to

Welldeck Discharges
7
-------
\
The vehicles and equipment are washed with a 1.5-inch firehose at a rate of about 95 gpm
qf fresh water. Each vehicle or piece of equipment takes about 5 minutes to wash. Therefore,
about 475 gallons of water are used. If five to ten vehicles or pieces of equipment were unable to
be off-loaded, 2,375 to 4,750 gallons of water could be used.

The duration of the landing craft washes for calculation purposes will be estimated at 15
minutes using a 1.5-inch firehose at rate of about 95 gpm of fresh water. Therefore, about 1,425
gallons could be used for each landing craft. The washing of the LCACs in this manner is
unlikely however, so the loading of one to four LCUs (from Section 2.3) is used to yield a range
of effluent produced which is 1,425 to 5,700 gallons.

3.3 Constituents

The potential constituents of this discharge include:2'3
... i iii; , ' .''[[

.';.,• air-conditionuig condensate
• automotive grease
• B&B 3100 detergent (MIL-C-85704)
• bromine (from the wash water)
• chlorine (from the wash water)
• detergent
• gas turbine fuel, JP-5 (MIL-F-5624E)
• graywater
• lumber-treatment chemicals
• methanol
motor oils
naval distillate fuel, F-76(MIL-F-16884)
nickel, copper, zinc, and other metals
• solvent P-D-680 type HI (petroleum distillate)
• Vehicle diesel fuel, F-34 (MEL-T-83133)
• ZOK-27 water-soluble detergent

ZO]£j-27 contains ethanol arid 2-butoxyethanol, while B&B 3100 contains solvent-refined
heavy naphthenic distillate and petroleum solvents. Marine diesel fuel (F-76) contains petroleum
mid-distillates, antisetting agents, and flow improvers.

It is possible that lube oils, greases, and fuel oils can be spilled on welldeck surfaces.
However, spills will be quickly wiped up hi accordance with shipboard practices, so any oils or
greases found on welldeck surfaces will exist as surface films. Such surface films may contain
benzene, toluene, ethylbenzene, and xylenes which are the common constituents of lighter
petroleum products. These chemicals are also priority pollutants, as are various metals (e.g.,
copper and nickel) which are in firemain water and could be present in greases, oils, and fuels.
Welldeck Discharges
8
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There are no constituents present in welldeck discharges that are bioaccumulators.8

3.4 Concentrations

The constituent concentrations have not been estimated. The concentration of metals in
the firemain water is discussed in the Firemain Systems NOD Report.
4.0 NATURE OF DISCHARGE ANALYSIS

Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. A discussion on the
mass loadings is presented in Section 4.1. In Section 4.2, the concentrations of discharge
constituents after release to the environment are discussed along with the water quality standards.
In Section 4.3, the potential for the transfer of non-indigenous species is discussed.

4.1 Mass Loadings

Since numbers that quantify the constituents of the various components of this discharge
are unknown and variable, mass loading calculations cannot be performed with any accuracy.
However, generalized statements regarding the mass loadings can be made based upon the
physical features of the discharge.

4.1.1 Welldeck Washouts

Spills from vehicle and equipment maintenance within the welldeck could potentially
result hi the discharge of substances such as oil. These spills can leave a residue on the deck.
However, spills are controlled by shipboard procedures for spill containment and clean-up. Oily
patches on the decks are cleaned with a detergent.2 The small amounts of constituents remaining
as surface films in the welldeck do not support the production of significant mass loadings.

4.1.2 LCAC Engine Washes

The degree to which engine contaminants are removed by the wash water is unknown and
the amounts of engine washes within 12 n.m. are unknown. Since there are many LCACs and
not all of them are operating each day or are not within U.S. waters, it will be assumed that 1
LCAC is operating each day in U.S waters and requires an engine wash. Since the gas turbine
engines are relatively clean, it is assumed that, at most, a few tablespoons of hydrocarbon
constituents will be removed by each wash. Using these numbers, only 3-5 gallons of
hydrocarbon constituents would be released by the engine washes, per year, in U.S. waters.

4.1.3 Graywater and Air Conditioning Condensate

As discussed in section 3.2.3 above, it is estimated that 30 gallons of graywater can be
discharged from an LCU while the host ship is transiting to 12 n.m. LCUs are not normally

Welldeck Discharges
9
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carried onboard amphibious ships since LCACs are favored. Assuming 10 LCUs are carried
onboard ships during a year, and assuming that each ship transits the 12 n.m. zone 6 times per
year, it is estimated that, at most, 1800 gallons of graywater will be released per year during
transit. These assumptions overestimate the amounts of graywater produced because it is
unlikely mat each LCU on a host ship is discharging graywater at the maximum design rate
during the entire 12 n.m. transit. Graywater production is likely to be much lower during transit
because the I^QU crew is occupied with preparations for, or stand down from, welldeck
operations. In port, mass loadings of graywater can equal the design rate so each LCU could
produce 180 gallons per day (32,760 gallons per year assuming 6 months in port).
!' ' :" l:li: 'Bill .• .,,,•• • " :; • ;' . • , fv" , , iil: , ", ,. ;
Ij. : .:. . v • '.' '. ' •; '''•..' J: ••[.!.•• . ', ! ' :
Base
-------
4.2.1 Welldeck Washout

Spills from vehicle and equipment maintenance within the welldeck could potentially
result in the discharge of substances such as oil. The spills can coat the deck with a residue.
However, the spills are controlled by shipboard procedures for spill containment and clean-up.
Oily patches on the decks are cleaned with a detergent.2 The small amounts of constituents
remaining as surface films in the welldeck do not support the production of significant mass
loadings. The large water volumes involved (see 3.2.1) and the small volumes contained in the
surface films do not appear to support the production of significant contaminant concentrations
in the washouts and it is not expected that they will exceed federal or state water quality criteria.
The visual criteria for oily discharges is that the discharge does not cause a sheen while the Act
to Prevent Pollution from Ships limits the oil content of the discharge to 15 parts per million
(approximately 15 mg/L). Florida has set a criterion of 5,000 micrograms per liter (|ig/L) with
no visible sheen.

4.2.2 LCAC Engine Washes

Since this discharge comprises a low volume of water which passes through an engine
and is in contact with hydrocarbons, it is believed that water quality criteria can be exceeded. A
rough estimate of contaminant concentrations can be performed to check the validity of assuming
that hydrocarbon concentrations in the discharge can exceed water quality criteria. It does not
seem unreasonable to assume that one teaspoon (4.9 mL) of hydrocarbon constituents could be
deposited within the gas turbine engine and washed away in the discharge. The 4.9 mL placed in
12 gallons (45.42 L) of water (daily wash) will yield a hydrocarbon concentration of about
108,000 ppb of oil which exceeds the Florida water quality criterion of 5,000 ppb of oil. This
rough calculation supports the assumption that water quality criteria can be exceeded. There is
also the possibility that trace amounts of metals could be present that exceed federal and state
water quality criteria. Furthermore, the nature of the detergent wash will liberate more
hydrocarbon constituents and it is still assumed that water quality criteria can be exceeded, even
though twice as much water is used.

4.2.3 Graywater and Air Conditioning Condensate

As discussed in section 3.2.3 above, it is estimated that 30 gallons of graywater can be
discharged from an LCU while the host ship is transiting the 12 n.m. zone, or 180 gallons per day
in port. LCU graywater has not been sampled, but it is possible that graywater sampling data for
surface ships can be applied to the LCUs. According the Graywater NOD Report, the measured
concentrations of several metals in the discharge exceed ambient water quality criteria and the
estimated loadings of nutrients, solids, and oxygen-demanding substances are high.

As discussed in section 3.2.3 above, it is estimated that 30 to 48 gallons of air-
conditioning condensate can be produced each day. Based on the Refrigeration/AC Condensate
NOD Report, this discharge contains little or no constituents and has a low probability of
producing an environmental effect.
Welldeck Discharges
11
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4.2.4 Vehicle, Equipment, and Landing Craft Washes

Although concentrations have not been calculated, the low volumes of water that are
mixed with small amounts of hydrocarbon constituents, are not considered to exceed federal or
state water quality criteria or to have an environmental effect.

4.2.5 USDA Washes and Inspections
1 •' , !":!:" ''•••'?' •" ':,' ': ' ' •' • , "' : : ..••!'
The discharge from the USDA washes of the welldeck and vehicle storage areas will
c|ntain dirt, debris, detergents, and hydrocarbons in concentrations that could possibly exceed
federal discharge standards or state water quality criteria. The washes of the welldeck will also
contain metals from the ship's firemain.
i"1 ' !f»:,,,!liii , " ,', , , ' • , , . i ' . • , "
4.3 Potential for Introducing Non-Indigenous Species

Although washes and inspections are required by the USDA for the vehicles, equipment,
landing craft, welldeck, and vehicle storage areas, the potential for introducing non-indigenous
species exists when the washes occur in U.S. ports. The wash water effluent could potentially
carry non-indigenous species from the ship into the water. It should be noted that the USDA
washdowns are intended to prevent transfer of non-indigenous species to land and the viability of
any waterbome species introduced is questionable since they generally would have been exposed
to air for extended periods of time prior to their introduction into U.S. coastal waters (i.e., for the
most part, these species would have been removed from vehicles and deck surfaces and thus it
would not be a water-to-water transfer, in contrast to species transfers from ballast water
systems).
5,0 CONCLUSIONS
, IP t :"..|ll''iil! • ' i ' .1"' • |l ! "
. !ii ; , . ,'ij ! • ; || ; •, : ' „, •;! ,
If uncontrolled, discharges from the well deck could possibly have the potential to cause
an adverse environmental effect because oil drippings spilled during vehicle and equipment
maintenance would leave an oil film on the deck surface. When the welldeck is flooded, the oil
film can be washed from the deck by the incoming water. An oil sheen could possibly be
discharged when water within the welldeck is discharged. However, current management
practices provide for the clean-up of oil and other substances spilled during routine maintenance.
These practices reduce the possibility of discharging an oil sheen.
6.0 DATA SOURCES AND REFERENCES

To characterize the discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge. Information to
determine the concentrations and loadings of constituents is not available. Table 1 shows the
sources of data used to develop this NOD report.

Welldeck Discharges
12

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Specific References

1. Sharpe, Richard. Jane's Fighting Ships. Jane's Information Group, Ltd., 1996. 790-792.

2. Report on the Ship Check of USS Kearsarge (LHD 3) by M. Rosenblatt & Son, Inc.
(MR&S) dated October 1,1997.

3. UNDS Equipment Expert Meeting Minutes - Welldeck Washout, October 3,1996.

4. Welldeck/LCAC Questionnaire completed by Assault Craft Unit 4, June 1997.

5. Operating Instructions for LCAC/Welldeck Operations, SEAOPS Manual for LCAC,
Volume m, Revisions 1 and 2. September 30,1995.

6. Eaton, Tim, CAPT USMC, USS Kearsarge. Gas Turbine Water Washes, 10 October
1997, David Eaton, MR&S, Inc.

7. Committee Print Number 95-30 of the Committee on Public Works and Transportation of
the House of Representatives, Table 1.

8. The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.

General References

USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.

Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.

Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.
Welldeck Discharges
13
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,„".,,' ' ' '.': • i , i!1;
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of Natfpnal Affairs, Inc., 1996.
i::' "•;' !".'' •• • ' ' :. .'. , i . .
Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
'f '•' V! i.fjj : ;, | , 'I';1 "• • • . • ,1 •' " I';'!;, '' j . "
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.

New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Lie., 1996.

Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
• , SI" J! : , ' •! " .• "!'l ' , "Jl :
YJrghiia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.

Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
Welldeck Discharges
14
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Welldeck Discharges

15
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Table 1. Data Sources

NOD Section
2.1 Equipment Description and
Operation.
23. Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigcnous Species
Data Source
Reported

UNDS Database

MSDS

Sampling

Estimated

X
X
X
X
X

Equipment Expert
X
X
X
^_ X

X
Welldeck Discharges
16
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Appendix B
Matrix of Navy Vessels and Discharges
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Appendix C
Matrix of MSC Vessels and Discharges
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Appendix D
Matrix of Coast Guard Vessels and Discharges
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Appendix £
Matrix of Army Vessels and Discharges
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Appendix F
Matrix of Marine Corps Vessels and Discharges
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