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.
                                           l-l

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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,
                                            1-2

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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

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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

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(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

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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

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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

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                       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

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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

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 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
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                        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

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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

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                      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
                                            4-10

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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.
                                          4-12

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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.
                                          5-1

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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
                                          5-36

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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
                                         5-37

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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

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

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

       2.2     Releases to the Environment

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

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

       2.3     Vessels Producing the Discharge

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

       This section contains qualitative and quantitative information that characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and 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.

                           Aqueous Film Forming Foam (AFFF)
                                          3

-------
       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.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
       Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
       Register, Vol. 62, Number 150.  August 5,1997.

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

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

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

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

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

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

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

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

Washington.  Water Quality Standards for Surface Waters of the State of Washington.  Chapter
       173-201 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.

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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

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

Sampling










Estimated .




X


X
X
X
Equipment Expert
X
X
X
X
X




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

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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

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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

       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

       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

-------
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.

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

-------
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

-------
                                 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

-------
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


22
25


60

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

20
10


20
10


none

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

10
20


10
20


30

Notes:
Information taken from a NAVSSES Memo of 23 August 1991,5 detailing boiler blowdowns per year and revised
based ship operation, time in port, and operation within 12 n.m.
* - The USCG auxiliary boilers conduct surface blowdowns once per day.
Most of their activity is performed within 12 n.m. and therefore the number of bottom blowdowns are elevated to
control boiler water chemistry.
                              Boiler 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

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

lofl
lofl

lofl
lofl

lofl
lofl

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

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

6

37,700
38,750

1

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
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

0.01
0.01

8
9

0.004
0.02

1

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

83

27.6

32.4

8,080
5,380

53.1
Frequency of
Detection


lofl
lofl

lofl

lofl

lofl

lofl
lofl

lofl
Mass Loading
(Ibs/yr)

0.4
1

0.02

0.01

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
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

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) > : '

1

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

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

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

0.00
0.02

0.01

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


Iof2

Iof2

Iof2

2 of 2
2 of 2

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

BDL

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
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

2 of 2
2 of 2

Iof2

Iof2

Iof2

Iof2
2 of 2
f
Iof2
Minimum
Concentration


1.7
30.7

BDL
BDL

12.95
119

19,250
28,500

BDL

BDL

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

1

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

1

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

1

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

27

1

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

1

0.01

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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-------
    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)

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
                                              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)

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

FL = Florida
GA = Georgia
HI = Hawaii
WA = Washington
                                       Boiler 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
X

X


Estimated




X


X

X

Equipment Expert
X
X
X
X
X





X
   Boiler Slowdown
          52

-------
                     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.

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

-------
2.0    DISCHARGE DESCRIPTION

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

       2.1    Equipment Description and Operation

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

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

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

       2.1.1   Catapult Water Brake Tank

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

       The oil used to lubricate the catapult power cylinder conforms to both SAE J1966, Grade
60 and Military Specification 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

       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

       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

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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

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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

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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.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
      Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
      Register, Vol. 62, Number 150. August 5,1997.

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

              Catapult Water Brake Tank and Post Launch Retraction Exhaust
                                         8

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       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
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
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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

X






Sampling











Estimated




X
X
X
X
X
X

Equipment Expert
X
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

       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.
                           Catapult Wet Accumulator Discharges
                                           1

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2.0    DISCHARGE DESCRIPTION

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

       2.1     Equipment Description and Operation

       Aircraft are launched from aircraft carriers using a steam driven catapult piston. Steam is
supplied to a catapult from a 16,000-gallon pressure vessel known as a catapult wet accumulator.
The wet accumulator contains a mixture of steam and saturated water at a high temperature and
pressure. As steam is released from the accumulator for a launch, the pressure drops in the
accumulator and water flashes to steam producing additional steam. The pressure from the steam
against the catapult piston forces the piston to accelerate rapidly, providing sufficient force and
velocity to  launch the aircraft.1  Each aircraft carrier has four catapults.

       Approximately 8,000 gallons of boiler feedwater are used when initially filling an
accumulator on conventionally-powered aircraft carriers. Similarly, 8,000 gallons of steam
generator feedwater are used when initially filling an accumulator on nuclear-powered aircraft
carriers.  Feedwater from boilers and steam generators contain similar constituents.  Feedwater is
distilled fresh water from the ship's water generating plant. Steam from the ship's main steam
plant is used to maintain the water level and to pressurize the accumulator to between 450 and
520 pounds per square inch (psi).2 The steam is provided to the accumulator through a manifold
that distributes the steam below the water level in the accumulator. Figures 1 and 2 show a
schematic of a wet accumulator and its associated external and internal piping.

       The continuous addition and condensation of steam during flight operations, while
standing by for flight operations, or during catapult testing causes the water level in an
accumulator to rise. 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

       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

       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

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       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

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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

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5.0   CONCLUSION

      Catapult wet accumulator discharge has a low potential to cause an adverse
environmental effect because:

      •      Mass loadings of benzidine, bis(2-ethylhexyl) phthalate, nitrogen, phosphorous,
             copper, and nickel within 12 n.m. are small, less than a pound per year combined
             fleetwide, discharged at concentrations near WQC;

      •      The discharge contains small quantities of water treatment chemicals;

      •      Resulting contributions to environmental concentrations from the discharge are
             expected to be insignificant because the discharge event is spread out over
             multiple blowdowns that allow concentrations to dissipate; and

      •      The discharge of a wet accumulator pierside does not cause thermal effects that
             exceed known state thermal mixing zone criteria.
6.0    DATA SOURCES AND REFERENCES

       To characterize this discharge, information from various sources were obtained. Process
information and assumptions were used to estimate the rate of discharge. Based on this estimate
and on concentration requirements of boiler feedwater chemistry, the concentrations of feedwater
chemistry constituents resulting from this discharge were then estimated. Table 3 shows the
sources of data used to develop this NOD report.

Specific References

1.     UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Discharges,
       Round Two Meeting. March 14,1997.

2.     UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Steam
       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

                                                                      5

                                                                      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
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



X

Sampling










Estimated






X



Equipment Expert
X
X
X
X

X

X

X
                             Catapult Wet Accumulator Discharges
                                               13

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                     NATURE OF DISCHARGE REPORT
                                  Cathodic Protection
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.
                                  Cathodic Protection
                                           1

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2.0    DISCHARGE DESCRIPTION

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

       2.1    Equipment Description and Operation

       Nearly all vessels use some form of cathodic protection to prevent metal hulls and
underwater structures from corroding.  The Armed Forces (Navy, Air Force, Army, Military
Sealift Command (MSC))  and the U.S. Coast Guard (USCG) use cathodic: protection, in
conjunction with corrosion-resistant coatings, to protect their vessels.  This combination provides
an optimal corrosion control system which utilizes the advantages of each individual system.
While coatings are the primary means of controlling corrosion, nearly all coatings have some
defects (whether from wear or damage) and some components are uncoated by design (e.g.,
propellers).  Cathodic protection could, in theory, be used alone to protect a hull and other
external underwater structures, but the number of anodes for sacrificial-anode-based systems or
power requirements for Impressed Current Cathodic Protection (ICCP)-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

       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

       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

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                                           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
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                                             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.

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                                            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

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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
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       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

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                                          14

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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

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       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.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
       Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
       Register, Vol. 62, Number 150. August 5,1997.

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

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

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

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

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

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

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

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

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

UNDS Equipment Expert Meeting Minutes- Protection, Sacrificial Anodes. August 6,1996.
                                  Cathodic Protection
                                          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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CQ
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                                  CQ
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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

X


X

Sampling








X

Estimated

X

X
X

X
X
X

Equipment Expert
X
X
X
X
X
X
X
X

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

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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

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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

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                      NATURE OF DISCHARGE REPORT
                                 Chain Locker Effluent   '
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.
                                 Chain Locker Effluent
                                           1

-------
2.0    DISCHARGE DESCRIPTION

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

       2.1   Equipment Description and Operation

       Surface vessels of the Armed Forces have one to three anchors, depending on vessel
class.1 Each surface vessel's anchor is attached to at least 810 feet (135 fathoms) of steel chain
that is stored below decks in the chain locker when not in use. The chain is constructed in 90-foot
(15-fathom) lengths, called "shots," which are connected together by detachable links. A diagram
of a typical detachable link is provided in Figure 1.  The inside of each detachable link is greased
to prevent binding and corrosion, and to permit easy disassembly of the detachable parts. The
chain locker is an enclosed compartment used only to store the anchor chain.  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

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       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

       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

       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

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       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

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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

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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.

 USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
       Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
       Register, Vol. 62, Number 150. August 5,1997.

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

 Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
       62-302. Effective December 26,1996.
                                 Chain Locker Effluent
                                          6

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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

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              MATCH MARKS
        NOTCH
Figure 1. Schematic Diagram of a Typical Detachable Chain Link
                    Chain Locker Effluent
                            8

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Figure 2. Schematic Diagram of a Typical Chain Locker
                Chain Locker Effluent
                        9

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           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

22


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

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




X

unknown
unknown
unknown


Equipment Expert
X
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

       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.
                                     Clean Ballast
                                          1

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2.0    DISCHARGE DESCRIPTION

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

       2.1    Equipment Description and Operation

       Ballast water is carried by many types of vessels and is held in a variety of tanks. The
relative complexity of ballast operations depends on the size, configuration, and requirements of
the vessel and on the complexity of its pumping and piping systems.

       Clean ballast water is seawater which is introduced into dedicated ballast tanks to adjust a
vessel's draft, buoyancy, trim and list, and to improve stability under various operating
conditions. For example, ballast water is used on various vessel classes to replace the weight of
off-loaded cargo or expended fuel oil. Generally, seawater is directed to the ballast tanks from
the firemain, by flooding, and/or from dedicated ballast pumps.  Ballast intake systems are
usually covered with a grate; suction strainers can be used to protect the pumping system from
debris. Ballast water is discharged through valves by gravity or pressurized air, or is pumped out
by eductors. Clean ballast tanks are dedicated to ballasting operations and their contents are not
mixed with fuel or oil.

       Amphibious assault ships also flood clean ballast compartments during landing craft
operations to lower the ship's 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

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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

       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

       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

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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

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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

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       3.4    Concentrations

       Although suspected constituents in clean ballast discharge have been identified,
constituent concentrations were not estimated.
4.0    NATURE OF DISCHARGE ANALYSIS

       Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated.  Mass loadings are
discussed in Section 4.1 and the concentrations of discharge constituents after release to the
environment are discussed in Section 4.2. In Section 4.3, the potential for the transfer of non-
indigenous species is discussed.

       4.1     Mass Loadings

       Using known tank volumes and numbers of vessels in specific classes, an estimate of the
total ballast capacity is presented in Table 2. Most surface vessels are required to conduct double
exchanges outside of 12 n.m. of shore unless the discharge of the clean ballast is located in the
same geographical region as the intake, or operational conditions prevent the double flush from
being performed.  Additional ballast exchanges occur within 12 n.m. Although total ballast
capacity estimates have been made, mass loading of chemical constituents were not estimated
due to the uncertainty in the frequency of ballasting operations and the lack of chemical
constituent data.

       4.2    Environmental Concentrations

       Although water quality criteria are available for suspected constituents, no analyses have
been completed and constituent concentrations are not available.  A comparison of
concentrations with water quality criteria was not made.

       4.3    Potential for Introducing Non-indigenous Species

       Discharged clean ballast water from vessels of the Armed Forces has potential for
introducing non-indigenous species into receiving waters. This can be inferred from studies of
commercial vessels.

       Studies of foreign ballast water commonly introduced into the Chesapeake Bay found that
more than 90% of the commercial vessels carried live organisms. Forty percent of the sampled
vessels had organisms within their ballast tanks including dinoflagellates and diatoms.  Such
organisms are suspended in both water and sediments within ballast tanks. Organisms also may
attach to tank walls and be dislodged during deballasting.13 One study characterized a variety of
non-indigenous species in 159 cargo vessels arriving in Coos Bay, Oregon, from 25 different
Japanese ports. The study found 367 distinctly identifiable taxa, representing 16 animal phyla, 3
protist phyla, and 3 plant divisions. Organisms present in most vessels included copepods (99%

                                      Clean Ballast
                                            6

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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

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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.

USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
      Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria.  60 FR
      22230. May 4,1995.
                                    Clean Ballast
                                         8

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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.

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

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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

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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

       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.
                               Compensated Fuel Ballast
                                          1

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2.0    DISCHARGE DESCRIPTION

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

       2.1   Equipment Description and Operation

       Compensated ballast tanks are used for fuel storage and to maintain stability on some
classes of Navy vessels. As fuel is consumed while underway, water is taken in by the vessel to
maintain a nearly constant total fluid weight in the vessel. Compensated fuel ballast tanks are
maintained full of either fuel, seawater, or a combination of both. When both fuel and seawater
are present in the same tank, the fuel floats on top of the seawater because the fuel is less dense.
These tanks are only completely emptied of all fluid (seawater and fuel) during in-tank
maintenance or modification work that is not part of the ships' normal operation.

       In vessels that use compensated fuel ballast systems, several compensated fuel ballast
tanks are connected in series to form a tank group.  The first tank of the group is called the
"receiving tank." Fuel enters and exits the tank group via the receiving tank. The last tank of the
group is called the "overflow/expansion tank." Seawater enters and exits the tank group via the
overflow/expansion tank from the ship's firemain.  Compensating water is introduced into the
overboard discharge pipe of the overflow/expansion tank through a level control valve. This
valve maintains a constant pressure within the compensated fuel tanks. The compensated
ballast/fuel storage tanks are 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

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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

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          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

       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

       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

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       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

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       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

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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

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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.

USEPA. Interim Final Rule.  Water Quality Standards; Establishment of Numeric Criteria for
      Priority Toxic Pollutants; States'  Compliance - Revision of Metals Criteria. 60 FR
      22230. May 4,1995.
                              Compensated Fuel Ballast
                                         9

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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.

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

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                        KQ
Figure 1. Fuel Tank Group 3 and 4 (Typical) Compensated Seawater Ballast
                       Compensated Fuel Ballast
                                11

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Figure 2. Compensated Fuel Ballast Tank Layout
                 Compensated Fuel Ballast
                          12

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                                          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

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           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

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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

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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

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         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

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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

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     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

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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

X

Sampling





X
X

X

Estimated




X


X


Equipment Expert
X
X
X
X

X
X


X
Compensated Fuel Ballast
          20

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                      NATURE OF DISCHARGE REPORT
                        Controllable Pitch Propeller Hydraulic Oil
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 candidates for regulation under UNDS.  The NOD reports were developed
based on information obtained from the technical community within the Navy and other branches
of the Armed Forces with vessels potentially subject to UNDS, from information available in
existing technical reports and documentation, and, when required, from data obtained from
discharge samples that were collected under the UNDS program.

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

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2.0    DISCHARGE DESCRIPTION

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

       2.1     Equipment Description and Operation

       CPPs are used to control vessel speed and direction without changing the speed or
direction of the vessel's main propulsion plant shafting. With CPPs, the angle of the propeller
blades (pitch) is variable, which affects the "bite" that the blade has on the water. This allows
the amount of water displaced in the forward or reverse directions to be varied, which changes
the forward and reverse speed of the vessel.

       The pitch of the CPP blades is controlled hydraulically through a system  consisting of a
pump, piston, crosshead, and blade crank rings.  The piston, crosshead, and crank rings are
located in the propeller hub.  High pressure hydraulic oil, acting on either side of the piston,
moves the piston axially within the propeller hub.  The piston is attached to a piston rod that
connects to the crosshead that moves axially with the piston. Sliding blocks fit in machined slots
on the crosshead and these sliding blocks fit over eccentrically-located pins mounted on the crank
pin rings. As the crosshead moves forward and backwards within the hub, the sliding blocks
move in an arc that also  moves the eccentric pin and rotates the crank pin rings to which the CPP
blades are bolted.1

       High-pressure hydraulic control oil is provided to each propeller by a hydraulic oil
pressure module (HOPM). While operating, the HOPM supplies oil pressure at  400 pounds per
square inch (psi) to control the CPP. While a vessel is pierside, the HOPM is idle and the
pressure to the CPP consists of approximately 6 to 8 psi provided by  16 to 21 feet of hydraulic
head, depending on the vessel class, from a 40- to 65-gallon reservoir that supplies head to a
larger sump tank (600 to 800 gallons) for the CPP system.  Several rubber O-ring seals, along
with the finely machined surfaces of the blade port cover, the bearing ring, and the crank pin
ring, keep the hydraulic  oil inside the CPP hub and away from the water.

       Figures 1 through 3 show cross sections and a top view of a CPP.  Figure 4 is a block
diagram of a CPP system.

       2.2    Releases to the Environment

       The hydraulic oil can be released under three conditions from a CPP and CPP
maintenance tools:  leaks past CPP seals; releases during underwater CPP repair and
maintenance activities; and release of power head tool hydraulic oil during CPP  blade
replacement. Small quantities of oil can leak past the CPP seals if they are old, worn, or
defective.
                         Controllable Pitch Propeller Hydraulic Oil
                                            2

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       Oil can also be released to the environment during the underwater maintenance of CPP
propeller blades or seals.2 Underwater maintenance is performed to:  1) replace seals or center
blade post sleeves; or 2) replace one or more propeller blades. The procedures for performing
underwater replacements are detailed in reference (2). The detailed information in the following
subsections applies to Navy vessels. Data on Military Sealift Command (MSC) underwater
replacements are unavailable, and the U.S. Coast Guard (USCG) performs replacements only in
dry dock.3'4

       Blade Port Cover Removal.  Approximately five to seven of the estimated thirty
underwater replacements per year fleetwide are to remove blade port covers for maintenance and
can cause some hydraulic oil to be released from the CPP hub.5 The CPP hub seals or center post
sleeve are replaced when observations or inspections indicate failure or cracking.6 To change
hub seals or the center post sleeve, the CPP blade is removed to access the blade port cover,
which, in turn, must be removed to access the seals and center post sleeve.  The underwater
husbandry manual for the underwater change outs also references "NAVSEA Best Management
Practices (BMPs) to Prevent/Mitigate Oil Spills Related to Waterborne Removal(s) of Blades on
Variable Pitch Propellers for Naval Vessels." This BMP is described in Section 3.2.2.

       CPP Blade Replacement.  CPP blade replacement normally occurs after a casualty that
causes blade damage (e.g., running aground, hitting a submerged object). During blade
replacements, a CPP blade is unbolted from the blade port cover and replaced (see Figure 1).
Removing a CPP blade does not, in itself, cause hydraulic oil to be released from the CPP hub
assembly (other than that released by the bleeding procedure described above). Seals, bearings,
and sleeves are still in place to prevent any oil from being released.

       During CPP blade replacement, the blade is rotated to the 12 o'clock position to remove
the Morgrip bolts that secure the blade to the CPP hub.6 The Morgrip bolts are removed with a
hydraulic power head tool. Before the power head tool is used, it is bled of air underwater while
attached to the Morgrip bolt by allowing oil to flow from a port until a "steady stream of
hydraulic fluid (no air) bleeds from the loosened port opposite the HP tube  in the power head."6

       2.3    Vessels Producing the Discharge

       The Navy, MSC and USCG operate vessels equipped with CPPs. The Army and Air
Force do not operate any vessels equipped with CPPs. Table 1 lists the vessels that have CPPs
and the number of shafts (i.e., number of CPPs, per vessel).
3.0    DISCHARGE CHARACTERISTICS

       This section contains qualitative and quantitative information that characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and 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 provides concentrations of the constituents in the discharge.
                        Controllable Pitch Propeller Hydraulic Oil
                                          3

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       3.1    Locality

       Leaks of hydraulic oil past seals can occur at sea or within 12 n.m. of shore. Discharge
underway is more likely than while pierside or at anchor because the CPP system is operating
under a higher pressure.

       Hydraulic oil can be discharged within 12 n.m. of shore during CPP repairs. The
replacements are performed in port and are conducted on an as-needed basis when dry-docking is
not scheduled for a vessel or is impractical.

       3.2    Rate

       The rate of oil release from CPPs will vary with the activity performed on the CPP. The
leakage rate from CPP seals is expected to be negligible while the release of oil from CPP blade
replacement will be larger. The release of oil from the underwater replacement of CPP seals will
generate more oil than the underwater replacement of CPP blades only.  The following
paragraphs provide further information related to the anticipated release rates from CPPs.

       3.2.1  Leaks From CPP Seals

       The systems that monitor hydraulic oil loss can detect catastrophic failures on the order of
5 to 250 gallons over 12 hours, but not small leaks. The internal pressure in the CPP hub is
approximately 6 to 8 psi, depending on the vessel class,  when the HOPM is not operating (e.g.,
while a vessel is pierside). The external pressure from the seawater is approximately 5.8 to 8 psi
provided by 13 to 18 feet of seawater, depending on the vessel class.  Therefore, the pressure
differential between the hydraulic oil in the CPP and the seawater is low (e.g., 1 psi or less) and
provides little driving force to force oil from the CPP hub.  Leakage rates under these conditions
constitute seal failures requiring repairs/replacement considering that CPP hubs are designed to
operate at 400 psi without leakage.  CPPs are pressure tested at 400 psi prior to ship delivery and
during dry dock maintenance. The CPPs are inspected quarterly for damage and signs of failure
or excessive wear.7 CPP seals are designed to last five to seven years and are reported to last
their projected life.7'8 Most Navy vessels equipped with CPPs have dry-dock cycles of
approximately five years and MSC vessels have dry-dock cycles of two to three years.3'9'10
During the dry dock cycle, the CPP is removed and shipped back to the manufacturer for
inspection and maintenance, which includes replacement of the CPP seals.  Based on the above
information, the release rate of hydraulic oil from CPPs under normal operating conditions is
expected to be negligible.

       3.2.2   Underwater Replacements

       Approximately thirty underwater CPP blade replacements occur per year, and five to
seven of these include blade port cover removal to access the seal or center post sleeve for
replacement.5

       CPP Blade Port Cover Removal. According to Reference No. 2, as much as  five
                         Controllable Pitch Propeller Hydraulic Oil
                                           4

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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

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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

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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

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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

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2.


3.


4.


5.


6.


7.


8.

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

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

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

USEPA.  Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
       Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
       Register, Vol. 62, Number 150. August 5,1997.

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

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

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

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

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

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

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

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

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

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

The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
       Register,?. 15366. March23,1995.
                        Controllable Pitch Propeller Hydraulic Oil
                                          10

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                                      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

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                                                        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

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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

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Figure 4. Block Diagram of a CPP System
 Controllable Pitch Propeller Hydraulic Oil
                   14

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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

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       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
X

Equipment Expert
X
X
X
X

X


X
                            Controllable Pitch Propeller Hydraulic Oil
                                                16

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                      NATURE OF DISCHARGE REPORT
                                     Deck Runoff
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.
                                     Deck Runoff
                                          1

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2.0    DISCHARGE DESCRIPTION

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

       Decks are addressed in this NOD report under three categories: weather decks, aircraft
flight decks, and oiler weather decks. The runoff from each deck type reflects the materials and
treatment to which it is exposed during normal operations. All decks are exposed to a similar
and harsh environment; however, there is a core group of activities, weapons, and machinery
common to all ships. These common elements are addressed under the general category of
weather deck runoff. Runoff from flight decks from which aircraft are launched and recovered
and from oiler weather decks are addressed separately since the unique nature of the operations
conducted on these decks distinguishes them from other weather deck surfaces.

       2.1     Equipment Description and Operation

       2.1.1   Weather Deck Runoff

       Weather deck runoff consists of rain and other precipitation, seawater which washes over
the decks (green water),  and freshwater washdowns. Precipitation is usually the primary source
within 12 nautical miles (n.m.) of shore. Except for small craft, green water or salt spray over the
deck occurs primarily at sea and does not contribute to deck runoff while a ship is in port or in
protected coastal waters. Freshwater washdowns also occur, but contribute less  to weather deck
runoff than precipitation.

       The following paragraphs summarize each source that can contribute components to
weather deck runoff.1

       Deck Machinery - Ships have many pieces of deck machinery, such as windlasses,
       mooring winches, boat winches, underway replenishment gear, cranes, towing winches,
       and 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

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       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

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       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

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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

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       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

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the hydroplanes, rudder, shaft seals, periscope, and antennae, are greased on a submarine;
however, discharges from these sources are described in a separate NOD report. When
operating, submarines spend virtually all of their time submerged beyond 12 n.m., and no
activities are performed topside on a routine basis that could contribute to the contamination of
deck runoff. Similarly, while submarines are in port, the majority of work occurs on the inside of
the ship, not topside.  Based on this information, the deck runoff from submarines is not a
significant discharge.
3.0    DISCHARGE CHARACTERISTICS

       This section contains qualitative and quantitative information that characterizes the
discharge.  Section 3.1 describes where the discharge occurs with respect to harbors and 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

       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

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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

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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

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                                           9

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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
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                                            10

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       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

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                                           11

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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

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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
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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.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
       Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
       Register, Vol. 62, Number 150. August 5,1997.

 Connecticut.  Department of Environmental Protection. Water Quality Standards. Surface Water
       Quality Standards Effective April  8,1997.
                                     Deck Runoff
                                         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
i^&t$P^ipfe

r^wwStat?;
^ainw^olss,
$$&$&&?:$•
>T!$ "-A£Sf.Kff-'' ~>V v
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






X



Estimated




X


X
X

Equipment Expert
X
X
X
X

X



X

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                     NATURE OF DISCHARGE REPORT
                                     Dirty Ballast
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.
                                     Dirty Ballast
                                          1

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2.0    DISCHARGE DESCRIPTION

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

       2.1    Equipment Description and Operation

       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

       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 hi the discharge.

       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

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       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

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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

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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

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       Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
       22230. May 4, 1995.

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

USEPA.  Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
       Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
       Register, Vol. 62, Number 150. August 5,1997.

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

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

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

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

Mississippi. Water Quality Criteria for 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

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              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

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 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

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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

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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

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                      NATURE OF DISCHARGE REPORT
                         Distillation and Reverse Osmosis Brine
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.
                          Distillation and Reverse Osmosis Brine
                                           1

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2.0    DISCHARGE DESCRIPTION

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

       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

       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

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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

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       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

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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

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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.

USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
      Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
      Register, Vol. 62, Number 150. August 5,1997.

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

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

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

Hawaii. Hawaiian Water Quality Standards.  Section 11, Chapter 54 of the State Code.
                         Distillation and Reverse Osmosis Brine
                                         10

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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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             Distillation and Reverse Osmosis Brine
                               12

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